Jef f Warner Contract and Grant Of ficer FEDERAL UPDATE Spring QRAM - Monday, March 14, 2012 Danielle VandenBos Esq. Contract and Grant Of ficer F E DE RAL U P DATE AG E NDA : NIH Fiscal Policy - FY 201 2 Impor tant ARRA Information NRSA Budgetar y Levels E-Verify FAR Clause NIH Ef ficient Spending – Conference Gants NSF Senior Project Per sonnel Multiple PI Assurance NIH Resubmissions NIH – LikeThis DoD – Enhanced IRB Requirements DHHS – Salar y Limitation Sponsor Climate in Washington NIH E-Submission Supplement Requests Subaward Proposal Package Spring QRAM - Monday, March 14, 2012 NIH FISCAL POLICY FOR GRANT AWARDS – FY 2012 N OT- OD - 1 2 - 0 3 6 Non-competing awards will be issued without cost of living/inflationary adjustments in FY 2012 and inflationary increases for future year commitments will be discontinued for all competing and non -competing research (SPA recommends to continue to budget proposals with these increases). However adjustments for special needs (such as equipment and added personnel) will continue to be accommodated. FY 2012 awards that have already been issued will be revised to adjust the award level and future year commitments in accordance with these principles. Spring QRAM - Monday, March 14, 2012 R U T H L . K I R S C H S T E I N N AT I O N A L R E S E A R C H S E R V I C E AW A R D ( N R S A ) S T I P E N D S , T U I T I O N / F E E S A N D O T H E R B U D G E TA R Y L E V E L S E F F E C T I V E F O R F ISCAL YEAR 2 01 2 NOT-OD-12-033 This Notice establishes new stipend levels for fiscal year (FY) 2012 Kirschstein-NRSA awards for undergraduate,predoctoral, and postdoctoral trainees and fellows (i.e. issued on or after October 1 , 2011). Tuition, fees and training -related expenses for trainees and institutional allowances for Fellows remain unchanged. All FY 2012 awards issued using FY 2011 stipend levels will be revised to increase the stipend category to the FY 2012 level. For institutional training grants already awarded in FY 2012, if trainees have been appointed to the FY 2012 budget period, the grantee institution must amend those appointments to reflect the FY 2012 stipend level once the revised award is received. Spring QRAM - Monday, March 14, 2012 N E W N I H P O LI C Y O N E F F IC IENT S P E NDI NG R E LATED TO G R A N T S S UP P ORTING C ON FERE NCES A N D M E E TING S N OT- OD - 1 2 - 0 41 Ef fective with grant awards issued on/after January 27, 2012, a new term and condition which prohibits food/meal costs from being supported or charged to NIH -supported conference grants will be included: “Direct charges for meals/food and beverages are unallowable charges to this project .” The new policy applies to awards supporting a Conference and/or Scientific Meeting (i.e. R13s and U13s); however, other grant mechanisms that are specifically issued to support conferences will be considered on a case by case basis . For conference grants previously awarded with FY2012 funds, NIH will not revise the award to modify the terms and conditions of the grants. Spring QRAM - Monday, March 14, 2012 NIH RESUBMISSIONS Resubmission– A proposal submitted to make a significant change (e.g., scope of work, budget, facilities, subawards, etc.) to a previously submitted proposal not yet funded by the sponsor and where the sponsor requires submission of a revised full proposal. Please remember to include the previous proposal number in section 5 of the AA Form. Please remember to include the Federal Identifier in the applicable section of the SF 424 (4A). The Federal Identifier is the Institute Code and Serial Number assigned to the previous submission (ex. CA123456). This number is available in the eRA Commons. Spring QRAM - Monday, March 14, 2012 N I H - L I KE TH IS ( A T H E SAURUS - BASED S E A RCH TO OL ) LikeThis is a new search tool to aid Principal Investigators in finding and learning about other research projects that have similar goals and objectives as their own. By entering specific scientific terms or accessing their own grant applications or grants and clicking on LikeThis, investigators will be provided a listing of similar funded projects and/or publications. LikeThis is available from the eRA Commons home page under the Additional Links section along the right side of the page. Spring QRAM - Monday, March 14, 2012 N I H - L I KE TH IS ( A T H E SAURUS - BASED S E A RCH TO OL) LikeThis provides a powerful and integrated search tool in a user friendly interface. With the ability to find similar projects and publications, Principal Investigators can more quickly and ef ficiently: find out new ideas for research based on what NIH has awarded in the past; see what NIH is doing in his or her area of interest ; use the information as a decision tool to determine if they need to come up with a fresh research idea; and figure out in which study section his or her application should be reviewed. Spring QRAM - Monday, March 14, 2012 SA LA RY L I M I TATION O N G R A NT S, C O OP ERATI VE AG RE EMENT S A N D C O NTRAC T S F ROM N I H A N D A H RQ N OT- OD - 1 2 - 0 3 5 & N OT- H S- 1 2 - 0 07 The Department of Health and Human Services (“DHHS”) budget signed on December 23, 2011 includes a reduction in the salary cap from Executive Level I ($199,700) to Executive Level II ($179,700). Budget periods awarded using previous fiscal year funds use the salary cap that was in effect for that particular fiscal year . The salary cap does apply to all subawards and subcontracts. Please note that the Executive Level II salary cap will apply to all DHHS entities, not just NIH and AHRQ. However, NIH and AHRQ are the only agencies that have issued implementation guidance. We will forward additional guidance as it becomes available. Spring QRAM - Monday, March 14, 2012 SA LA RY L I M I TATION O N G R A NT S, C O OP ERATI VE AG RE EMENT S A N D C O NTRAC T S F ROM N I H A N D A H RQ N OT- OD - 1 2 - 0 3 5 & N OT- H S- 1 2 - 0 07 When the The following will apply: issue date of an award is on or before December 22, 2011 initial issue date of an award is on or af ter December 23 If the award is a non-competing renewal AND initial issue date is on or af ter December 23 The FY 2012 award will remain at the $199,700 salar y cap and the following years will be adjusted downward to the $ 17 9 , 7 0 0 c a p o r t h e c a p i n e f f e c t w h e n the new non-competing renewal is issued. T h e $ 17 9 , 7 0 0 s a l a r y c a p w i l l a p p l y. If the award is a new or competing award, NIH will issue a revised Notice of Award, adjusting the award and the following years to reflect the new salar y cap. The new cap applies but NIH will not adjust the award. Principal Investigators may re-budget the “funds freed as a result of the lower cap” into other budget c ateg ories. Future non -c ompeting r e n e w a l s , h o w e v e r, w i l l b e a t t h e s a l a r y cap of Executive Level II in ef fect at the issue date of the renewal. Spring QRAM - Monday, March 14, 2012 SA LA RY L I M I TATION O N G R A NT S, C O OP ERATI VE AG RE EMENT S A N D C O NTRAC T S F ROM N I H A N D A H RQ N OT- OD - 1 2 - 0 3 5 & N OT- H S- 1 2 - 0 07 UCI Implementation: Sponsored Projects has modified its awards synopsis so that the Contract and Grant Of ficers can advise departments on which salary cap applies to awarded funds from DHHS agencies. The award synopsis contains a code in the upper right hand corner that indicates either “Exec LvL I” or “Exec LvL II.” Spring QRAM - Monday, March 14, 2012 N E W E L E CTRONIC S U BMISSION P ROCE SS N OW AVA I LA BLE FO R A D M INI STRATIVE S U P PLE MENT R E QUEST S N OT- OD - 1 2 - 0 4 3 Administrative Supplement requests may now be submitted through either the eRA Commons or Grants.gov, as described in NOT-OD-12-024 (notification of the availability of the two pilot processes), or through the existing, paper -based process. NIH has published the first administrative supplement FOA (Funding Opportunity Announcement). This FOA (PA -12-100) is available for prior approval requests to nearly all active grant awards. NIH will soon also publish FOAs for Research Supplements to Promote Diversity. Once published, applicants are encouraged to use one of the two new electronic processes. Spring QRAM - Monday, March 14, 2012 N E W E L E CTRONIC S U BMISSION P ROCE SS N OW AVA I LA BLE FO R A D M INI STRATIVE S U P PLE MENT R E QUEST S N OT- OD - 1 2 - 0 4 3 Pilot System for Forms -Based Submissions through Grants.gov: Applicants choosing this method will need to complete a full supplement application package using the SF424 (R&R) forms available on Grants.gov. They will need to provide information in all required fields, and provide additional information justifying the supplemental dollars. Spring QRAM - Monday, March 14, 2012 N E W E L E CTRONIC S U BMISSION P ROCE SS N OW AVA I LA BLE FO R A D M INI STRATIVE S U P PLE MENT R E QUEST S N OT- OD - 1 2 - 0 4 3 Pilot System for Streamlined Supplement Requests through eRA Commons: PDs/PIs and AORs will login to the eRA Commons, identify the parent award that a supplement is being requested for, and prepare an administrative supplement request. The system will utilize data from the previous award and pre populate as much of the request as possible . Applicants only need to provide information justifying the supplement. Spring QRAM - Monday, March 14, 2012 I M P ORTA NT I N FORMATION R E G AR D I NG A R R A AWAR D S On September 15, 2011 , the Of fice of Management and Budget (OMB) issued Memorandum M -11-34, “Accelerating Spending of Remaining Funds from the American Recovery and Reinvestment Act.” The memo directed Federal agencies to accelerate the spending of ARRA funds as a way to support the President's ongoing ef forts to "drive the economy forward and create jobs” and to take steps to complete Recovery Act projects by September 30, 2013. The National Institutes for Health ( NIH) and the National Science Foundation (NSF) have provided separate guidance on meeting the accelerated spending goal. Spring QRAM - Monday, March 14, 2012 I M P ORTA NT I N FORMATION R E G ARDI NG A R R A AWARDS – N I H G U I DA NCE For awards sc heduled to end on or BEFORE September 30, 2013 For awards t hat are sc heduled to end AFTER September 30, 201 3 I f a n o - c o s t ex te n s i o n i s n e c e s s a r y, i t m u s t b e r e q u e s te d b y J U N E 1 , 2 01 2 , r e g a r d l e s s o f t h e e n d d a te o f t h e aw a r d . If a no-cost extension is necessar y, it must be requested by June 2, 201 2 . G r a n te e s m ay s t i l l ex e r c i s e t h e i r o n e t i m e , g r a n te e - a p p rov e d n o - c o s t ex te n s i o n a s l o n g a s t h e p e r i o d o f p e r fo r m a n c e w i t h t h e ex te n s i o n d o e s n o t ex te n d b eyo n d S e p te m b e r 3 0 , 2 01 3 . The NIH Grants Management Of ficer for the award must be notified in writing via the appropriate Contract and Grant Of ficer in Sponsored Projects of the request for an extension. H o w ev er, i f a P r i n c i p al I nv e s t i g a to r r e q u i r e s a n ex te n s i o n b eyo n d S e p te m b e r 3 0 , 2 01 3 , h e / s h e m u s t f o l l ow t h e g u i da nc e f o r “ aw a r d s t h a t a r e s c h e d ule d to e n d a f te r S e p te m b e r 3 0 , 2 01 3 .” The request for extension must explain why an extension of the project is vital for its completion. Spring QRAM - Monday, March 14, 2012 I M P ORTA NT I N FORMATION R E G ARDI NG A R R A AWARDS – N SF G U I DA NCE If a no-cost extension is necessar y, it must be requested by Ju ne 2, 201 2 , regardless of the end date of the award. Grantees may still exercise their one -time, grantee -approved no-cost extension as long as the period of per formance with the extension does not extend beyond September 30, 2013. The deadline for an extension past September 30, 2013 was March 2 nd . Awards that are scheduled to end AFTER September 30, 2013, were required to submit their plan to accelerate completion was due to the Program Of ficial on March 2 nd . NSF will amend awards to ensure that the period of per formance does not extend beyond September 30, 2013 in order to comply with the OMB memorandum Spring QRAM - Monday, March 14, 2012 I M P ORTA NT I N FORMATION R E G AR D I NG A R R A AWAR D S Sponsored Projects strongly encourages Principal Investigators to responsibly accelerate spending on their ARRA awards to the greatest extent possible because waivers are not guaranteed. Spring QRAM - Monday, March 14, 2012 FA R C L AUSE: E - VE RI FY R E QUI REMENT 5 2 .2 2 2 - 5 4 Ef fective September 8, 2009, all employers who receive specific federal contracts are required to comply with E -Verify, an Internet-based system operated by the Department of Homeland Security (DHS) in partnership with the Social Security Administration (SSA). The E-Verify program provides an Internet -based means of verifying employment eligibility of workers employed in the United States. E-Verify electronically compares information contained on the Form I-9 with records contained in the Social Security Administration (SSA) and DHS databases to verify the identity and employment eligibility of employees. Spring QRAM - Monday, March 14, 2012 FA R C L AUSE: E - VE RI FY R E QUI REMENT 5 2 .2 2 2 - 5 4 UC, as a federal contractor, must verify qualifying new and existing employees, including employees who may be assigned through a transfer to a qualified federal contract/subcontract. Grants are not subject to the federal rule, only qualified federal contracts/subcontracts. The E -Verify process must be done in a nondiscriminatory manner and, in the case of new hires, only after the individual has accepted an of fer of employment and completed the Form I-9. Please see all UC E -Verify Guidelines here: http://snap.uci.edu/viewXmlFile.jsp?resourceID=4365 Spring QRAM - Monday, March 14, 2012 N SF - S E N I OR P ROJ EC T P E RSONNE L SA LA RI ES & WAG ES P O LI C Y NSF limits salary compensation for senior project personnel to no more than two months of their regular salary in any one year. This limit includes salary compensation received from all NSFfunded grants. If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award. Spring QRAM - Monday, March 14, 2012 M U LTIP LE P I A S SURA NCE The Administrative Approval (“AA”) form contains the NIH PI assurance. Thus, all UCI Principal Investigators on a Multiple Principal Investigator NIH application must sign the Administrative Approval (“AA”) form. Only the Chair/Dean/Director signatures are required from the Lead/Contact PIs administering unit. For NIH’s 2590 progress report, the PI assurance statement must be retained for all named PI’s on the project. For all prior approval requests, each PI on project must endorse the request. Spring QRAM - Monday, March 14, 2012 D O D – E N H A NC ED I R B R E QUIREME NT S In 2006, the Department of the Defense (DoD) enhanced its human subject protection requirements, including the application of those requirements to extramural performers. UCI has signed an assurance with the DoD which requires that UCI apply DoD regulations and policies for the protection of human research participants when conducting, reviewing, approving, overseeing, supporting or managing DoD supported human subject research. Sponsored Projects conducts a protocol match prior to issuing synopses; if it is found these extra requirements are not met, SPA will hold the award. Please see guidance concerning these requirements here: http://www.research.uci.edu/ora/hrpp/deptOfDefense.htm Spring QRAM - Monday, March 14, 2012 S P ONSOR C L I MATE I N WA SH INGTON Please ensure all prior approval requests are routed through Sponsored Projects prior to submission. All Federal Agencies are under new scrutiny to focus on all areas of non -compliance and unallowable costs. NIH is pushing for more timely submissions of Just -in-Time requests. As there are fewer funds available to support NIH administrative staff, the JIT review process is taking more time which results in longer delays in receiving funds. The Air Force Office of Scientific Research recently published a memo clarifying their No Cost Extension policy. Their policy allows for extensions; however, they are only issued in situations where they are both properly documented and truly warranted. These requests are considered on a case -by -case basis. Spring QRAM - Monday, March 14, 2012 SUBAWARD PROPOSAL PACKAGE Subrecipient Commitment Form: All Subrecipients must complete this form when submitting a proposal to UCI . Detailed Scope of Work Detailed Budget and Justification Spring QRAM - Monday, March 14, 2012 CONTRACT AND GRANT OFFICERS Should you have any questions, please feel free to contact your Contract and Grant Of ficer. Jonathan Lew: 949-824-3029 or jlew@uci.edu Alison Yeung: 949-824-2644 or alison.yeung@research.uci.edu Danielle VadenBos Esq.: 949-824-7109 or vandenbd@uci.edu Leighsa Washington: 949 -824-2460 or lrwashin@uci.edu Jef f Warner: 949-824-4781 or warnerj@uci.edu Spring QRAM - Monday, March 14, 2012