Research Roundtable

Office of Grants & Contracts Accounting

Office of Research & Sponsored Programs

April 5, 2011

GCA UPDATES Audit Updates

New Policies that Impact Researchers

Activity (Effort) Reporting

NIH Updates

Other GCA Hot Topics

Educational Sessions

GCAUpdates

Audit Update

A-133 Audit completed – Major Audit Findings

1. NIH Salary CAP not adjusted

2. Late reporting of FSRs

3. Subrecipient Monitoring and CFDA numbers

Audit Update (cont.)

Fringe Benefits Proposal submitted to DHHS on March 1, 2011 Rates have been submitted for these four

categories: Staff, Post Docs, Temp Faculty/Non-Faculty, Students

Extended leave being charged to federal grants

F&A Rate Study

Audit Update (cont.)

DHHS Audit Workplan includes audits related to: Indirect Costs claimed as Direct Costs Recharge Centers (Service Centers) Extra Service Compensation Payments Tuition and Fee Charging Practices

New Policies that Impact Researchers

Travel invoicing within 60 calendar days from the return date of the trip (Policy 6-14.0)

Travel on Sponsored Projects

P-Card cannot be used to purchase gift cards for study participants

Activity Reporting

Outstanding # of reports – 117 (for the first 2 quarters of FY 11)

Recertifying activity reports for previous quarters

Retroactive PEARs must match up with activity reports

Reminder – Activity Reports should drive PEARs

NIH Updates – NIH Policy Statement Changes

Exhibit 5: Selected Items of CostThe table presents specific items that may or may not be included in

the cost portion of grants.

Items Explanation of Allowable Costs

Donor Costs: Added

Donor costs are not considered a research patient care expense Donor costs are not considered a research patient care expense (see the Research Patient Care Costs chapter in IIB). Also see Incentive Costs in this exhibit.

Equipment: Added

Office equipment (copiers, laptops, desktop computers, personal handheld computers, fax machines, scanners, etc.) that is used for general office purposes (rather than justified as a specific research purpose) are not allowable as direct costs; they are allowable as an F&A cost.

Incentive Costs: New

Incentive payments to volunteers or patients participating in a grant-supported project or program are allowable. Incentive payments to individuals to motivate them to take advantage of grant-supported health care or other services are allowable if within the scope of an approved project. See Salaries and Wages/Bonus Funds & Incentives in this exhibit for incentive payments to employees.

NIH Updates – NIH Policy Statement Changes (cont.)

Items Explanation of Allowable Costs

IRB or IACUC Costs: New

Costs associated with IRB review of human research protocols, or IACUC review of animal research protocols, are not allowable as direct charges to NIH-funded research unless such costs are not covered by the organization's F&A rate.

Laboratory Directed Research & Development:

New

NIH awards to DOE laboratories will not include the proportionate share of F&A costs for Laboratory Directed Research & Development (LDRD) in accordance with the MOU with the Department of Energy dated June 18, 1998, although the NIH will not restrict the DOE laboratory contractors from recovering LDRD costs within the total funding included in an award. In addition, DOE has agreed to waive the Overhead Rate on all NIH grant awards to DOE laboratory contractors.

NIH Updates – NIH Policy Statement Changes (cont.)

Items Explanation of Allowable Costs

Maintenance and Repair Costs:

New

Costs incurred for necessary maintenance, repair or upkeep of buildings and equipment (including Federal property unless otherwise provided for) which neither add to the permanent value of the property nor appreciably prolong its intended life, but keep it in an efficient operating condition, are allowable. Costs incurred for improvements which add to the permanent value of the buildings and equipment or appreciably prolong their intended life shall be treated as capital expenditures.

Meals:

Added When certain meals are an integral and necessary part of a meeting or conference (i.e., a working meal where business is transacted), grant funds may be used for such meals. The cost of meals served at a meeting or conference, for which the primary purpose is the dissemination of technical information, is allowable. In all cases the cost of any meal must meet a test of reasonableness. However, recurring business meetings, such as staff meetings, should not be broadly considered as meetings for the primary purpose of disseminating technical information in order to justify charging meals or refreshment to costs to grants.

NIH Updates – NIH Policy Statement Changes (cont.)

Items Explanation of Allowable Costs

Pre-Award (Pre-Agreement) Costs:

Added

Pre-Award Costs are generally not applicable to training grants or fellowships. See respective sections for Individual Fellowships and Institutional Training Grants in the Ruth L. Kirschstein National Research Service Award chapter in IIB for additional information.

Profit or Fee:

New

Except for grants awarded under the SBIR/STTR programs, under an NIH grant, no profit or fee will be provided to a for-profit organization, whether as a grantee or as a consortium participant. A profit or fee under a grant is not a cost, but is an amount in excess of actual allowable direct and F&A costs. In accordance with normal commercial practice, a profit/fee may be paid to a contractor under an NIH grant providing routine

goods or services to the grantee.

Items Explanation of Allowable Costs

Salaries and Wages /Payments for Dual Appointments

For investigators receiving compensation from the institution (grantee/contractor) and separately organized clinical practice plans, compensation from such sources may be included in the institutional base salary (IBS) budgeted and charged to NIH sponsored agreements if all of the following criteria are met:

-Clinical practice compensation must be set by the institution. *

-Clinical practice activity must be shown on the institution's payroll or salary appointment forms and records approved by the institution.

-Clinical practice compensation must be paid through or at the direction of the institution.

-Clinical practice activity must be included and accounted for in the institution's effort reporting and/or payroll distribution system.

-The institution must assure that all financial reports and supporting documents associated with the combined IBS and resulting charges to NIH grants are retained and made available to Federal officials or their duly authorized representatives consistent with the requirements of 45 CFR part 74.53 (A-110 Subpart C 53).

* "Set by the institution" means the grantee/contractor institution must be in a position to document and certify that the specified amount of clinical practice compensation is being paid in essentially the same manner as other specified amounts of the committed IBS (compensation) of the investigator. Further, this requires that the IBS not vary based on the specific clinical services provided by investigator within the periods for which total IBS is certified by the grantee institution.

NIH Updates – NIH Policy Statement Changes (cont.)Items Explanation of Allowable Costs

Service Charges:

Major verbiage

Change

Allowable. The costs to a user of organizational services and central facilities owned by the grantee organization, such as central laboratory, technology infrastructure fees, computer services and next generation computing/communication costs, are allowable provided that they are not covered by F&A costs. They must be based on organizational fee schedules consistently applied regardless of the source of funds.

Visa Costs:

New

Allowable direct cost as part of recruiting costs on an NIH grant, as long as the institution has an employee/employer relationship with the individual. It is the responsibility of the institution to monitor the status of the individual's visa and ensure they have sufficient time to fulfill the obligations of the research they are being paid for on the grant. However, if the person is already an employee and the cost in question is a visa renewal then this isn't a recruiting cost so the cost would not be an allowable charge to a grant. Expedited processing fees are generally unallowable unless and until they become part of standard processing fees. Fraud fees are allowable if they are required fees. Department of Homeland Security SEVIS Form I-901 is a required fee and is allowable. See also Recruitment Costs in this exhibit.

Other GCA Hot Topics

Cost Transfers

Award Close-out

Educational Sessions Accounting 101 – GCA/ORSP Module II

Next session in May (to be announced by HR)

National Council of University Research Administrators (NCURA) Non-Financial Research Compliance

Date: April 18, 2011Time: 10:00 AM until 2:00 PM (there will be at 30 minute break at 12:00 noon)Location: Psychiatry Auditorium 1st Floor

Negotiating Federal Contracts and Pass-Through Awards Date: May 2, 2011Time: 10:00 AM until 2:00 PM (there will be at 30 minute break at 12:00 noon)Location: Psychiatry Auditorium 1st Floor

If interested in specific training please let us know and we will come to you!

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