sponsored programs at penn proposal budget preparation, budgeting using pennera and routing &...

1The Office of Research Services

The Office of Research Support Services REVISED September 2013

Sponsored Programs at Penn

Proposal Budget Preparation, Budgeting Using PennERA

and Routing & Approval



Where Do You Start?

• Gather the Facts – Talk to the Principal Investigator (PI)

• What is the Scope of Work?• Who is the Sponsor?• Where will the work be performed?• Collaborators?• Consultants?



Sponsor Guidelines

• Instructions and Contractual Terms• Requests for Proposal/Quote (RFP/RFQ)• Requests for Application (RFA)• Funding Opportunity Announcements (FOAs)• “Unsolicited” Applications• Send sponsor guidelines, instructions,

contractual terms, etc., to Research Services



Cover Page

• PI Name• Title • Name of Grantee

– Trustees of the University of Pennsylvania• Period of Performance• Amount Requested • Required Signatures



RFProposal • Government generates scope of work via

Notices/Program Announcements.• You respond with how you will accomplish,

budget and time frame.• Contract is usual award document for RFP/RFQ

while a grant/cooperative agreement is usual award document for RFA.

RFQuotationRFApplication



Budget preparation is a collaborative effort!

• Principal Investigator:– Should work with the Grants Manager to develop the

budget.– Designates others who might have input, e.g., lab

manager, research coordinator.



Reasons for carefully preparing the budget

• Reduces the possibility of significant budget cuts by the sponsor.

• Aids post-award management.• Aids the department in budget planning.• Significant budget changes are interpreted by

sponsors as a change in scope!



Preparing the Budget

• Costs requested in proposal budget must:– Be Allowable (Factors used in determining)

• Allocable • Reasonable• Consistently Estimated

– Directly benefit the proposed project

Costs must be necessary for the performance of the award (OMB Circular A-21); SPP #2108, #2110, #2138

http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html

http://www.finance.upenn.edu/vpfinance/fpm/2100/2108.shtml

http://www.finance.upenn.edu/vpfinance/fpm/2100/2110.asp




Regulatory guidance• CAS 501 (app. OMB A21, 48 CFR 9905.501)

– “The purpose of this standard is to ensure that each educational institution's practices used in estimating costs for a proposal are consistent with cost accounting practices used by the educational institution in accumulating and reporting costs.”




Other considerations• Sponsor guidelines and limitations

– Salary caps– F&A limitations– Direct cost or total cost limits– Expense category exclusions

• Recover F&A as direct costs from non-governmental sponsors– SPP #2138 Direct Cost Expenditures for Non-Govern

mental Agencies• May be School-specific rules





Preparing the Budget (Salary)• Salary requests are expressed as % effort or person

months• Plan realistically

– Determine the percent of effort for all personnel needed to conduct the project

– Downward adjustments of effort may need sponsor approval

• Percent of effort=Percent of salary requested– Cost sharing is discouraged– Avoid hourly rates

• Cannot usually charge clerical salaries or administrative costs directly



Allowability of clerical and/or administrative staff expense

• Generally part of F&A costs.• Possible exceptions (see OMB A21, Exhibit C):

– Large, complex programs (e.g., Center grants).– Epidemiological studies, clinical trials.– Scheduling seminars/conferences attended by large

numbers of participants.– Individual projects requiring project-specific tasks

such as database management, human and animal protocols, etc.




Preparing the Budget (Benefits)

• Fringe Benefits are charged as a % of Salary• As of 06/21/13, rates on federally sponsored

projects:– Full-time employees – 31.8%– Part-time employees - 9.7%

• For non-Federal sponsors, add Spouse and Dependent Tuition Benefit (2.2% ) for full-time employees

• Current F&A and benefits rates

http://www.upenn.edu/researchservices/history.htm



Preparing the Budget (Equipment)• Definition

– “Equipment” costs $5,000 or more per item, and has a useful life of more than 1 year

– Includes computer software that meets this definition (capitalized computer software).• Accounting Policy #1106.0

• Justification– Why is this item necessary to support the science?– When is it necessary?

• Availability– Is the equipment available elsewhere in the

University?• Competitive Bid Requirement

http://www.finance.upenn.edu/vpfinance/fpm/1100/1106.0.asp



Preparing the Budget (Office Supplies)

• Generally not treated as direct costs.• Can be allowable if specifically related to the

project. For example:– Specific aim of the project is to create a manual or

other instructional media.– Extensive human subjects data accumulation,

questionnaires, etc., is required.• Must be necessary for conduct of project

– OMB Circular A-21, Exhibit C




Preparing the Budget (Travel)

• Usually restricted to employees• Domestic• Foreign

– Fly America Act if Federal $$– May require prior approval even if in budget

http://osr.unc.edu/documents/federal_travel.pdf



Preparing the Budget (Patient Care)

• Defined in rate agreement:“…hospitalization and other fees associated with patient care whether the services are obtained from an owned, related, or third-party hospital or other medical facility…”

• Excluded from MTDC base and F&A calculations.



What is not included in patient care?

• Subject reimbursement and travel.• Costs of ancillary tests performed outside the

hospital on a fee-for-service basis.• Costs accumulated in service centers at Penn,

such as in Radiology for research patient care.• Consulting physician fees.• All of the above are “other” or “consultant”

expense.



Preparing the Budget (Subcontracts)

• Budget, including F&A costs• Copy of F&A rate agreement• Statement of Work (SOW)• Cover page/Letter of Intent with Authorized

Signature• Reps/Certs required by sponsor



Preparing the Budget (Consultants)• Penn staff usually cannot be included in this

category– If applicable, must coordinate payment through Penn

Payroll Office.• Consultant’s letter of intent and cost

– All costs related to the consultant including travel are usually accumulated in this category.

• Statement of Work– Consortium agreements typically used if consultants are

identified as Key Personnel.



Preparing the Budget (Other Direct Costs)• Service Center charges• Tuition and Fees (Research Projects)• Post Doctoral Health Insurance• Publication Costs• Protocol Review fees, when appropriate• Rent, when appropriate, but excluded from MTDC.• Animal per diem.• Subject compensation and travel

SPP #2110 Federal Direct Cost Expenditures;SPP #2138 Direct Costs Expenditures for Non-Government Organizations






Preparing the Budget (F&A Costs)• F&A = Overhead = Indirect Costs

– Pays for many costs that cannot be allocated to a specific project, i.e. utilities, administrative payroll and other support services, etc.

• The “Colleges and Universities Rate Agreement” contains the federally negotiated F&A rates

• F&A usually expressed as a % of a base• Modified Total Direct Cost Base (MTDC)

– Excludes equipment, patient care costs, student tuition, and fees, alterations and renovations, rental of off-site facilities and the portion of each subcontract in excess of $25,000

• Check sponsor guidelines for appropriate base

http://www.upenn.edu/researchservices/pdfs/negotiated.pdf



Preparing the Budget (F&A Costs)• Which rate to use?

– Research rates (on- and off-campus) [60% & 26%]– Certain DOD Contracts [62%]– Instruction [57%]– Other Sponsored Activities (on- and off-campus) [36% &

26%]• Examples: health or community service projects,

seminars, conferences, exhibitions, lecture programs– Clinical Trials [28% Total Direct Costs (TDC)]– Corporate Contracts [62%]

• Current agreement

http://www.upenn.edu/researchservices/pdfs/negotiated.pdf



When is the offsite rate applicable?

• Use this rate whenever activity will occur for 3 months (or 25%) or more at a facility not owned by the University.– Consider preparing a split-rate budget when

appropriate.• Remember that rent can be a direct charge

when using the off-site rate.– Rent is excluded from MTDC and F&A calculations.



Don’t overlook• Are there humans involved?

– Subject compensation and travel?– Related patient care costs?– Equate costs proposed to research plan, especially

with the consents.• Are there animals involved?

– Prepare detail cost estimate: include shipping and box charges.

– Animal per diem?– Equate costs proposed to research plan.



…and more• Are there large pieces of equipment?

– Installation and set-up included?– Maintenance contracts?– Space available or renovation costs included?

• Provide a quote.• Are there pre- and or post-docs?

– Tuition included?• Excluded from MTDC and F&A.

– Health insurance costs listed?• Not excluded from MTDC.



Budget Justification

• Each line item usually requires specific justification.

• Unusual or extraordinary expenses such as equipment, clerical salaries and administrative expenses, may require additional justification.

• Check sponsor guidelines for requirements.



Other Considerations

• Specific Sponsor Requirements– NIH modular: ≤$250,000/year– Many non-Federal sponsors may not allow PI salary,

benefits, travel, etc.• Penn Participation Agreement



Terms & Conditions• Terms and Conditions

– Must be consistent with University mission of research, education and service

– No bars on publication– University owns and controls intellectual property– Federal regulations appropriate to educational

institutions are used



Budgeting Using PennERA Proposal Development (PD)



Budgeting Using PennERA PD• Type of budget is automatically

determined by PD during proposal setup.



Budgeting Using PennERA PD• Type of budget is automatically

determined by PD during proposal setup.

• Proposal creator answers questions so that PD can select the correct configuration.



Sample Budget Configurations Typical setup – detail or simplified entry, S2S or generic records.

Modified for NIH modular budget – detail or simpli-fied entry, only S2S.

Noncompeting records or S2S not requiring a detail budget.



Budgeting Using PennERA PD• Two budget entry methods

– Simplified•Minimal data entry•Use if not a Federal system-to-system (S2S) requiring a detail budget



Budgeting Using PennERA PD• Two budget entry methods

– Detail•As required by Federal sponsor’s instructions

•Can be used in any PD record



• Detail – Personnel Expense



• Detail – Personnel Detail Entry



• Detail – Non-Personnel Expense



• Detail – Non-Personnel Detail Entry



• Detail – Subcontract Expense



Budgeting Using PennERA PD• Complete other sections:

– F&A• Many proposal records calculate F&A automatically

• If manual entry is used, reset to autocalculation if editing budget expense data entry



Budgeting Using PennERA PD• Complete other sections:

– Cost Sharing• Observe Penn’s cost-sharing policies

• Complete cost-sharing form– Upload Budget Justification



Routing & Submission



PI and BA Submit Proposal• PI and Business Administrator (BA)

have completed all components in PD• Participation Agreement signed and

filed in department• Upload internal documents (e.g., subaccount

worksheet)• PI completes certification• BA completes e-transmittal form• Record submitted to routing path for internal review



• What’s a routing path?

…and…



• What’s a routing path?…and final step…

• Approvers notified by e-mail message when previous reviewer approves the proposal.

• Only one approval is required per step.



Research Services Review• Review e-Transmittal Form &

PI certification for Accuracy & Completeness

• Regulatory Issues• Determine Type of Award• F&A Cost Review• Conflict of Interest• Cost Sharing• Terms & Conditions if

applicable• Check for electronic

submission validation issues



Purpose of e-Transmittal• The Transmittal Form

– Internal Form• Does not get submitted to sponsor

– Uses• Departments, make commitments & determine that

project is within total program and academic objectives of department

• Deans, determine that project is consistent with the total program objectives of the school and that commitments for project (including any cost sharing/matching funds) are acceptable

• Research Services uses it to create funds; accuracy matters



Proposal Routing and Submission• Approvals

– If project includes faculty from multiple schools/departments • Plan for additional time to secure appropriate approvals

– If project includes participation from another institution• Information from the other institution must also be

obtained and presented in the application• Plan for delays

– Electronic proposal submission issues– Administrative support assisting with multiple grant

applications from multiple PI’s– Broken copiers, scanners



Proposal Routing and Submission• Applications requiring additional information

(financial reports) require more time• Responses to RFP’s

– Contractual terms sent to Research Services as soon as possible

– Policy requires 5 days• PI’s transferring from another institution should begin

the transfer process as soon as they have accepted a position at Penn

• Observe individual School deadlines



Regulatory Issues• IACUC• IRB

• PI Submits Protocol electronically for Human Subject research using the HS-ERA system and for Animals using ARIES.



Office of Regulatory Affairs• Administers

– Institutional Review Board (IRB) – Institutional Animal Care and

Use Committee (IACUC)• Provides Research Services

with approval status for all protocols



Institutional Review Board• Protects the rights and welfare

of human research subjects• Authorized to approve, require

modifications in, or disapprove all research activities involving human subjects



Human SubjectsApproval Requirements & Timelines

• Approval of a human subject protocol for a new application is not required at time of submission – Unless mandated by sponsor – Approval can be “Just-in-Time” for NIH

• Human subject protocol approval and appropriate education certification– Required to be in place prior to the awarding of a new

project



Human SubjectsApproval Requirements & Timelines (cont.)

• For non-competing continuations the approval date must not be earlier than one year before the start date for which the progress report is submitted– If the protocol approval date does not meet this

criteria the non-competing application will be delayed



Institutional Animal Care and Use Committee (IACUC)

• Reviews and approves the care and use of animals in research



Use of AnimalsApproval Requirements & Timelines

• Approval of an animal subject protocol for a new application is not required at time of submission – Unless mandated by sponsor– Approval can be granted “Just-in-Time” for NIH

• Non-competing continuation applications must have a valid approval date at the time of submission



Reminders• Electronic Proposal Submission

– All Electronic Submissions are not created equal– Read the Instructions– Does the PI or Institution need to be registered users?– Is the required technology available at the

Department? At ORS? – All electronic applications must be approved by ORS

before submitting to sponsor even if a paper copy with signatures is required after electronic submission.

SPP #2102 Approval of Proposals




Reminders continued…• Meet the specifications of

the announcement • Make it easy for the

reviewers to see that you have done so

• Awards are made to the Institution

• Only Research Services is authorized to sign on behalf of the University



Questions???



Award Acceptance and Account Set-Up

Sponsored Programs at Penn



What is a Notice of Award (NOA)?

• A notice of grant award - also referred to as notice, NOGA, NGA, sponsor notice, contract or award letter - is an official notification from a sponsor indicating that a proposal has been funded.

• Notice of grant awards are typically received by the Office of Research Services [Pre-award offices], although on occasion a PI may be notified directly.



What is Contained in a Notice of Award

• PI Name• Dates of Performance

– Current budget period– Total project period

• Dollars– Direct, F&A– Current, project total

• Cost Sharing• Contact information

• General & Special T&C

– Use of Animals/Human Subjects

– Use of Interest Income– Use of Program Income

• Reporting requirements– Programmatic– Financial– Property– Invention



Review and Negotiation• ORS Pre-Award and Corporate Contracts staff review

sponsor terms and conditions for compliance with University Policy.

• Non-standard terms may require negotiation or other measures to harmonize with University Policy.

• Selected examples:– Intellectual Property and Tangible Research Policy– Publication– Financial Reporting Requirements– Governing Law– F&A rate (See SPP 2116 Recovery of F&A Costs)

http://www.finance.upenn.edu/vpfinance/fpm/2100/2100_pdf/2116.pdf



Review and NegotiationConsiderations Specific to Corporate Contracts:Expectations of corporate sponsors different from

expectations of public sector sponsors:

Ownership of data and other intellectual output; Confidentiality of work for which sponsor is paying; Control over publication of research; Responsibility/liability for harm that may arise from

research or use of research output’ For clinical trials, rapid, frequently competitive, activation

of protocols.



Review and Negotiation Considerations Specific to Corporate Contracts: Internal Review Process Adapted to Accommodate Projects

Funded by Corporate Sponsors:

Agreements to be forwarded to Corporate Contracts for negotiation as soon as sponsor is willing to negotiate/final budget; IRB/IACUC submission not required;

Only items necessary for negotiation need to be forwarded; See eform in Internal Documents in Penn ERA for step-by-step

instructions for this parallel review process.



Award example - NIHNOA Section I:• Award Data & Fiscal Information

– Summary of totals for current and future years– Fiscal year of award– Indicates whether an unobligated balance has been

applied to the award amount

NOA Section II:– Grant Payment Information– OIG Hotline Information



Award example - NIHNOA Section III: Standard Terms & Conditions• Grant program legislation and regulations• Restrictions on the expenditure of funds in appropriation acts• 45 CFR 74 or 92 as applicable• NIH Grants Policy Statement• Carryover—automatic or prior approval• Included/excluded from Streamlined Noncompeting Award

Process (SNAP)• FDP Institutions noted• FFATA/ARRA • Program Income



Award example - NIH• NOA Section IV: Specific Terms and Conditions

– Revisions– Cooperative Agreement– Restrictive terms– Information items– Staff Contact Information– Spreadsheet Summary



Exercise• What is the name of the sponsor?• What is the name of Penn’s PI?• Is your award a grant or contract?• Is your award cost-reimbursable or fixed-price per

patient?• What is the first year budget period?• What is the entire project period?• What is the dollar amount obligated under this award?• Are there any subcontracts? • Will PHS-FITS be required?• Bonus: identify 1 or more specific term and condition.



Award Example - Foundation• Award layout varies by sponsor

• NOA often references terms and conditions not explicitly named



Exercise• What is the name of the sponsor?• What is the name of Penn’s PI?• Is your award a grant or contract?• Is your award cost-reimbursable or fixed-price per

patient?• What is the first year budget period?• What is the entire project period?• What is the dollar amount obligated under this award?• Are there any subcontracts? • Will PHS-FITS be required?• Bonus: identify 1 or more specific term and condition.



Account Set-Up



Account Set-Up - WorkflowNotice of Award

(NOA)Received and

Negotiation completeFCOI Compliance verified

Fund AttributesFund Parents

Special BudgetsAccount Segments

Assigned in PennERA & Sent to GL

Fund & Legacy Number Created

in BEN Financials & Sentto PennERA

AIS is GeneratedAward Notice Uploaded

in PennERA

Status Changed To AwardFrom Pending, FuturePending, Advance Account,or Account Continuation10 Business Days



Workflow• Electronic process for imaging awards and updating

PennERA– Applies to changes to records that result in AIS

• Several steps and roles– Document enters imaging system– Package created and assigned to AD/CA for handling– AD/CA creates account setup summary for package and

sends to Operations– Operations updates award, adds package to PennERA

• Hurdles:– Is PHS-FITS necessary? Is it complete?– Is there a Non-Competing Continuation on file?– Is there inconsistency between the package and record?– Is there a Cost-Share form to be signed?



Funds and Accounts• New Funds are created for each year of the award when

carryover of money from one year to the next must be approved by the Sponsor

• New funds are also required when the F&A changes from one segment to another

• New funds may be required if the funding mechanism changes at the sponsor

• Subaccounts are to be requested on the subaccount worksheet



Receiving the Award and the Account Information

Sheet (AIS)

AIS is issued online. NOAs are uploaded in the Attachments tab

in PennERA as part of Workflow.For help: [email protected]



Review the Award• AIS is not a substitute for award• PI is responsible for all terms• Review terms and conditions of award• Sponsor guidelines• Restrictions• Scientific reporting specifications



Review the AIS• Ensure Account End Dates Accurate (budget end or

project end?)• Ensure Award on AIS matches Award on NOGA• Ensure FDP and/or SNAP• Ensure accuracy of F&A rate• Ensure proper PI name and Org#• If the AIS is for a continuation year, always check

for budget periods funded with prior unobligated funds.

• If errors occur, email [email protected]



Advance Accounts• What is an Advance Account?

– Use when high probability of award– Allows you to put charges on proper account

• Avoid journal entries and payroll reallocations– Use with pre-award costs under expanded authorities– Easy to request

• ORS Web page has link to Advance Account Request– http://www.upenn.edu/researchservices/pdfs/advance.pdf– PSOM-Advance Accounts are approved and setup by ORSS– All other schools - forward request to ORS Pre-Award

http://www.upenn.edu/researchservices/pdfs/advance.pdf



Advance Accounts (cont.)• Risks

– Award may not materialize – Start date may be delayed – Not all sponsors allow “Pre-award”

expenditures• Establish follow-up routine

– Has award materialized?– Is something holding it up?– 3 month limit on advance accounts



Subaward Process• BA/PI prepares subaward request form

http://www.upenn.edu/researchservices/subawards.html Complete package sent as pdf email to [email protected]

• ORS completes subrecipient monitoring, prepares subaward & sends to subrecipient– Subrecipient signs & returns

• ORS sends email notification to BA that the subaward is fully executed– Signed agreement uploaded to PennERA record

• BA sets up Purchase Order• Subaward activity from request to execution noted in PennERA record activity log.

http://www.upenn.edu/researchservices/subawards.html



Subrecipient Monitoring• A-133 report or audited financial

statements required annually

• Current F&A rate agreement

• Risk Assessment – results indicate appropriate subcontract terms and conditions



Questions???

sponsored programs at penn proposal budget preparation, budgeting using pennera and routing &...

Documents

office of research services

research coordinator

budget planning

significant budget changes

scope of work

direct costs

usual award document

sponsor guidelinesinstructions