WHAT CAN SPONSORED PROGRAMS DO FOR YOU?

John D. HulveyDirector, Sponsored Programs Administration and Accounting

October 21, 2013

What is a Sponsored Program?

An award from an external source (Sponsor)

Must provide accountability for its disbursement

Is NOT a gift - legal stipulations for use Is NOT permanent

OUR MISSION• To enhance and facilitate the

ability of faculty, staff, and students to develop and achieve their goals in research, educational programming, and service delivery through successful competition for external funding.

This mission will be accomplished while maintaining responsible stewardship of extramural sponsored projects as directed by the values of our office and the applicable federal, state, and agency regulations and policies.

SPONSORED PROGRAMS PERFORMS 4 BASIC FUNCTIONS:

Distribute information concerning potential funding opportunities

Review agency guidelines and assist with the overall proposal submittal process (including budget development)

Negotiate sponsor agreements, relationships, and award terms and conditions

Interpret and apply the regulatory, contractual, and administrative requirements applicable to sponsored projects

Funding Opportunities: The Search for Sponsors Ask other successful researchers -(how/where

did they start) Funding agencies’ web sites (NIH, NSF) Grants.gov Office of Sponsored Programs (OSP)

Funding Web sites COS Funding Opportunities through ProQuest

Funding Announcements OSP Newsletter External Funding Advisor

Funding ResourcesBy request, our office will run tailored funding searches depending on your indicated interests.

Contact us for individual assistance: 568-6872

COS Funding Opportunities through ProQuest (from on/off campus) Grants.gov NSF Active Funding Opportunities & Deadlines National Institutes of Health (NIH) Receipt Dates/Deadlines The Grant Advisor Search OSP Web Site

Search feature: by Sponsor, Deadline, or Key Word Sponsor Listings Limited Submissions

OSP Website Support: http://www.jmu.edu/sponsoredprograms/index.shtml

Effective Proposal Development

Getting Started:Formulate an IdeaConsider Proposal Writing WorkshopSearch for and Target Funding Source(s)

Pick up Speed (OSP Recommended):Proposal PreparationBudget DevelopmentSecure Departmental and Dean approvals

OSP’s Role: Coordinationand Compliance University Review:

Verify sponsor’s requirements are metVerify accuracy and allowability of budget

items and completeness of budget justificationEnsure contractual requirements are

acceptableObtain final university approvalSubmit final proposal package to sponsor

Parting the Red Tape: Plan Contact OSP early so we can add value

Review sponsor’s terms and conditionsAlert you of red flags/special considerationsDevelop budgets

Collaborators, on or off-campusSubstantial lead time is required to obtain

collaborators’ approved materials

Writing the Proposal: Follow the solicitation or RFP CLOSELY

Use sponsor’s buzzwords/answer questions/

follow specified format/avoid jargon & acronyms Identify the problem/need/new knowledge Demonstrate Significance of the work

Why is it important and what are the “broader impacts?”

State proposed/expected outcomes Provide a timeline/milestones/deliverables Show how you will assess/evaluate efficacy

Budget Development(NOT an afterthought) Consider “needs” for the project in terms

of narrative, not cost (dollars)Senior Personnel Requirements

Who, how much time, when Example: 1 summer month, 1 course release

Beware of “over commitment” Student Support

Undergraduate, Graduate, PostDoc Example: $10/hr x 12 summer weeks x 20 hours/wk x 2

Budget Development (continued): Equipment Needs (items with cost >$5,000) Supply Needs (items with cost <$5,000) Contractual: Collaborator/Consultant Needs

“Collaboration Checklist” on OSP website Subawards require budget, budget justification, statement of

work, letter of commitment (at minimum) Travel Requirements

Location, duration, number of travelers Facilities and Administration (F&A) (overhead, IDC)

Required unless disallowed by the sponsor

OSP will translate your budget narrative into an Excel Budget template for review and refinement Travel projections – let us handle the details Salary and wage calculations

Direct vs. Indirect Costs (F&A)DIRECT costs Easily identified with a

sponsored project with a high degree of accuracy

EXAMPLES: Senior personnel and student

salaries Travel for dissemination of

results Technical and laboratory

supplies consumed on the project

Subawards to collaborators

INDIRECT costs Necessary to support

research and other sponsored projects, but cannot be readily assigned to individual projects

Facilities operations (utilities, maintenance, security, etc.), libraries, departmental administration, and general administration

EXAMPLES:

Salaries & wages for administrative and clerical staff

General office supplies Postage & local telephone costs

BEWARE UNALLOWABLE

COSTS

The “Biggies” Salaries of administrative and clerical staff Office supplies Postage Local telephone costs Memberships Entertainment costs & alcohol

Per Federal Costing Regulations,OMB A-21 (pertains to educational institutions)

What is OMB A-21?OMB A-21, Cost Principles for Educational Institutions is located in Title 2 in the Code of Federal Regulations (2 CFR, part 220)

Costs on grants/other forms of assistance must be “Allowable”

The tests of ALLOWABILITY of costs are: They must be REASONABLE – the “Prudent Person” test They must be ALLOCABLE – able to be assigned with high degree of certainty to a project They must be CONSISTENT – treated the same in like circumstancesALLOWABLE – not on the prohibited list in A-21 Section J (54 items)

Caveat – There MAY be some exceptions to these excluded costs depending on unique situations. Talk to your grants specialist.

Why Should I Care About OMB A-21?

“Contemplating any business act, an employee should ask himself whether he would be willing to see it immediately described by an informed and critical reporter on the front page of his local paper, there to be read by his spouse, children, and friends.”

--- Warren Buffet

The Headline Test

Final Submission:

By University policy, ALL proposals for external funding much be submitted through the Office of Sponsored Programs (no matter how large or small)

OSP is already established in most electronic portals and systems (Grants.gov, FastLane etc), but final institutional approval must be obtained before submissions can occur

Proposals should be presented to OSP for final review and submission 5 working days before the submission deadline

Pre-Submission Considerations:Compliance Items:

Financial Conflicts of Interest with yourself or collaborators

If federally-funded “Research” or Public Health Service funded, then MUST submit a Financial Conflicts of Interest Disclosure Form(s) for all investigators PRIOR to application

If selected for funding, then must take FCOI training prior to award

At Award/Regulatory Compliance: Individuals cannot sign agreements, only the

university’s delegated authorized representatives OSP will coordinate the review, negotiation, and

signing of ALL agreements (contracts, subaward agreements, cooperative agreements, etc.) Includes Non-Disclosure, Teaming Agreements, and

Materials Transfer Agreements Common “Problem” wording includes:

Indemnity (Hold Harmless) and Liability Clauses Governing Law Clauses Arbitration/Mediation

Other Compliance Considerations: Financial Conflict of Interest (FCOI)

FCOI training required for all investigators prior to expenditures

Human Subject Research requiring Institutional Review Board (IRB) review

Animal Research requiring Institutional Animal Care and Use Committee (IACUC) review

Responsible Conduct of Research (RCR) Interpretation of OMB Circulars, Federal and

Sponsor regulations

Regulatory Hierarchy:

What rules apply to my award?Award Terms and Conditions- Sponsor

University Policies

State Regulations

Federal Regulations

NO terms can violate Federal Law

Regulatory Hierarchy:Award Terms and Conditions- Sponsor

Sponsors generally include terms & conditions (T&Cs) with award agreements or documents. These describe grantees’ requirements:

duration of project invoicing instructions Reporting & deliverable requirements Closeout

Regulatory Hierarchy:University Policies

Sponsors’ T&Cs are compared against University policy to reveal any conflicts such as:

Hiring & pay practices Anti-discrimination policies Educational mission of University Insurance Coverage & limits Others?

Regulatory Hierarchy:

State Regulations Sponsors’ T&Cs are compared

against state law to reveal any conflicts such as:

Governing law/sovereign immunity Anti-discrimination policies Indemnification & liability Disputes Settlement/Binding Arbitration

Regulatory Hierarchy:

Sponsors’ T&Cs are compared against federal law to reveal any conflicts.

Remember:

NO terms can violate Federal Law

Federal Regulations

What is OMB A-110 all About? OMB A-110, Uniform Administrative Requirements for

Institutions of Higher Education (and hospitals and other non-profits) is located in Title 2 in the Code of Federal Regulations (2 CFR), part 215

Outlines standards of consistency and uniformity for administration of grants and agreements in terms of: Financial Administration - accounting transactions, meeting cost share

requirements, budget revisions, determining allowability of costs Programmatic Issues –no-cost extension requests ( if not automatic),

change in key personnel, PI/PD extended absences or >25% reduction in effort

Property & Equipment Standards and Management Reports and Records Termination, Enforcement, Closeout

What rules apply? (continued):Depends on type of award instrument issued:

Grant – most flexible, “to carry out a public purpose of support” to achieve aim(s), diligence is required, can adapt scope and budget

Contract – more restrictive, a procurement with deliverables and stringent T&C’s, must produce results

Cooperative Agreement - sponsor has substantial involvement in project activities

These distinctions determine the applicability of Federal Regulations for award administration:

Federal Acquisition Regulation (FAR), (codified in Title 48 of the Code of Federal Regulations) FAR governs Contracts

OMB A-21 for Grants and Cooperative Agreements

SPONSORED PROGRAMS 4 BASIC FUNCTIONS (Review):

Distribute information concerning potential funding opportunities

Review agency guidelines and assist with the overall proposal submittal process (including budget development)

Negotiate sponsor agreements, relationships, and award terms and conditions

Interpret and apply the regulatory, contractual, and administrative requirements applicable to sponsored projects

Stages of an Awarded Project: Award Receipt and Setup – dept ID Project Administration

Complete Scope of Work, incur expenses per the award budget

Gather/maintain documentation Matching requirements, Effort Reporting, Sub-

recipient monitoringFile applicable Technical and Financial

Reports Request Sponsored Programs Accounting’s

assistance with Financial Reports Copy of all reports to OSP

Stages of an Award (Continued): Evaluate the Project (at a minimum, 90

days before ending date)Timely completion by award end date

No-cost extension required? – Contact OSPAccurate predicted Use of Award Budget

Budget Modification required? – Contact OSP

Closeout (BEFORE the project end date)Complete Scope of WorkProcess all expenditures

Stages of an Awarded Project (Continued): Closeout (AFTER the project end date –

within 45 days)Verify posting and reconciliation of expensesSubmit applicable Certifications

Matching & Effort ReportingComplete applicable Technical and Financial

Reports Copy to OSP

Follow Record Retention Requirement Up to 5 years from the date of final reports.

STAYING IN TOUCH WITH SPONSORED PROGRAMS

Location: JMAC Building 6 (Medical Arts West), Suite 26, MSC 5728

Phone: (540) 568-6872 FAX: (540) 578-6240 E-mail: jmu_grants@jmu.edu web:

http://www.jmu.edu/sponsoredprograms/index.shtmlSee “About Sponsored Programs” for staff listing

Thank you for your attention!

Questions??