♫♫♫ Let’s “RAP” ♫♫♫ (Research Administration Processes) In our interactive RAP session, panelists will discuss issues which affect our RAP. Find out what you can do to facilitate the process! Research Administration Support Group (RASG) Tuesday, November 15, 2005 Panelists: Barbara Longmire.............Director, Office of Clinical Trials...........................Pre Award Barbara Lyons.........Financial Analyst, Comprehensive Cancer Center..........Pre Award Cathy Rogers..........Contract Specialist, Office of Sponsored Research.........Pre Award Ellen Ludington...Deputy Director for Research Development, Psychiatry...Pre Award Kelly Musty...........Financial Analyst, Office of Sponsored Research.............Post Award Dianne Blake....Sr. Accounting Specialist, Highway Safety Research Ctr.....Post Award Welcome to the UNC-CH Office of Clinical Trial Barbara Longmire, RN, MSN, Director Location Current Location 200 S. Elliott Rd. January, 2006 Bioinformatics OCT’s Mission Consistent with UNC's mission to acquire, discover, preserve, synthesize and transmit knowledge and provide an environment for research, the Office of Clinical Trials (OCT) will perform all administrative, legal, and pre-award budgetary functions for clinical trials. The People Administrative Assistant – Ginger Morgan Project Manager – Sabrena Mervin-Blake, MSCR Contract Manager – Erika Nunn, MS, JD Contract Manager – Janet Devine, BA Contract Manager – Aylin Regulski, MS, JD Director – Barbara Longmire, RN, MSN Processing a Clinical Trial Agreement Pharma CRO Other Funding Agency Principal Investigator internal feasibility review Office of Clinical Trials (submit with RRF) • Submit CTA/CDA/Amendment upon receipt • Submit IPF when complete OCT will review/negotiate contract terms as needed and contact PI/Department for signature on agreement Contract Review and Approval Negotiate terms of all agreements related to clinical trials, such as: Confidentiality Disclosure Agreements (CDA’s) NOT signed by PI Clinical Trial Agreements (CTA’s) Amendments Subcontracts Other Sign agreements on behalf of the University IPF/Proposal Packet Review and Approval Full review within OCT Accurate IPF and Internal Budget that matches the dollar amount in the contract IRB Fee Pharmacy Fee if applicable Correct F&A rate applied to all appropriate costs Current IRB approval/pending letter AND informed consent Provide help desk assistance for document preparation Final University signature approval of IPF Processing an Amendment to the Clinical Trial Agreement Does the amendment change the financial terms of the contract? Yes No Submit the following to the OCT: •Amendment •Review Request Form* •Hard copy Proposal Packet (IPF) Does the amendment change the timeline and/or PI only? No Submit the following to the OCT: Amendment Review Request Form Yes SIGN the amendment, then submit the following to the OCT: Signed amendment Review Request Form * Proposal packets for amendments must include a copy of the most recent IRB approval, informed consent form, and the most current protocol in addition to the required forms. If the protocol has not changed, a emm0o stating so will be acceptable Required for all agreements related to clinical trials. Please complete and send to the Office of Clinical Trials, 200 S. Elliott Road, CB #1651 Phone: 843-2698 Fax: 843-2399 email: oct@unc.edu TYPE OF AGREEMENT: Is electronic version available from the department? OCT Review Request Form (RRF) http://research.unc.edu/oct/ ****** Must accompany every submission Yes No If yes, please forward to oct@unc.edu ASAP Principal Investigator: Administrative Department Name and Number: Division: Phone: Pager: Mailing address (CB #) for payment: Physical (FEDEX) address: E-Mail: Fax: Protocol Number and Title: GCRC/IRB #: Estimated Start Date for Study: Type of Trial: Drug Trial Device Trial Date Submitted to GCRC and/or IRB: Estimated Length of Study: < 2 yrs Drug or device provided/No Funding 2-4 yrs Other > 5 yrs Primary Dept. Contact for Questions: Name: Phone: E-Mail: CB#: Fax: Pager: Primary Sponsor Contact for Contract Questions: Sponsor: Primary CRO Contact (if applicable) for Contract Questions: CRO: Contact Name: Phone: Fax: E-mail: Address: Contact Name: Phone: Fax: E-mail: Address: IF THIS RRF IS FOR A CONFIDENTIALITY AGREEMENT OR AMENDMENT, STOP HERE. NO SIGNATURE IS REQUIRED!! IF THIS RRF IS FOR A CLINICAL TRIAL AGMT, ANSWER FOLLOWING QUESTIONS ACCURATELY AND SIGN THE FORM. THIS INFO MAY BE FORWARDED TO OFFICE OF UNIVERSITY COUNSEL Will subcontacts be required? Yes No If yes, approximately how many? __________ Are there multiple sponsors? Intellectual Property Concerns: Yes No Did the PI design the protocol? Is there a likelihood of an invention resulting from this study? Do you consent to the Sponsor owning any invention resulting from the study? Yes Yes Yes No No No Yes Yes No No Publication Concerns: Is a publication delay of >12 months acceptable to you? Do you consent to transfer your copyright of any written materials produced in relation to this study to the sponsor? I hereby certify that all the information provided above is true and correct and the ORIGINAL signature below is my own. PI Signature: ______________________________________ Date: ____________________ OCT Web site Research Administration Process-Clinical Trials Barbara M. Lyons Financial Analyst Lineberger Cancer Center 919-843-6902 blyons@med.unc.edu Agenda Review Request Form Budget and Contract Internal Budget Internal Process Form Useful Website Review Request Form Send this to OCT as soon as you receive the contract template Electronic Template send to OCT@UNC.EDU Estimated Length of Study PI answer questions on Intellectual Property, Publication, and PI sign Review of Budget and Contract Negotiate Budget with Sponsor Make sure all costs are covered Don’t be afraid to ask for items not in template Contract Terms Read the whole contract Check for Payment Terms Pay attention to any items that will affect the department What is expected of site Definitions of Protocol Violations-nonpayment Internal Budget Complete after negotiating budget with sponsor Keep it simple NO F@A on IDS or IRB Fee Address items outside of normal budget Reimbursed Items-Hotel Stays/MRI/etc Internal Budget • Personnel Patient Care Costs Pharmacy Costs IRB Admin Fee Total Direct F@A Total Items on case by case basis and Reimbursed items list below budget Internal Processing Form Complete IPF when study is at the IRB for Review Total Budget Period-Be realistic about end date. LCCC 2-4 years Use Internal Budget for IPF Budget First year and total will be same Allow a few days for signature process Make a copy Department of Medicine Once you have one with no errors-use Copy function RAD-Do not include-Confidentiality of Protocol IPF-What to Include Internal budget Contract template IRB review letter/approval Consents Protocol Website http://cfx3.research.unc.edu/my_clinical_trials/ PRE AWARD SERVICES Cathy Rogers Contract Specialist, Office of Sponsored Research PRE AWARD SERVICES Transition from UNC Department to Central Department (Office of Sponsored Research) Pre Award Proposal Routing within OSR Front Desk (Receptionist) Proposal Specialist Contract Specialist Proposal Specialist Front Desk (Receptionist) Pre Award Topics Amendment/Supplements No-Cost Extension Requests Project Financial Guarantees Office of Sponsored Research Website http://research.unc.edu/osr/ Information Sheet Pre Award Services Ellen Ludington and Amanda Bundren Department of Psychiatry Business Office UNC School of Medicine What grants will we submit this month? Keep track of all grant submissions on grant project board Talk with Principal Investigator about grant type Review guidelines early Work with Principal Investigator’s support personnel Keep in touch with the Principal Investigator during the month for updates on his/her progress. Determine personnel for grant application Work with Principal Investigator to determine personnel Budget salaries correctly (include escalation for future years) Resolve all personnel cost share issues Use current and correct fringe benefit rates Information sheet can be found at: http://research.unc.edu/osr/information/general_info.php Budget for all other grant expenses Review guidelines to determine allowable amounts for other expenses such as consultants, travel, supplies, and other costs. Justify all other costs Fellowship Awards Review guidelines Is employee eligible to apply for the fellowship award? Has a mentor/sponsor been identified? Is nominee letter required? If so, include in grant package when submitting to the University for review. Subcontracts Scope or Statement of Work Face Page Budget Budget Justification Checklist (NIH) F&A Agreement Letter of Intent Indirect Cost (Facilities and Administrative) Check guidelines for allowable rate, allowable rates vary, especially on Foundation grants Cost sharing and cost matching Check guidelines for requirements, work out all issues before routing grant for approval Conclusion Review guidelines (include guidelines in packet to OSP or OSR) Plan ahead as much as possible Information sheet can be found at: http://research.unc.edu/osr/information/ general_info.php OSR POST AWARD FORMS Kelly Musty Financial Analyst Office of Sponsored Research TYPES OF FORMS Just to name a few… Travel Check Request Adjustments Petty Cash Reimbursements Purchase Requisitions IPAS WHAT SLOWS DOWN THE PROCESS??? No justification Poor justification Over drawn accounts Unallowable cost Incorrect backup Charges not within grant period dates EXAMPLES OF INCORRECT JUSTIFICATION Account Adjustment To move charge to correct account. 2nd try at justification The attached charges were incorrectly charged wrong account. This entry is needed to post them to the correct account. EXAMPLES CON’T To cover over draft of account ending To pay criminal background checks Reimburse default accounts for P-Card charges Charge was not allowed by agency AJ to move expenses off account EXAMPLES CON’T IPAS FOREIGN TRAVEL Unique opportunity to consult with international colleagues Establish themselves internationally EXAMPLES CON’T IPAS FOR PURCHASE REQUISITION Do not use sole source justification for IPAS justification To expand the project Equipment will be used in common labs EXAMPLES CON’T Travel Forms Purpose of trip – Attend meeting Put travel reimbursement on grant 5-5XXXX or 5-3XXXX whichever one has money ANSWERING TO A HIGHER POWER The different sponsoring agencies make the guidelines Auditors check for compliance to program guidelines Such as… Unallowable costs Timeliness and accuracy of reports Time and Effort Reporting Cost sharing Cost Transfer OSR is entrusted with responsibility of insuring compliance to the guidelines. HOW DOES THIS CHARGE OR ACTION BENEFIT THIS GRANT? How to Close Out an Award 6 stages to Closing an Account Successfully Post Award Services Dianne Blake Senior Accounting Specialist Highway Safety Research Center 1ST Stage Approximately 60 days prior to the expiration of the project account, the department should receive a notification/reminder to the PI of the terminating account, asking if an extension will be needed and the need for a final progress report. HSRC meets with the PI 6 months prior the project end date to review the expenses Reallocate funds to ensure all expenses will be covered and to ensure the funds can be expended by the project end date This is the opportune time for the PI to review their accounts closely, and request an extension if needed. nd 2 Stage A Notice of Termination Reply (NOTR) letter and form is sent to the department administrator. The administrator should complete and return the NOTR to OSR post award services by the date stated in the NOTR letter and form. Make sure all project costs are projected Ensure all costs are legit Remove all costs that may not be allowable or appropriate Treat the NOTR like your personal check book (on the other hand maybe not). NOTR Form http://research.unc.edu/osr/documents/notr_protected.xls rd 3 Stage The following reports are generally due for all sponsored projects at termination. Most sponsors require submission 90 days after expiration. You should refer to each project’s term and conditions for required reports and due dates. final technical, progress, narrative report-submitted by PI final inventions report – submitted by the PI, counter signed by Office of Technology, mailed to sponsor by OSR final financial report – submitted by OSR upon approval of expenditures by the PI final property report – submitted by OSR University Property Administrator th 4 Stage Upon project termination, the Financial Reporter will review the account and work with the department administrator submitting the NOTR to determine the final figure to be reported to the sponsor on the financial report or final invoice. The department administrator needs to ensure the following: All staff payroll has been removed All cash advances must be reconciled All erroneous charges have been transferred, any deficits and post-term charges have been cleared All internal service centers have been notified of the account termination for any future costs such as printing, telephone & postage th 5 Stage Final financial reports and final invoices must be submitted no later than 90 days from the close date for federal awards; state and private agency deadlines may vary and have stricter stipulations. In order to meet sponsor deadlines there needs to be a clear and timely communication between PI’s, department administrators, and Financial Reporting. OSR Financial Reporting will submit the final financial report/invoice to the sponsor once they have coordinated with the department the final figure to be reported. However, failure to return the NOTR by the required due date will result in OSR preparing & filing the Financial Report based on the current Budget & Expenditure Report (FBM090/91) to avoid compliance issues and audit finding for late reporting. Definitions Deficits: more commonly referred to as “overdrafts” occur when cumulative expenses exceed the amount awarded by the sponsor and could be considered voluntary uncommitted cost sharing. It is the responsibility of the department to transfer deficits out of sponsored awards promptly and no later than 90 days after the termination date. Post-Term Charges: charges incurred after the termination date of a project/award. Under some circumstances, the costs of final report preparation may be incurred after the end date, and so should be carefully documented. Most common examples: payroll expenses, Pcard expenses, telephone costs, copy services, MMD charges and service center charges th 6 Stage Final Adjustments/ Closing Entries OSR will notify the department 120 days after termination of any deficits/overdrafts, which must be reconciled within 30 days to avoid the OSR closing the account by off setting the overdraft against the departments overhead receipt account. The University is responsible for closing accounts in a timely manner to avoid the appearance of having LACK OF INTERNAL CONTROL AND COMPLIANCE JUSTIFICATION RAP CHORUS: l Jus-ti-fy, Jus-ti-fy, Always remember you must jus-ti-fy So you want to take a trip Remember to tell us why How to the grant does it apply You always need to justify CHORUS Cost transfers – problems may exist. Do it right the first time – no need to fix. When problem is found – correct right away Don’t do any past ninety days! How did error occur – how to correct Why the grant is paying – to the grant it must connect CHORUS Just If I want to charge the grant – how does it apply If it doesn’t pass the test – it will be nullified CHORUS