What You Need to Know to Be a Pre-Award Research

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PROPOSAL REVIEW 101:
What You Need to Know to Be a PreAward Research Administrator
YOUR FACILITATOR FOR
TODAY:
Brigette Pfister,
MHRD, CRA
• Director of Sponsored
Programs for Humanities
& Sciences, Virginia
Commonwealth
University
bspfister@vcu.edu
LEARNING OBJECTIVES
• Identify and develop crucial skills for the pre-award
research administrator.
• Plan your own professional development related to the
crucial skills identified.
• Review proposals for compliance with applicable rules,
regulations, laws, and policies.
• Communicate effectively with faculty on policy and
regulatory issues.
• Prepare proposals for submission with a minimum of
problems or stress.
• Introductions/
Burning Questions
• Sponsored Program
Basics
• How Pre-Award
Works
• Crucial Skills for PreAward Research
Administrators
AGENDA
• Rules and
Regulations
• How to Review a
Proposal
• Budgets
• Communicating
with Faculty
INTRODUCTIONS AND
BURNING QUESTIONS
• Tell us:
• Your Name
• Your Institution
• How long have you
been a research
administrator?
• What are your burning
questions?
SPONSORED PROGRAM
BASICS:
GRANTS VS. GIFTS
Sponsored Program
 There is a quid pro quo
 Deliverables are required
 F&A (indirect) costs are
provided by sponsor policy
 Official acceptance is
required
 Specific time frame
 Application is in response to
a solicitation
Gift or Donation
 No exchange of mutual
consideration
 Funds are irrevocable
 “Donative intent” is clearly
implied
 Acceptance does not
require the University to
change magnitude or
direction of its current
efforts
SPONSORED PROGRAM BASICS:
GRANT LIFE CYCLE
Image courtesy of
University of
Delaware
• Really Centralized
SPONSORED PROGRAM
BASICS:
INSTITUTIONAL
STRUCTURES
• There can be only one
OSP! (OSP does
everything)
• Centralized
• Departmental staff do
proposal development,
and OSP does all preaward processing
• Decentralized
• Most/many pre-award
tasks happen in
depts/units, but OSP
handles final submissions
• Really Decentralized
• All pre-award, including
submission, happens at
dept/unit level. OSP
handles award
negotiations
SPONSORED PROGRAM
BASICS:
PRE-AWARD VS. POSTAWARD
Pre-Award
•
•
•
•
•
•
•
•
Proposal Preparation
Proposal Budgeting
Proposal Submissions
Award Negotiations
Revisions
Continuations
No-Cost Extensions
RPPRs and Progress Reports
Post-Award
• Account Setup
• Day-to-Day Accounting
• Invoicing
• Financial Drawdowns
• Financial Reporting
• Effort Reporting
• Closeout
HOW PRE-AWARD WORKS
Department or
•Generates ideas
•Creates proposal
•Notifies Dept/College
RA
•Discusses project with
Department Chair
Faculty
College
•Proposal Development
•Reviews and Approves
•Sends to OSP
•Final Review
•Final Approval from
AOR
•Final Submission to
Sponsor
Central OSP
PRE-AWARD TIMELINE
FOR REVIEW
• How long does a good
pre-award review take?
• How many proposals can
each individual handle at
once?
• How is your workload
divided?
• How experienced is your
team? Your faculty?
• Insufficient lead time is
THE #1 stressor of
research administrators!
• The answer: Your Timeline
Policy!
COMMON PRE-AWARD
PITFALLS
• Insufficient lead time
• Insufficient training
• Research administrators
• Faculty
• Department staff
• Poor business practices
• Inefficiencies
• Ill-defined institutional
policies
• Missing documentation
• Subaward materials
• Consultant letters
• Principal Investigators
• If they didn’t read the
sponsor guidelines…
• If they’re indecisive
• If they waited to start
writing until deadline
week…
CRUCIAL SKILLS FOR
RESEARCH
ADMINISTRATORS
• Reading Comprehension
• Communication
• Critical Thinking
• Time Management
• Filtering the Important
from the Noise
• People Skills
• Judgment
• Computer Skills
• Math
READING
COMPREHENSION
• The ability to read text, process it, and understand its meaning
• 2CFR200.413: Clerical and Administrative Salaries:
“The salaries of administrative and clerical staff should normally be treated
as indirect (F&A) costs. Direct charging of these costs may be appropriate
only if all of the following conditions are met:
1. Administrative or clerical services are integral to a project or
activity;
2. Individuals involved can be specifically identified with the
project or activity;
3. Such costs are explicitly included in the budget or have the
prior written approval of the Federal awarding agency; and
4. The costs are not recovered as indirect costs.”
CRITICAL THINKING
• the intellectually disciplined process of actively and
skillfully conceptualizing, applying, analyzing,
synthesizing, and/or evaluating information gathered
from, or generated by, observation, experience,
reflection, reasoning, or communication, as a guide to
belief and action
• clear, reasoned thinking involving critique
• Dan Kurland’s www.criticalreading.com
FILTERING THE
IMPORTANT FROM THE
NOISE
• The first few years in research administration has been
compared to drinking from a firehose
• Each set of regulations may span 100+ pages
• Each proposal will involve sponsor guidelines from 1-300+
pages
• Each institution has policies that may total 100+ pages
How do you determine what’s important in each
situation??
PEOPLE SKILLS
• The ability to communicate effectively with people in a
friendly way, especially in business. The term people
skills is used to include both psychological skills and
social skills
JUDGMENT
• An opinion or decision that is based on careful thought
• The act or process of forming an opinion or making a
decision after careful thought : the act of judging
something or someone
• The ability to make good decisions about what should
be done
COMPUTER SKILLS
• Knowing how to use that
machine they give you to
work on
• Microsoft Office
• Excel, Word, PowerPoint
• Adobe PDF Professional
• Accounting Software
• PeopleSoft, Banner
• Database Software
• InfoEd, ClickCommerce,
Cayuse, KualiCoeus
• Sponsor Systems
• Grants.gov, FastLane
MATH SKILLS
• The ability to work with
numbers
• Operations
• Addition, Subtraction,
Multiplication, Division
• Fractions and
Percentages
• Algebra
• Solving for “x”
• Khan Academy
COMMUNICATION
• The act or process of using words, sounds, signs, or
behaviors to express or exchange information or to
express your ideas, thoughts, feelings, etc., to someone
else
TIME MANAGEMENT
• The act or process of planning and
exercising conscious control over the
amount of time spent on specific activities,
especially to increase effectiveness,
efficiency or productivity
• It is a meta-activity with the goal to
maximize the overall benefit of a set of
other activities within the boundary
condition of a limited amount of time
TAKING CHARGE OF YOUR
PROFESSIONAL
• Research Administration
DEVELOPMENT
Career Paths
Central -> Departmental
Departmental -> Central
Pick One and Stay There
Compliance
Universities, Nonprofits,
Hospitals, Military
• And SO MANY MORE
OPTIONS…
•
•
•
•
•
DEVELOPING YOUR
SKILLS
• Overall:
• Practice, Practice,
Practice!
• Listen and Learn
• Take Advantage of ALL
Available Training
• Including CITI,
Responsible Conduct
of Research, etc!
• Ask to Sit in at Meetings
• Find a Mentor
• Someone who has
already been where
you want to go
• Someone respected in
the field
• Someone who you get
along with and enjoy
talking to
HOW TO REVIEW A PROPOSAL:
WHAT YOU NEED TO KNOW BEFORE
YOU START
Rules & Regs Before
12/26/14
• 2CFR220 Cost Principles for
Educational Institutions
• Formerly OMB Circular A-21
• 2CFR215 Uniform Administrative
Requirements for Grants and
Agreements with Institutions of
Higher Education, Hospitals, and
Other Non-Profit Organizations
• Formerly OMB Circular A-110
• OMB Circular A-133 Audits of
States, Local Governments, and
Non-Profit Organizations
Rules & Regs After
12/26/14
• 2CFR200 Uniform
Administrative
Requirements, Cost
Principles, and Audit
Requirements for Federal
Awards
• Also known as:
• Uniform Guidance
(UG)
• OMB-zilla
• A-81
HOW TO REVIEW A PROPOSAL:
WHAT YOU NEED TO KNOW BEFORE
YOU START
• Cost Accounting Standards
• CAS 9905.501 Consistency in Estimating, Accumulating, &
Reporting Costs
• CAS 9905.502 Consistency in Allocating Costs Incurred for
the Same Purpose
• CAS 9905.505 Accounting for Unallowable Costs
• CAS 9905.506 Cost Accounting Period
RULES AND
REGULATIONS: FEDERAL
• Human Subjects
• Belmont Report: Ethical
Principles and
Guidelines for the
Protection of Human
Subjects of Research
• 45CFR46: Basic HHS
Policy for Protection of
Human Research
Subjects
• Animal Care and Use
• HEALTH RESEARCH
EXTENSION ACT OF 1985
PUBLIC LAW 99-158
• Animal Welfare Act
RULES AND
REGULATIONS: FEDERAL
• Intellectual Property
• Overview from Sanford
Encyclopedia of
Philosophy
• Bayh-Dole Act, P.L. 98620
• Export Control
• International Traffic in
Arms Regulations (ITAR)
• Export Administration
Regulations (EAR)
• Office of Foreign Assets
Control Regulations
(OFAC) OFAC website
RULES AND
REGULATIONS: STATE
• Each state has its own set of rules and regulations
• These may be different from the federal regulations
RULES AND
REGULATIONS: YOUR
INSTITUTION
• Your Institution’s Policies
•
•
•
•
•
Faculty effort on research projects
Course release
Cost sharing and matching
Timeline for review
F&A Rate Agreement/Fringe Benefits
• Use of off-campus rates
…and more
EXERCISE: WHAT
WOULD YOU DO?
HOW TO REVIEW A
PROPOSAL
• Gather Materials
• Sponsor Guidelines
• Proposal Documents
• HR information on the PI
and other participants
• Sponsor Forms and
Templates
• References (2CFR200,
institutional policies, etc)
GET ORGANIZED
• Start a Notes File or
Comment Log
• Use a File System that
works for you
• Keep everything
together
• Make it difficult to lose
things
READ THE SPONSOR
GUIDELINES
• The #1 rule: RTFM
“Read the Fine Manual!”
• Why?
• It tells you exactly what
the sponsor is looking for
• The PI may not have
read it or may not
understand it
• If the proposal is not
compliant, it will not be
reviewed
• You will need these skills:
• Reading
Comprehension
• Critical Thinking
• Filtering the Important
from the Noise
READ THE SPONSOR
GUIDELINES
• Look For:
• Eligibility rules
• Deadlines
• Funding Restrictions
• F&A costs
• Funding minimums or
maximums
• Budget categories the
sponsor will not fund
• Terms and conditions
• Contract language
• Ask Yourself:
• Is my institution eligible?
• Is this a good fit for the
PI’s research?
• Is this a good fit for my
institution?
• Are there other
documents I need to
review?
• NSF, NIH, USDA, and
others have additional
info available!
OUR FORMS, OUR LIVES
• Internal Forms
• Processing Forms
• Clinical Research
Documentation
• Internal Budget
Worksheets
• Sponsor Forms
• SF424
• FastLane Forms
• Sponsor-Specific Forms
REVIEW THE NARRATIVE
MATERIALS:
LOOK FOR..
• Format
• Does it meet the
specifications in the
guidelines?
• Are all of the documents
present?
• Are all of the subject
areas addressed?
• Suggest using the
guidelines as a
template!
• Organizations or people
named as partners
• Are they receiving
funds? Endorsing the
project?
• Depending on
involvement, you may
need a letter from them!
REVIEW THE NARRATIVE
MATERIALS:
LOOK FOR..
• Implied Cost Share
• “Dr X will spend 15% of
his time on this project”
when there is no effort in
the budget
• “We will leverage
$50,000 for this project in
the form of volunteer
time…”
• All cost share must be
documented in the
budget!
• Hidden Commitments
• “New lab space!”
probably needs to be
vetted with the
department chair first!
• Typos, Grammatical Errors
• Yes, PhDs make them all
the time
• Yes, you should say
something
REVIEW THE NARRATIVE
MATERIALS:
LOOK FOR..
• Human Subjects:
• Medical procedures
• Psychological testing or
treatment
• Surveys
• Focus Groups
• Using human tissue or
cells: make sure you
know where it’s coming
from!
• Animal Care and Use:
• Vertebrate animals
• Anything with a spine
• Kittens, puppies and
fluffy bunnies count!
• Insects do not count!
• Not just lab animals–
some studies involving
observation of wildlife
must be reviewed, too!
REVIEW THE NARRATIVE
MATERIALS:
LOOK FOR..
• Hazardous Materials:
•
•
•
•
•
Radioactive Materials
Recombinant DNA
Biohazards
Select Agents
Pathogens
• Viruses
• Some bacteria, etc
• Any point in which the
proposal narrative strays
from the focus suggested
by the guidelines
• Is the project a good fit?
• If not, is there another
opportunity that would
be better?
EXERCISE: SAMPLE
NARRATIVE
WHAT IS A BUDGET?
• The financial story of your
project
• Two parts:
• Budget form
• Itemized list of costs
• Budget narrative
• Description of costs
• How they were
calculated
• Why they are
important
REVIEWING THE BUDGET
• You will need these skills:
•
•
•
•
Judgment
Math Skills
Computer Skills
Critical Thinking
REVIEW THE BUDGET:
LOOK FOR…
• Check all calculations
• Pay special attention to
F&A calculations
• Make sure the numbers in
the budget narrative
match those on the
budget forms
• Make sure all items of
cost are allowable
• Make sure all items are
properly categorized
• Salary and fringe benefits
should be budgeted
separately
• If graduate assistants are
budgeted, their tuition
should usually be
budgeted too
• Make sure
documentation is present
for consultants,
subawards, equipment,
etc
REVIEW THE BUDGET:
UNDERSTANDING
ALLOWABILITY
• Sponsors award to many
types of organizations
who operate under
different cost principles
•
•
•
•
•
Universities
Nonprofits
Hospitals
Individuals
Corporations
• In order to be allowable,
a cost must
• Conform to Cost
Principles (2CFR200)
• Necessary
• Reasonable
• Allocable
• Conform to institutional
policy
• Consistently treated
• Be budgeted in an
appropriate budget
category
DIRECT AND INDIRECT
COSTS
• Direct Costs
“costs that can be
•
Indirect
Costs
(F&A)
identified .. with a
“costs incurred for
particular sponsored
common or joint
project..or that can be
objectives and ..cannot
directly assigned to
be identified readily
activities relatively
and specifically with a
easily with a high
particular sponsored
degree of accuracy.”
project..or other
activity.” (A-21, E.1)
(A-21, D.1.)
DIRECT AND INDIRECT
COST EXAMPLES
• Direct Costs
– Salary and Wages
– Fringe Benefits
– Travel
– Equipment
– Supplies
– And more..
• Indirect Costs (F&A)
• Some Administrative
Salaries and Wages
• Office Space
• General and Office
Supplies
• And more..
COST SHARE
• The portion of a project’s
cost that is paid by the
institution or another
(non-sponsor) party
• Types of Cost Share:
• Mandatory
• Voluntary Committed
• Voluntary Uncommitted
• Cost Overrun
COST SHARE RULES
• Same Allowability rules as
Direct Costs
• Necessary
• Reasonable
• Allocable
• Costs must be incurred
during the same project
period
• Must be verifiable from
institution’s records
• Must be in support of the
same project
• Funds can only be cost
shared once
• Federal funds generally
cannot be used as cost
share, especially on
another federal project!
COST SHARE: WHY NOT?
• Cost Share Myths:
• It will make
proposals more
competitive
• What Cost Share
Really Does:
• Usually doesn’t
unless sponsor
specifies
• It impacts reviewers’
funding decisions
• They may not even
see it!
– Lower the
institution’s F&A
recovery
– Use up scarce
resources
– Create additional
administrative
burden
BUDGET CATEGORIES
• Salaries and Wages
• Fringe Benefits
• Materials and Supplies
• Equipment
• Travel
• Consultants
•
•
•
•
Subawards
Participant Support
Patient Care
Other Costs
– Tuition
– Usage fees
– Rent
– Et cetera…
BUDGET CATEGORIES
• Salary and
Wages
• Usually the largest cost
category
• Includes faculty effort,
Postdocs, Students, etc
• Everyone paid by your
institution
• Must have associated
fringe benefits in the
budget
• Generally
Unallowable:
– Housekeeping
– IT staff
– Research
administrators,
etc
• 2CFR200.414
BUDGET CATEGORIES
• Fringe Benefits
• Negotiated with federal
government alongside
our F&A rates
• Must be budgeted for all
direct salaries and wages
• There are usually several
rates
• Faculty/FT
• Summer/PT
• Students
• To Calculate:
– Individual’s salary
on the project x
Fringe Rate
• Travel Costs
BUDGET CATEGORIES
• Necessary and
reasonable
• Typical travel budgets
include:
•
•
•
•
Airfare/transportation
Lodging
Per Diem
Registration
• Unallowable
costs that can be
travel related:
– Alcoholic
beverages
– Entertainment
– Dry cleaning
BUDGET CATEGORIES
• Travel (continued)
• Domestic or
International?
• Foreign Travel usually
requires approval from
the university at
minimum before the
travel happens
• 2CFR200.474
• Potential issues:
• Duty of care: the
university has to know
where its people are
located when on official
business
• Export control: travel
may be restricted or you
may not be able to take
certain items/info with
you
• Equipment
BUDGET CATEGORIES
• Federal definition: $5000
or more per item, with
useful life of more than
one year
• Always get a quotation!
• Things often
erroneously
budgeted as
equipment:
– Computers
– Cameras
– Chainsaws
• Not kidding.
Seriously.
BUDGET CATEGORIES
• Materials and
Supplies
• Tangible property
• Meant to be consumed or
used up
• Must be allocable!
• Generally
Unallowable:
– Office supplies
– Furniture
– General use
computers
– Food
BUDGET CATEGORIES
• Consultants
• Can’t be faculty at your
institution
• Your faculty must be
budgeted in Salary &
Wages
• Limited participation in
the project
• Only party who stands to
profit or lose from
participation
• In business for themselves
• Consultants must:
• Submit a signed letter
with the rate and total
dollar amount
BUDGET CATEGORIES
• Subawards
–Usually another
university or legal
entity
–Partner on the
project with
substantial
involvement
• Subaward package
includes:
• AOR-signed letter or
face page (SF424 or
PHS398)
• Scope of work
• Budget and budget
narrative
• CVs for key personnel
• Any other information
required by the sponsor
CONSULTANT OR
SUBAWARD?
Consultant
Subaward
• Is in business for him or
herself
• Handles a substantial
piece of the project
• Stands to profit or lose
from participation
• Rules and Regs flow
down
• Limited part of project
• F&A is calculated only on
the first $25,000
• Must be external to your
institution
• Full F&A is calculated
• Patient Care
BUDGET CATEGORIES
• Mainly found in clinical
trials
• Cost of caring for human
subjects
• Both patient care and
participant support costs
are exempt from F&A
• Participant Support
– Items or funds that
go directly to
program
participants
– Incentives for
research subjects
are not necessarily
participant support!
– Training materials
BUDGET CATEGORIES
• Other Costs
• Rent for off-campus space
• Postage
• Printing Costs
• Long distance telephone
• Advertising
• Tuition costs for graduate
students
• Equipment usage fees
• Software
TOTAL DIRECT COSTS
• All of these budget
categories equal your
Total Direct Costs
• The amount your PI will
be able to spend, in
other words..
MODIFIED TOTAL
DIRECT COSTS
• MTDC = Total Direct Costs
– Exclusions
• Equipment
• Tuition
• Amount of each
subaward in excess of
initial $25,000
• Patient Care
• Participant Support
• Rent
• Capital
improvements
(construction, etc)
SALARY AND WAGES
BASE
• If your institution uses a
salary and wages base,
you would calculate your
F&A on the Salary and
Wages total rather than
calculating MTDC.
INDIRECT COSTS
• F&A (Indirect Costs)
• Rates are negotiated
with the federal
cognizant agency
• DHHS or ONR
• Classifications
• Research, Training, or
Other
• On-Campus or OffCampus
To Determine Which Rate
To Use:
• Look at your
institution’s NICRA
• What type of project is
it?
• Where is the work taking
place?
SPONSOR-LIMITED F&A
RATES
• A sponsor may only pay
a certain percentage, or
may not allow F&A at all
• Must be in writing
• Must be an actual
policy that applies to all
• Examples:
– NIH F31
fellowships do not
separately
reimburse F&A
– US Dept of
Education limits
F&A to 8%
INDIRECT COST
CALCULATIONS
• Calculate Total Direct
Costs
• Calculate Modified Total
Direct Costs
• Multiply the MTDC by the
applicable F&A rate
Indirect Costs = Rate
x Modified Total
Direct Costs (MTDC)
TOTAL BUDGET
CALCULATION
• Total Budget = Total
Direct Costs + Indirect
Costs
• Most common error:
using MTDC instead of
total direct costs!
• You have completed your proposal review!
• You’re not done yet, though!
• Now you have to communicate with your PI to resolve
issues.
COMMUNICATING WITH
FACULTY
• Summarize your notes in • This gives you:
an email to the faculty
• A running to-do list for
member
you and the PI
• Numbered list
• One issue per number
• Tell them about all
changes
• Make sure they know
what action is needed
• Clear documentation of
where the proposal is in
the process
THE WORLD OF FACULTY
• A PhD takes an average
of 8.2 years to complete
• A scientist then may do a
postdoctoral
appointment of 2-4 years
• Faculty start at Assistant
Professor on the tenure
track, with hopes of
eventually making it to
Full Professor
• There are reviews and
checks along the way,
but generally they have
3-5 years to earn tenure
• If they are denied, it can
be career ending (or at
least career changing)
• Getting a grant is often a
condition of tenure, as is
a certain number of
publications
THE WORLD OF FACULTY
• Faculty lives revolve around
three areas:
• Teaching
• Classes, classes, and
more classes
• Research
• Conducting
experiments,
developing projects,
writing proposals, and
writing scholarly papers
• Service
• Serving on committees,
chairing committees,
etc
• This amounts to 60-80 hour
weeks in some cases
• No overtime
• Very little support
• Departmental politics
can cause stress
• BUT they have academic
freedom and can spend
their time on the subject
matter they are
passionate about!
THIS GRANT COULD
MEAN…
• Tenure for the faculty PI
• Jobs for the postdocs, graduate students, and others
listed in the budget
• Development of new research or technology that
could change the world
Every grant is a big deal, in other words!
THINGS TO REMEMBER:
• Faculty are people, too
• Diversity
• Culture
• Life outside the
academe
• You are on the same
team
• Be professional
• But it’s okay to be friends
• Your Credibility and
Integrity are of utmost
importance!
• Know what you’re
talking about before
you engage!
EGOS AND UNFRIENDLY
TYPES
• Assume Positive Intent
• Take Nothing Personally
• Understand that it comes
with the territory
• Don’t take the bait
• Don’t be afraid to ask for
help
• But don’t immediately
run for the hills either!
COMMUNICATING “NO”
• Guidance, not
Gatekeeping
• “No, I’m not letting you
do that” vs.
• “That’s an unallowable
cost under 2CFR200, but
let’s talk about what you
really need..”
• Focus on honoring intent:
• How CAN we do what
needs to be done
CHAPTER AND VERSE
• How much information is
too much?
• May vary from one
faculty member to
another
• Use direct quotes when
you need to..
• ..But explain in plain
language whenever
possible!
• Use your
• Judgment
• People Skills
• Communication
WHEN TO CALL IN
THE BIG GUNS
• Judicious use of the
“Dean Card”
• Don’t cc the boss on
everything!
• Yours OR the faculty
member’s!
• When to call for backup:
• The faculty member is
abusive
• You don’t fully
understand the issues or
know what to do
• Multiple attempts to
explain have been
unsuccessful
• You’re losing your
temper
STRESS FREE
SUBMISSIONS
• Get information as soon
as you can, well ahead
of the deadline
• Get organized
• Work through the issues
with the PI
• Send for approvals well
ahead of the deadline
crunch
• Anticipate issues and
questions
• Be proactive
• Stay calm
• Take breaks
YOUR FACILITATOR FOR
TODAY:
Brigette Pfister,
MHRD, CRA
• Director of Sponsored
Programs for Humanities
& Sciences, Virginia
Commonwealth
University
bspfister@vcu.edu
QUESTIONS?
REFERENCES AND
ACKNOWLEDGEMENTS
• David Smelser, University of Tennessee (Research
Administration Memes)
• Grants.gov Glossary
• RACC CRA Body of Knowledge
• Stanford University DoResearch (Export Controls)
• Uniform Guidance (2CFR200)
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