WHAT CAN SPONSORED PROGRAMS DO FOR YOU? John D. Hulvey Director, 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 Resources By 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 Idea • Consider Proposal Writing Workshop • Search for and Target Funding Source(s) • Pick up Speed (OSP Recommended): • Proposal Preparation • Budget Development • Secure Departmental and Dean approvals
OSP’s Role: Coordinationand Compliance • University Review: • Verify sponsor’s requirements are met • Verify accuracy and allowability of budget items and completeness of budget justification • Ensure contractual requirements are acceptable • Obtain final university approval • Submit final proposal package to sponsor
Parting the Red Tape: Plan • Contact OSP early so we can add value • Review sponsor’s terms and conditions • Alert you of red flags/special considerations • Develop budgets • Collaborators, on or off-campus • Substantial 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) • 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 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
Per Federal Costing Regulations, OMB A-21 (pertains to educational institutions) BEWARE UNALLOWABLE COSTS The “Biggies” Salaries of administrative and clerical staff Office supplies Postage Local telephone costs Memberships Entertainment costs & alcohol
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 circumstances ALLOWABLE – 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.
The Headline Test 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
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: Federal Regulations • Sponsors’ T&Cs are compared against federal law to reveal any conflicts. Remember: NO terms can violate Federal Law
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 monitoring • File 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 OSP • Accurate predicted Use of Award Budget • Budget Modification required? – Contact OSP • Closeout (BEFORE the project end date) • Complete Scope of Work • Process all expenditures
Stages of an Awarded Project (Continued): • Closeout (AFTER the project end date – within 45 days) • Verify posting and reconciliation of expenses • Submit applicable Certifications • Matching & Effort Reporting • Complete 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: email@example.com • web: http://www.jmu.edu/sponsoredprograms/index.shtml • See “About Sponsored Programs” for staff listing
Thank you for your attention! • Questions??