Research Administrators Symposium – September 25, 2019 · by all Federal awarding agencies. § A Federal awarding agency may use a rate different from the negotiated rate only when

Research Administrators Symposium – September 25, 2019Presented by: Tim Wester, Rebecca Valdez, Rebecca Garcia, Hannah Clark

Tim Wester

§ Indirect Costs are assessed according to the University’s Federally Negotiated Indirect Cost Recovery Rate Agreement.


§ Office of the Vice President for Research is an enterprise unit and does not get any support from the State or University for operations support.



§ F&A is vital to the financial health of the research enterprise and individual departments.




§ OVPR financially supports the Office of Sponsored Project, Contract and Grant Accounting as well as the Office of Research & Compliance (COI, Institutional Review Board, Office of Animal Welfare, Research Integrity, Industrial Security, Export Control, Safety Compliance, etc.)




§ OVPR financially supports the Office of Sponsored Project, Contract and Grant Accounting as well as the Office of Research & Compliance (COI, Institutional Review Board, Office of Animal Welfare, Research Integrity, Industrial Security, Export Control, Safety Compliance, etc.)

§ OVPR serves eleven colleges in UNM’s main campus and the four branch campuses by providing infrastructure for proposal development and submission.

§ Negotiated rates must be accepted by all Federal awarding agencies.


§ A Federal awarding agency may use a rate different from the negotiated rate only when required by Federal statute or regulation.



§ Except where specifically identified in a program solicitation, the applicable negotiated indirect cost rate must be used in computing indirect costs.



§ Except where specifically identified in a program solicitation, the applicable negotiated indirect cost rate must be used in computing indirect costs.

§ Use of an indirect cost rate lower than the organization's current negotiated indirect cost rate is considered a violation of UNM’s cost sharing policy.

§F&A Rates for Pass-through Entities to Subrecipients.

§ 2 CFR 200.331 Requirements for pass-through entities states every subaward must include the subrecipient’s federally recognized indirect cost rate agreement.



§ A subrecipient has the legal authority to use its own indirect cost recovery rate unless the funding opportunity indicates restrictions on recovering administrative costs.



§ A subrecipient has the legal authority to use its own indirect cost recovery rate unless the funding opportunity indicates restrictions on recovering administrative costs.

§ In some cases the subrecipient’s F&A may be a higher rate than the pass-through entity.

§ The Modified Total Direct Cost(MTDC) base is used when an organization’s federally negotiated rate can be applied.

§ It is derived by excluding certain costs from the direct cost total.

§ Typically excludes capital equipment and fabrication of equipment, tuition remission, rent, scholarships, and fellowships, as well as the amount of each subaward over $25,000.

§ Under Uniform Guidance, participant support costs are also excluded.

§ The Total Direct Cost (TDC) base includes all of the direct costs being charged to the sponsor. Nothing is excluded from the base prior to calculating the indirect costs.

§ This base is typically used when a non-federal sponsor declines to pay the organization’s federally approved indirect cost recovery rate.

§What is the F&A Rate for Contracts vs Grants?

§ FEDERAL

§ 54.0% Research DOD

§ 52.0% Instruction

§ 51.5% On Campus Research

§ 43.5% Other Sponsored Programs

§ 29.0% Off Campus DOD

§ 26.0% Off Campus Research

§ Non-FEDERAL

§ 54.0% Industry Sponsors

§ 29.0% Off Campus Industry Sponsor

§ 20.0% New Mexico Public Sponsor

§What is the F&A Rate for Contracts vs Grants?

§ FEDERAL

§ 54.0% Research DOD Contract




§ 29.0% Off Campus DOD Contract


§ Non-FEDERAL




§What is the F&A Rate for Non-Profits/Foundations?

§ FEDERAL







§ Non-FEDERAL




§What is the F&A Rate for Non-Profits/Foundations?

§ FEDERAL







§ Non-FEDERAL

§ 54.0% Industry Sponsors§ 29.0% Off Campus Industry Sponsor


§ Most funded research programs should have some level of committed effort.


§ UNM has determined the minimum amount of effort committed to a specific sponsored research activity may be no less than 1%.



§ In most cases, it is expected that the effort will be substantially larger than 1%.




§ UNM has created a Minimum Effort Policy which applies to the Principal Investigator, Co-Investigator and Key Personnel.




§ UNM has created a Minimum Effort Policy which applies to the Principal Investigator, Co-Investigator and Key Personnel.

§ Some exceptions excluded from this policy:

§ Equipment Grants§ Doctoral Dissertation Grants

§ Training Grants§ Travel/Conference Grants§ NSF funded Research Experience for

Undergraduate (REU) Supplements

Rebecca Valdez

Rebecca Valdez

• The workflow closeout is used to closeout your award and request a NCE

• Notice is generated 90 days prior to your award end date.

• Workflow

§ You have received notification that your award is ending in 90 days.

§ Department -making a decision to Close or Extend

§ If closing the workflow will continue and C&G accounting will start the closeout process

§ If extending it routes to OSP

§ FM will receive your request

§ Decision is made whether to Continue, End, or Close out

§ Comments will be copied from “Extend or Close Out Grant”

§ Forward to OSP to request a NCE to the sponsor.

#1 Decision

#2: Comments will be copied over from “Extend Or Close Out Grant” Screen

§ Once an approval or denial of the NCE has be received.

§ Workflow will be updated “approved” or “Not approved”

§ Department will get a notification.

Rebecca Valdez

§ Prior approvals are required from Federal awarding agencies for one or more of the following program or budget-related reasons:§ Change in the scope or the objective of the project or

program.§ Change in a key person specified in the application or the

Federal award.§ The disengagement from the project for more than three

months, or a 25 percent reduction in time devoted to the project, by the approved project director or PI.

§ The inclusion of costs that require prior approval in accordance with Subpart E—Cost Principles.

§ The transfer of funds budgeted for participant support costs as defined in §200.75 Participant support costs to other categories of expense.

§ Unless described in the application and funded in the approved Federal awards, the subawarding, transferring or contracting out of any work under a Federal award, including fixed amount subawards as described in §200.332 Fixed amount subawards.

§ Changes in the approved cost-sharing or matching provided by the non-Federal entity.

§ The need arises for additional Federal funds to complete the project.

§200.308 Revision of budget and program plans.

(b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section.

PLEASE NOTE: Some agencies are more restrictive and may require prior approval for additional items, such as:

• Foreign travel

• Equipment

READ YOUR AWARD TERMS & CONDITIONS!

https://www.ecfr.gov/cgi-bin/text-idx?SID=cbf6bbba1b3b2a3d3601be55fb74ed4a&mc=true&node=se2.1.200_1308&rgn=div8

When is this budget form used?• When any budget change is needed to

the existing award budget in Banner.

Excel template can be found on C&G’s website and OSP’s website:

http://cgacct.unm.edu/forms.htmlhttp://osp.unm.edu/forms/index.html

Submitted by the PI and approved by• Department• C&G Fiscal Monitor

If agency approval is required, it will then route through OSP

http://cgacct.unm.edu/forms.html

http://osp.unm.edu/forms/index.html

§ Expect an email from the award team member (award receipt)

§ PI/Dept email that includes what is needed for your set up. (ABS, CS, GMT, etc.,)

§ Items that can potentially hold up your award (PII/Export Control)§ Upload Preliminary Security Questionnaire (PSQ) for PII Review§ Upload ECES Form for Export Control Review

§ Complete FCOI renewed annually (August)

§ Complete PHS Disclosures

§ All awards need a Cayuse record

Rebecca Garcia

How pre-award setup impacts post-award§ Risk Assessment

§ Carryover restrictions§ Supporting receipts

§ Collection of supporting documentation§ Budget § Budget Justification§ Scope of Work§ Indirect Cost Rate (aka F&A)

§ Subaward Negotiation§ Invoicing frequency§ Notice of changes in budget

• Option 1: Initiated by OSP when NOA received

• Option 2: Initiated by Department via Subaward Request Form on OSP Website (https://forms.unm.edu/forms/srf)

https://forms.unm.edu/forms/srf

• Initiated by Department via Subaward Request Form on OSP Website (https://forms.unm.edu/forms/srf)

https://forms.unm.edu/forms/srf

Hannah Clark

§ Grant agreement means a legal instrument of financial assistance between a Federal awarding agency or pass-through entity and a non-Federal entity that, consistent with 31 U.S.C. 6302, 6304:a) Is used to enter into a relationship the principal

purpose of which is to transfer anything of valuefrom the Federal awarding agency or pass-through entity to the non-Federal entity to carry out a public purpose authorized by a law of the United States (see 31 U.S.C. 6101(3)); and not to acquire property or services for the Federal awarding agency or pass-through entity's direct benefit or use;

b) Is distinguished from a cooperative agreement in that it does not provide for substantial involvementbetween the Federal awarding agency or pass-through entity and the non-Federal entity in carrying out the activity contemplated by the Federal award.

§ Cooperative agreement means a legal instrument of financial assistance between a Federal awarding agency or pass-through entity and a non-Federal entity that, consistent with 31 U.S.C. 6302-6305:a) Is used to enter into a relationship the principal

purpose of which is to transfer anything of valuefrom the Federal awarding agency or pass-through entity to the non-Federal entity to carry out a public purpose authorized by a law of the United States (see 31 U.S.C. 6101(3)); and not to acquire property or services for the Federal awarding agency or pass-through entity's direct benefit or use;

b) Is distinguished from a grant in that it provides for substantial involvement between the Federal awarding agency or pass-through entity and the non-Federal entity in carrying out the activity contemplated by the Federal award.

§ Contract means a legal instrument by which a non-Federal entity purchases property or services needed to carry out the project or program under a Federal award. The term as used in this part does not include a legal instrument, even if the non-Federal entity considers it a contract, when the substance of the transaction meets the definition of a Federal award or subaward (see §200.92 Subaward).

Documents

Research Administrators Symposium – September 25, 2019 · by all Federal awarding agencies. § A Federal awarding agency may use a rate different from the negotiated rate only when