federal update

Jeff WarnerContract and Grant Offi cer

Danielle VandenBos Esq.Contract and Grant Offi cer

FEDERAL UPDATE

Spring QRAM - Monday, March 14, 2012


NIH Fiscal Policy - FY 2012

NRSA Budgetary Levels

NIH Effi cient Spending – Conference Gants

NIH Resubmissions

NIH – LikeThis

DHHS – Salary Limitation

NIH E-Submission Supplement Requests

Important ARRA Information

E-Verify FAR Clause

NSF Senior Project Personnel

Multiple PI Assurance

DoD – Enhanced IRB Requirements

Sponsor Climate in Washington

Subaward Proposal Package

FEDERAL UPDATE AGENDA:


Non-competing awards will be issued without cost of living/infl ationary adjustments in FY 2012 and infl ationary 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.

NIH FISCAL POLICY FOR GRANT AWARDS – FY 2012

NOT-OD-12-036


This Notice establishes new stipend levels for fi scal 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 refl ect the FY 2012 stipend level once the revised award is received.

RUTH L. KIRSCHSTEIN NATIONAL RESEARCH SERVICE AWARD (NRSA) STIPENDS, TUITION/FEES AND OTHER

BUDGETARY LEVELS EFFECTIVE FOR FISCAL YEAR 2 012NOT-OD-12-033


Eff ective 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 Scientifi c Meeting (i.e. R13s and U13s) ; however, other grant mechanisms that are specifi cally 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.

NEW NIH POLICY ON EFFICIENT SPENDING RELATED TO GRANTS SUPPORTING CONFERENCES

AND MEETINGSNOT-OD-12-041


Resubmission– A proposal submitted to make a signifi cant 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 Identifi er in the applicable section of the SF 424 (4A).

The Federal Identifi er is the Institute Code and Serial Number assigned to the previous submission (ex. CA123456). This number is available in the eRA Commons.

NIH RESUBMISSIONS


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.

NIH - LIKETHIS (A THESAURUS-BASED SEARCH TOOL)


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 effi ciently:

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; andfigure out in which study section his or her

application should be reviewed.

NIH - LIKETHIS (A THESAURUS-BASED SEARCH TOOL)


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 fi scal year funds use the salary cap that was in eff ect for that particular fi scal 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.

SALARY LIMITATION ON GRANTS, COOPERATIVE AGREEMENTS AND CONTRACTS FROM NIH AND

AHRQNOT-OD-12-035 & NOT-HS-12-007


When the issue date of an award is on

orbefore December 22, 2011

initial issue date of an award is on or after December 23

If the award is a non-competing renewal AND initial issue date is on or after December 23

The following will apply: The FY 2012 award w i l l remain a t the

$199,700 sa lary cap and the fo l low ing years w i l l be ad jus ted downward to the $179,700 cap or the cap in eff ect when the new non-compet ing renewal i s i ssued.

The $179,700 sa lary cap w i l l app ly.I f the award i s a new or compet ing award , N IH w i l l i s sue a rev ised Not ice o f Award , ad jus t ing the award and the fo l low ing years to refl ect the new sa lary cap .

The new cap app l ies but N IH w i l l not ad jus t the award . Pr inc ipa l I nvest igators may re -budget the “funds f reed as a resu l t o f the lower cap” in to other budget categor ies . Future non-compet ing renewals , however , w i l l be at the sa lary cap o f Execut ive Leve l I I in eff ect a t the i ssue date o f the renewal .



http://osp.mit.edu/glossary/term/151



UCI Implementation:Sponsored Projects has modified its awards synopsis

so that the Contract and Grant Offi cers 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.”




Administrative Supplement requests may now be submitted through either the eRA Commons or Grants.gov, as described in NOT-OD-12-024 (notifi cation of the availability of the two pilot processes), or through the existing, paper-based process.

NIH has published the fi rst 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.

NEW ELECTRONIC SUBMISSION PROCESS NOW AVAILABLE FOR ADMINISTRATIVE SUPPLEMENT

REQUESTSNOT-OD-12-043

http://grants.nih.gov/grants/guide/notice-files/NOT-OD-12-024.html

http://grants.nih.gov/grants/guide/pa-files/PA-12-100.html


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.




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.



http://grants.nih.gov/grants/guide/url_redirect.htm?id=11123

http://grants.nih.gov/grants/guide/url_redirect.htm?id=11123


On September 15, 2011, the Offi ce 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 eff orts 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.

IMPORTANT INFORMATION REGARDING ARRA AWARDS




For awards scheduled to end on or BEFORE September 30, 2013

I f a no-cost extension is necessary, i t must be requested by JUNE 1, 2012, regardless of the end date of the award.

Grantees may st i l l exerc ise their one-t ime, grantee-approved no-cost extension as long as the per iod of performance with the extension does not extend beyond September 30, 2013.

However, i f a Pr inc ipal Invest igator requires an extension beyond September 30, 2013, he/she must fol low the guidance for “awards that are scheduled to end after September 30, 2013.”

For awards that are scheduled to end AFTER September 30, 2013

I f a no-cost extension is necessary, it must be requested by June 2, 2012.

The NIH Grants Management Offi cer for the award must be notifi ed in writing via the appropriate Contract and Grant Offi cer in Sponsored Projects of the request for an extension.

The request for extension must explain why an extension of the project is vital for its completion.

IMPORTANT INFORMATION REGARDING ARRA AWARDS – NIH GUIDANCE




If a no-cost extension is necessary, it must be requested by June 2, 2012 , regardless of the end date of the award.

Grantees may stil l exercise their one-time, grantee-approved no-cost extension as long as the period of performance with the extension does not extend beyond September 30, 2013.

The deadline for an extension past September 30, 2013 was March 2nd.

Awards that are scheduled to end AFTER September 30, 2013, were required to submit their plan to accelerate completion was due to the Program Offi cial on March 2 nd.

NSF will amend awards to ensure that the period of performance does not extend beyond September 30, 2013 in order to comply with the OMB memorandum

IMPORTANT INFORMATION REGARDING ARRA AWARDS – NSF GUIDANCE




Sponsored Projects strongly encourages Principal Investigators to responsibly accelerate spending on their ARRA awards to the greatest extent possible because waivers are not guaranteed.

IMPORTANT INFORMATION REGARDING ARRA AWARDS


Eff ective September 8, 2009, all employers who receive specifi c 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.

FAR CLAUSE: E-VERIFY REQUIREMENT52.222-54


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 off er of employment and completed the Form I-9.

Please see all UC E-Verify Guidelines here: http://snap.uci.edu/viewXmlFile.jsp?resourceID=4365

FAR CLAUSE: E-VERIFY REQUIREMENT52.222-54


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 NSF-funded 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.

NSF - SENIOR PROJECT PERSONNEL SALARIES & WAGES POLICY


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.

MULTIPLE PI ASSURANCE


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

DOD – ENHANCED IRB REQUIREMENTS


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 Offi ce of Scientifi c 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.

SPONSOR CLIMATE IN WASHINGTON


Subrecipient Commitment Form: All Subrecipients must complete this form when submitting a proposal to UCI.

Detailed Scope of Work

Detailed Budget and Justification

SUBAWARD PROPOSAL PACKAGE


Should you have any questions, please feel free to contact your Contract and Grant Offi cer.

Jonathan Lew: 949-824-3029 or [email protected]

Alison Yeung: 949-824-2644 or [email protected]

Danielle VadenBos Esq.: 949-824-7109 or [email protected]

Leighsa Washington: 949-824-2460 or [email protected]

Jeff Warner: 949-824-4781 or [email protected]

CONTRACT AND GRANT OFFICERS

mailto:[email protected]





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