How Much is Enough? Budgeting for Your Project and OCGA Forms

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Pre-Award: Budget
Development for Grants
& OCGA Updates
UCLA School of Nursing
Research Support Team
October 29, 2012
The Purpose of Budgets
 Demonstrate that PI has considered all costs of
achieving the specific aims and project goals
 Dedicate effort and resources to the project
 Delineate budget categories which must be
adhered to (±25%) once the project is underway
 Describe the scientific necessity of every line item
Timeline for Successful Budgets
 Three months before due date
 Develop Specific Aims
 Meet with Statistics Consultation Group to develop
power analysis and study size, statistician effort (if
applicable), data management plan
 Develop project timeline
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What is the project duration?
Who is involved? Does effort fluctuate?
Enrollment timeline?
Analysis timeline?
Timeline for Successful Budgets
 Two months before due date
 Identify personnel and performance
sites
 Rough draft of budget and justification
 One month before due date
 Final budget and justification
Timeline for Successful Budgets
 Secure special arrangements earlier
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Permission to exceed direct cost limitation?
Subawards to other Institutions?
Projects with an international component?
Quotes for equipment, consultants, vendor
agreements?
 Mandatory cost sharing?
 Program income?
Budget Foundations
Justification
Describe necessity
Cost categories
Effort, subcontracts, other costs
Project goals & specific aims
What is feasible/necessary to achieve goals?
Program announcement
Scope? Cost/category limitations? Modular or line item budget?
Direct and Indirect costs
 Direct Costs
identified with a particular sponsored project and
directly assigned to that project with a high degree
of accuracy
Examples: scientific/technical personnel effort,
project supplies, subject renumeration,
scientific/technical computers
 Indirect Costs
For common or joint objectives which cannot be
identified specifically with a particular project
Examples: clerical effort, office supplies, general
purpose computers
Direct Cost Categories
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Personnel: define effort devoted to the project
Materials and supplies
Travel (PI to study sites, conferences)
Consultants
Equipment
Subawards
Other costs
 Define categories and atypical line items at outset to ensure
allowability when project is underway
 Subject renumeration, TIF, fee remission, animal research,
pharmacy costs, rent, project-specific office-type supplies,
telephones, mailing, copying, machines (<5k), core services
Personnel Determinations
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Personnel comprise the largest part of grant budgets
2% escalation per NOT-OD-11-068
All personnel have a project role, duties, and effort
Senior/Key Personnel
 individuals who contribute to the scientific development or
execution of the project in a substantive, measurable way
 Current staff or TBN?
 Actual salary/benefits vs institutional scales
Project roles: Senior/Key
 Multiple PI
 Requires Multiple PI leadership plan
 Co-Investigator
 Requires stated effort/salary
 Faculty Collaborator
 Other Significant Contributor
 Effort is “as needed”
Subaward, Vendor or Consultant?
 Subawards are the most common mechanism for
collaboration with another site that brings intellectual
value to the project. They have discrete, fully-formed
budgets authorized by an institutional official.
 Vendor Agreements are established when a site
performs work (assays, sample processing) on a feefor-service basis. No intellectual contribution.
 Consultants are non-UCLA individuals who perform
fee-for-service work at a fixed rate; always requires a
letter of support stating the rate, scope and expertise;
compliant with SB1467 “Public Contracts: Conflict of
Interest.”
Human and Animal Subjects
 Protocol defines timepoints and processes
for subject renumeration which must be
included in the budget
 Approvals must be in place before award
can be issued
 Start work on the protocol before award is
issued to ensure the project is not delayed
or restricted
Financial Characteristics of
Contracts & Grants
 Defined performance period
 Ongoing reporting – progress, effort
and technical reports
 Auditable financial reports
Financial Characteristics of
Contracts & Grants
 Most research grants are cost-reimbursable
 Specific scope of work
 Unobligated funds returned to agency
 Some contracts (clinical trials, subcontracts for
services) are fixed-rate
 Funds provided for services rendered
 Unobligated funds retained under Policy 913
 Research Office will advise PI regarding the
contract type
Federal Costing Principles
 OMB A-21
 Should I charge this to my grant?
 Allowability- Does the agency or announcement prohibit certain
costs?
 Allocability-Is the expense tied directly and proportionally to the
project?
 Reasonableness- Are the cost and units reasonable in light of
the study aims and scope of work?
 Consistency- Are the costs consistent across projects and
campus units?
 OMB A-110
 Competitive procurement
 Report submission and records retention
 Prior approval for rebudgeting beyond established thresholds
Managing Project Expenses
 Partnership between PI, requestor,
purchaser and grant analyst to adhere to
principles and facilitate timely correction
 Continuous, dynamic, collaborative review
 Review Process
 Research Office provides ad hoc, real-time
reports on expenditures
 PI defines steps to align expenses with budget
and goals
 Fund manager and requester take action
 Repeat
Managing Project Expenses
 By approving a purchase, PI certifies that
the expense is necessary, directly benefits
and is used exclusively for the project
 Use exception processes sparingly or
never
 Out-of-pocket expenses, cost transfers, solesource purchases
 Expenses >90 days old cannot be moved to or
between research projects (NIH GPS 7.5)
Examples of reporting flags
 Categorical variances ± 25%
 Rebudgeting into/out of IDC-exclusion
categories
 Effort variances
 Unallowable/misattributed items
 Carryforward >25% to continuation year
Reporting
 Effort reports
 PI submits reports quarterly
 Prevents overlap and ensures effort is consistent
with stated levels
 Personnel effort must be ≥ pay
 Prior approval required if senior/key effort
decreases >25% from proposed effort
 Three reporting points: Other Support page, All
Personnel Report, Effort Reporting System
Reporting
 Progress reports
 Submitted to agency annually to secure
continuation funding
 Publications? Results? Project delays?
Changes to project? Enrollment? Effort?
Carryforward over threshold?
 Sloppy reports are frequently returned and will
delay continuation funding
Pre-Award: OCGA Updates
UCLA School of Nursing
Research Support Team
October 29, 2012
OCGA Reorganization
 Proposal and Award Intake Teams Created
 Grant Analysts
 Grants and Cooperation Agreements
 Grant Officers
 Contracts, Incoming Subs, and Multi Campus
Agreements
 New Assistant Director
 Grants and Cooperative Agreements
OCGA Proposal Intake Process
 Proposal Intake Team receives all proposals to
review
 Team reviews documents for completeness
 Complete application
 Minimum documents
 Less than minimum
 some level of review possible
 Incomplete/insufficient
 Systematic reminders will be issued to follow-up
on missing documents
OCGA Proposal Requirements
 Minimum for Review
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Completed EPASS with PI signature
Sponsor guidelines
All sponsor forms requiring OCGA signature
Final budget with budget justification
Brief description of proposal aims or proposal
abstract
 Subaward Documents (if applicable)
OCGA Proposal Requirements
 Review, Approval, and Submission
 Completed EPASS with all required signatures *
 Sponsor guidelines
 Final Proposal (budget, science, agency
required signatures, biosketches, etc.)
 Subaward Documents (if applicable) *
 Signed/Completed COI disclosure (if applicable)
 For PHS agencies or agencies that have adopted PHS
regulations, all investigators report in eDGE *
PHS Conflict of Interest
Regulations
 Applies to all research supported by PHS
agencies (NIH, CDC, AHRQ, etc.)
 Applies to non profits that have adopted the PHS
COI regulations (American Heart Association,
American Cancer Society, Susan G. Komen, etc.)
 Regulations apply to proposals submitted and
awards received on or after August 24, 2012.
UCLA Electronic Disclosure
Gateway (eDGE)
 By law, the PI and other Investigators must
disclose their significant financial interests to
UCLA before a proposal can be submitted
 Disclosures are required for all research awards,
including some that previously did not require
disclosure (i.e. conference, equipment, or training
grants)
 Could be found at: https://coi.research.ucla.edu
 Help Desk for eDGE: 310-206-8546 or
rpchelp@research.ucla.edu
UCLA Electronic Disclosure
Gateway (eDGE)
UCLA Electronic Disclosure
Gateway (eDGE)
OCGA EPASS Form
 Replaced the Goldenrod
 EPASS has been mandatory since September 1
 The PI/CoPI signature(s) on the EPASS
incorporate required PHS certification
 NIH/PHS PI signature Form is no longer needed
 Utilizes dropdowns and hyperlinks
 Form could be found at:
http://www.research.ucla.edu/ocga/Forms/EPASS_Form.pdf
OCGA EPASS Form
OCGA EPASS Form
OCGA EPASS Form
OCGA Subrecipient
Requirements
 Prior to proposal submission subs need to
submit:
 Statement of work
 Budget and budget justification
 Subrecipient Commitment Form
 Subrecipient Commitment Form
 Now incorporates new PHS COI regulations
 Form could be found at:
http://www.research.ucla.edu/ocga/Forms/Sub_Commit
ment_Form_revSept_2012.pdf
Subrecipient Commitment Form
Subrecipient Commitment Form
Subrecipient Commitment Form
Summary
 Budgets and expenses are a function of
the project goals and specific aims
 Budgets should be as realistic as possible
to minimize post-award changes
 PI and departmental coordinators are
jointly responsible for adhering to costing
principles and managing project expenses
 OCGA form/process changes reflect the
revised PHS funding regulations.
Summary
 Proposal submission tips:
 Familiarize yourself with UCLA Policies,
Procedures, and Forms (as well as Sponsor
Application Instructions and Forms)
 Alert the SON Research Office regarding all
upcoming submissions
 Meet deadlines for a successful submission
 Start Early!
Questions?
 Slides will be available on the web
(click Research, Past Presentations)
 Email researchoffice@sonnet.ucla.edu
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