Power Point.ppt · should total $32,806, year 2 should total $44,858. Please adjust budget justification page based on itemized list, using whole numbers only. Other Direct Costs

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1

Internal Forms – Policies and Procedures

Sponsored Programs Administration

Crystal Miller, MPA – Assistant Director

Amy Carson, MPA – Grants and Contracts Specialist

January 2011

University of Nebraska Medical Center

Goals• Understand why internal forms are purposeful in meeting

compliance requirements

• Reduce risk to the university through established systems


that are properly used by the campus community

• Equip administrators with the “tools” to articulate compliance

requirements as necessary

• Reduce re-work required when forms are completed

inaccurately

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2

Agenda

Internal Budget

F&A Waiver


Routing Form

PI Assurance


Internal Budget

• UNMC Salary

• Inflation Factor

• Effort

• Benefits

• Cost Share

• Subcontracts

• Signatures


UNMC Salary

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Key Points – UNMC Salary

• Accuracy and consistency

1. Documentation is the key

• Federal Policy – OMB Circular A-21Federal Policy OMB Circular A 21

• University IBS Policy

• Grants Policy Statement

• NIH Salary Cap


Federal Policy

• OMB Circular A-21 and NIH Grants Policy

Statement permit salary and wage charges

t d d t th t t th tto sponsored awards to the extent that:

• Total employee compensation conforms to

established and consistently applied policies of

the institution

• Such charges are for work in direct performance

of the award

Federal Policy

• OMB Circular A-21

• Charges for work performed on sponsored agreements by

faculty members must be based on the individual faculty


y y

member’s regular compensation during the period of

performance. Charges must be made at the allowable

base rate; the faculty member cannot receive additional

compensation for his or her participation in a sponsored

project over and above the appropriate portion of the

base salary allocated to the project

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UNMC Policy• Institutional Base Salary Policy (SPA -> Policies and

Procedures -> Institutional Base Salary Policy)

• UNMC IBS includes:

• UNMC base salaryUNMC base salary

• Specified UNMC stipends – based on wage codes

• UNMC Physicians base salary

• Nebraska Pediatric Practice base salary

*Does not apply to COD Practice Plan

http://www.unmc.edu/policy/index.cfm?L1_ID=18&L2_ID=19&CONREF=28

UNMC Policy

• Institutional Base Salary Policy

• UNMC IBS includes:

• UNMC base salary


y

• Specified UNMC stipends

• UNMC Physicians base salary

• Nebraska Pediatric Practice base salary

* If there is going to be a raise a documentation letter is required

Personnel – Grants Policy Statement• Key Personnel – individuals who contribute in a substantive

measurable way to the scientific development or execution of

the project


• Other Significant Contributor/Collaborator – may contribute to

the scientific development or execution of the project, but are

not committing any specified measurable effort to the project

• Consultants – individual who provides professional advice or

services for a fee, but normally not as an employee of the

engaging party

http://grants.nih.gov/grants/policy/nihgps_2010/index.htm

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NIH Notice

• NOT-OD-10-041 – Salary limitation on

grants, cooperative agreements, and

t t


contract

• 01/01/2010 – 12/31/2011 = $199,700

• Executive compensation freeze – will

remain the same for 2011

NIH Guide – Sign UpNIH Guide announcements (PAs, RFAs and Notices) are published daily. At the

end of each work week (usually on Friday afternoon), NIH transmits an e-mail to NIH Guide LISTSERV subscribers with the Current Weekly Table of Contents (TOC), including links to announcements published during the week. An up-to-date listing of new announcements published during the week may be checked anytime on the Current Weekly TOC


week may be checked anytime on the Current Weekly TOC.

To Subscribe to the NIH Guide LISTSERV, send an e-mail to [email protected]

with the following text in the message body (not the "Subject" line):

subscribe NIHTOC-L your name

(Example: subscribe NIHTOC-L Bill Jones)

Your e-mail address will be automatically obtained from the e-mail message and

add you to the LISTSERV.


Inflation Factor

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Key Points – Inflation Factor

• NIH allows for a yearly maximum inflation

rate of 3%.

• Although UNMC received 0% in the current fiscalAlthough UNMC received 0% in the current fiscal

year, you are budgeting for 5 years – at which

point we hope we’re still not at 0% increases


Sponsor Specific Guidelines - NIH

• NOT-OD-10-039

• The FY 2010 appropriation provides NIH a

2 percent inflation allowance to NIH investments2 percent inflation allowance to NIH investments

in research supported by research grants.


Effort

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Key Points – Effort

• A federally mandated process to confirm that the

salary and wages charged to sponsored projecs

are reasonable and reflect the actual work

performed

• OMB Circular A-21 requires that institutions

develop a mechanism to confirm how individuals

actually expended effort during a specific time

period.


Federal Policy

• OMB Circular A-21:

• Requires certification of effort spent by all

employees whose salaries are charged directlyemployees whose salaries are charged directly

to federal and federal flow-through funds

• Effort reporting must be completed and certified

on a regular basis

• Failure to meet these requirements puts the

University at risk for audit disallowances

resulting in significant financial penalties


Example of Non-Compliance

• Northwestern University

• Commitments did not match effort worked which

did not match the actual pay of personneldid not match the actual pay of personnel

• Paid $5.5 million to settle issues related to

problems with effort reporting, on a contracts

and grants base of $325 million

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SPA Action

• Compare application budget to application

budget justification to internal budget – all

t t h


must match

False Claims Act

The Act establishes liability when any person on

entity improperly receives from or avoids

payment to the Federal government


payment to the Federal government

The Act Prohibits:

• Presenting false claims to the government

• Making false records to get a false claim paid


Benefits

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Key Points – Benefits• UNMC Rate to be used on all grant applications

• Facutly/Staff: 28%

• Students: 8%

Notes:

• Average of all employees

• SPA documents with letter from upper administration

• Use regardless of % appointment

• DOD may require your to itemize

• Especially students

Key Points – Benefits cont’d

Other Institutions (examples)

• North Carolina State: 28%

• University of Iowa: 36%


University of Iowa: 36%

• University of Minnesota: 32.3%

• University of California San Diego: 25.8% - 34.6%

• Creighton:

• Federal Grants: 23.2%

• Non-Federal Grants: 28.5%

• Graduate Student: 0%

• Undergraduate Student: 8%


Federal Policy


• Fringe benefits shall be treated in the same

manner as salaries and wages of themanner as salaries and wages of the

employees receiving benefits.

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NIH Guide – PHS 398 Instructions• Fringe Benefits

• May be requested in accordance with institutional guidelines for each position, provided the costs are treated consistently by the applicant organization as a y y pp gdirect cost to all sponsors.

*There is discussion of negotiating a fringe rate with the Fed’s just like an F&A rate

Rare Exceptions - DOD• Email received from DOD GMS

• Fringe - Please tell me what makes up the fringe pool and the percentages associated with them?

• Personnel (Salary) - In year 2, please adjust TBA (Research Tech) to $31,518 which is a 3% adjustment from year 1. Salary listed in year 2 is currently too high. Please adjust f i di l


fringe accordingly.

• Supplies - In year 1 and 2, please use actuals, which is based on itemized list. Year 1 should total $32,806, year 2 should total $44,858. Please adjust budget justification page based on itemized list, using whole numbers only.

Other Direct Costs

• a) Mouse housing calculations are off based on Animal per diem cost sheet. (Year 1: $1.05 per day/per cage 2011 rate, or $1,176, Year 2: $1.09 per day/per cage [includes a 4% adjustment for year 2012], or $5,494. Please adjust language in budget justification page and calculations in budget.

• b) Core Facilities - include the hourly cost for Flow Cyometry & Confocal and the number of hours used for each.

• c) Histology - Provide pricing sheet for histology. Include cost per slide(s) and number of slides used for year 1.

Please adjust budget summary page (last page) accordingly

Student Rates - Examples

Department 1 Department 2


UPFF Fund A Student Senate Fee $10

UPFF Fund B Health Center Cost $199.50$1247 50

UPFF Fund A Student Senate Fee $10

UPFF Fund B Health Center Cost $199.50

UPFF Health Insurance $1247.50

Immunization Record Fee $20

Library Fee $72

Major Medical $256

Total $1920 (8%)

$1247.50UPFF Fund B Student Life Center $115

Student Health Insurance $1060

Immunization Record Fee $20

Library Fee $72

Major Medical $30

Parking $156

Total $1862.5 (8%)

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Cost Share


Key Points – Cost Share

• UNMC: Zero tolerance practice


Federal Policy


• Cost Sharing vs. Matching

I Ki d• In-Kind:

• Third party in-kind contributions means the value of

non-cash contributions provided by non-Federal third

parties. Third party in-kind contributions may be in the

form of real property, equipment, supplies and other

expendable property, and the value of goods and

services directly benefiting and specifically identifiable

to the project or program.

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Sponsor Specific Policy

• NIH – not required per the Grants Policy

Statement


• HRSA – funding opportunity announcement

will specify if matching or cost sharing is

required

Cost Share

Results in:

• Negatively affects UNMC’s F&A rate

Ad i i t ti b d t ki


• Administrative burden – tracking

• Tying-up investigators effort


Facilities & Administrative Costs (F&A)

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Key Points – F&A

• Total Direct Cost (TDC)

• Refers to the direct costs of the proposed budget

Key Points – F&A Applies to:

• Modified Total Direct Costs (MTDC) -

• Includes salaries and wages, benefits, supplies,

service travel and subcontracts up to the first


service, travel and subcontracts up to the first

$25,000 of each subcontractor

• Excludes equipment, capital expenditures,

charges for patient care and tuition remission,

rental costs, scholarships and fellowships, as

well as the portion of each subcontract in

excess of $25,000


UNMC Policy

• Federally Negotiated Rates

• Organized Research: 48.5%

• Instruction: 40%

• Other Sponsored Accounts: 35%

• Off-Campus: 26%

• Industry Sponsored: 26%

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HRSA Policy

• HRSA RFA’s normally require a lower rate (8%), if

not stated, use the negotiated rate


Example - HRSA• Federally Negotiated:

1. Indicate the most recent indirect cost rate(s), also known as

Facilities and Administrative Costs {F&A} established with a

cognizant Federal office or in the case of for profit


cognizant Federal office or, in the case of for–profit

organizations, the rate(s) established with the appropriate

agency.

• Other:

1. Indirect costs under training grants to organizations other than

state, local or Indian tribal governments will be budgeted and

reimbursed at 8% of modified total direct costs rather than on

the basis of a negotiated cost agreement, and are not subject to

upward or downward adjustment.


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Facilities and Administrative (F&A) Cost Waiver Request Form


Key Points

• Defined as the acceptance of a rate lower

than the approved F&A rate

• Granted on a case-by-case basis

1. Must be adequately justified


UNMC Policy• Required anytime it is not the standard rate

1. Request for waiver made at the time of award

2. If requesting less than published rate, approval is needed at the

ftime of application

• Provides justification for lower rate to SPAccounting

• Rare with for-profit companies

• Have become rare altogether

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Subcontracts

Federal Funding Accountability and Transparency Act (FFATA)New Policy

• Requires recipients of Federal awards to report on

executive compensation and first-tier subawards


• First-tier = any subcontracting of funds that obligates

$25,000 or more in federal funds

• Reporting total compensation of executive:

• 80% or more of annual gross revenues from federal

sources and

• $25,000,000 in annual gross revenues from federal

sources


Key Points – Subcontract Out

• Documents required at the time of submission:

• When the principal investigator is at UNMC• Intent to Form a Consortium or Face Page Form Page 1

S f• Statement of Work

• Detailed Budget

• Budget Justification

• Checklist – document F&A rate

• Contact Information

• Internal Forms

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Key Points – Subcontract In

• Documents required at the time of submission:

• When the principal investigator is at another institution• Intent to Form a Consortium or Face Page Form Page 1

S f


• Statement of Work

• Detailed budget

• Budget justification

• Checklist

• Copy of any other documentation the other institution requires

• Internal Forms


Federal Policy


• To provide reasonable assurance that Federal

award information and compliance requirementsaward information and compliance requirements

are identified to subrecipients, subrecipient

activities are monitored, subrecipient audit

findings are resolved and the impact of any

subrecipient noncompliance on the pass-

through entity is evaluated


Signatures

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Key Points – Signatures

• Signature Authority is verifying the validity of the

information included in the internal budget

• When personnel from other department are on theWhen personnel from other department are on the

budget, signature is required from signature

authority in corresponding department


Board of Regents Policy

• Executive Memorandum No. 13• “The President hereby delegates the following authority to each

Chancellor with respect to personnel under his or her

jurisdiction...

• ….Each Chancellor may further delegate all or any portion of the

authority described above to the appropriate Vice Chancellor(s);

provided, that each such further delegation of authority to

approve personnel actions shall be documented in writing,

signed by the Chancellor and filed of record with the Corporation

Secretary before the same shall be effective.”



• Executive Memorandum No. 14• Delegation of administrative authority to approve certain types of

university contracts, and requirements for submittal and

execution of contracts requiring approval by the board of

regents

• Each Chancellor may further delegate all or any portion of the

authority to such administrative officers and professional staff

employees under his or her jurisdiction as will provide for the

most efficient conduct of University campus business affairs.

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• Conclusion• The Chancellor may delegate contract signature authority.

Individuals with the authority to sign contracts on behalf of

UNMC are listed in the Contract Signature Authority Table

* UNMC Primary: Deborah Vetter

Signing Other Documents

• CDA – risks the PI takes on instead of the

institution


• MTA – Generally handled by UNeMed


Routing Form

1/24/2011

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Key Points• Faculty Member: Are they eligible to apply

• UNMC chargeback number: must be a non-sponsored projects account

P t i id d F&A ll bl di t• Postage is considered F&A – unallowable direct cost, even on non-federal projects


Federal Policy

• OMB Circular A-21

• Unallowable Costs:

9 C i ti t9. Communication costs:

Costs incurred for telephone services, local and long

distance telephone calls, telegrams, postage,

messenger, electronic or computer transmittal

services and the like are allowable.

Key Points Cont’d• Project Type: Determines WBS number

1. Chose only one

• Special Considerations: mark if applicable


• IRB/IACUC/IBC: used in the JIT process1. Protocols compared to the application contents

• Other Considerations• Required conversations with the Chair and/or Dean

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Principal Investigator Assurance Form


Key Points

• PI certification of application’s validity and

accuracy and acceptance of responsibility

• Required for all PI’s on NIH applications


Sponsor Specific Guidelines - NIH

• NOT-OD-06-054

• Signature of PI on application no longer

requiredrequired

• Responsibility of the applicant organization prior

to submitting an NIH application

* Applies to NIH applications only

1/24/2011

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Questions


Thanks!
