Test your research administration knowledge! Congratulations if you know all the answers. If not, the questions below may help both principal investigators and research administrators learn a little more about sponsored projects.
All pre-proposals must be reviewed by SPO/IAO before submission to the sponsor. True or False?
The only pre-proposals that must be reviewed by SPO/IAO before submission to the sponsor are those that require/include any of the following:
- An authorized institutional representative (AOR) signature
- A detailed budget
- Cost sharing
Explanation: Only the Sponsored Projects Office (SPO) or the Industry Alliances Office (IAO) are authorized to sign for the University when an Authorized Organizational Representative (AOR) signature is required. Submission of a detailed budget based on specific cost rates and/or a commitment to provide cost sharing at the pre-proposal stage may constrain the Principal Investigator (PI) if these costs or rates need to be changed at the full proposal stage.
When a contractor/vendor is listed by name in the proposal, it is not necessary to go out for bid after an award is set up. True or False?
Even if a contractor/vendor is named in a funded proposal, requests submitted to Supply Chain Management (SCM) that are equal to or exceed $100,000 per year will need to be competitively bid.
Explanation: The Sponsored Projects Office (SPO) and the Industry Alliances Office (IAO) issue subagreements to outside organizations that are collaborating on Berkeley sponsored projects. Typically, when a subrecipient is listed in a proposal by name, prior sponsor approval of the subrecipient is not required at the award stage (unless the sponsor requires this extra step).
However, purchases from contractors (vendors) are handled by Supply Chain Management and the California Public Contract Code (PCC) requires UC to competitively bid the purchase of goods and/or services that exceed $100,000 per annual year.
For more information on this requirement see Supply Chain Management Competitive Bidding.
The National Institutes of Health definition of a “clinical trial” now includes fundamental and basic health-related research. True or False?
In spring/summer 2017, NIH issued a notice that provided a number of case studies designed to clarify NIH’s definition of a clinical trial. These case studies included examples of research that previously would have been considered basic or fundamental health-related research. Although the Council on Government Relations (COGR), the Association of American Medical Colleges (AAMC), the Association of American Universities (AAU), and the Association of Public and Land-Grant Universities (APLU) have all expressed concern about the expansion of the definition of a clinical trial, NIH has not changed its position.
After January 25, 2018, research that meets the new definition of a clinical trial will need to be submitted through a Funding Opportunity Announcement (FOA) specifically designed for clinical trials. This means that the NIH will no longer accept clinical trial applications through “parent” FOA announcements or through other FOAs that are not specifically designed to accept clinical trials.
If your research fits the definition of a clinical trial, check the online version of your Funding Opportunity Announcement (FOA) as soon as possible to see if it is still appropriate for your application.
- All FOAs will specify the allowability of clinical trials in Section II.
- Award Information All clinical trial FOAs will specify allowability of clinical trials in the FOA title.
Note: FOAs that accept clinical trials also will incorporate specific review criteria including the significance of the proposed work; the expertise and experience of the personnel; whether the research plan includes innovative elements; the approach in terms of study design and data management and statistical analysis; whether the environment is appropriate for conducting the proposed research; and the study timeline.
When is the F&A (Facilities and Administrative or indirect costs) recovered on a grant awarded to UC Berkeley?
- It is taken off the top at the beginning of the award to make sure the University gets paid.
- It is recovered at the end to make sure the principal investigator (PI) has enough funds to carry out the project.
- A quarter of the F&A that was budgeted is recovered every three months regardless of the amount of project expenditures.
- None of these.
D. None of these.
F&A is recovered as the PI spends his/her project funds. For example, if the F&A rate is 57%, for every dollar the PI spends, the University will recover $.57. Therefore, if the PI underspends, i.e., spends less than budgeted for the project, less F&A will be recovered to support the facility and administrative costs of the University.
A Principal Investigator named in a National Institutes of Health Notice of Award reduces her NIH approved level of effort in Year 1 by 10%. In Year 2, she reduces her level of effort by another 20%. She does not need prior approval from NIH for either of these reductions in effort because each reduction is less than 25% of the level that was approved at the time of her initial competing year award. True or False?
Prior NIH approval is required if the Project Director/Principal Investigator or other Senior/Key Personnel specifically named in an NIH Notice of Award withdraws from the project entirely, is absent from the project during any continuous period of 3 months or more, or reduces the time devoted to the project by 25 percent or more from the level that was approved at the time of initial competing year award.
Reductions are cumulative, i.e., the 25% threshold may be reached by two or more successive reductions that total 25% or more. Once agency approval has been given for a significant change in the level of effort, then all subsequent reductions are measured against the previously approved adjusted level. For additional guidance on how to determine when prior approval is required by NIH see Reduction in PI/Co-PI Effort.
Which of the following is not allowed on a federally funded project?
- Charges for clerical personnel time
- Charges for a laptop used by two separate projects.
- A fixed price subaward of $250K.
- Subrecipients without a negotiated F&A rate.
C. A fixed price subaward of $250K.
Under the Uniform Guidance (200.332), the total maximum value of each fixed price/rate subaward is capped at $150,000, and agency prior approval is required to enter into a fixed price/rate subaward.
Clerical Personnel Costs: Under the Uniform Guidance (200.413) these costs now can be included as part of the proposal budget and charged to the federal award if the staff member’s services are integral to the project. At Berkeley, the staff member should be devoting significant (e.g. 10%) effort to the project.
Laptops: Under the Uniform Guidance (200.453) computing devices under $5,000, which are classified as materials and supplies (not equipment), now may be included as a direct cost in the proposal budget if the devices will be essential and allocable, but not necessarily solely dedicated, to the performance of the award.
Subrecipients without a negotiated F&A rate: Subrecipients that have never received a negotiated indirect cost rate may elect to charge a de minimis rate of 10 percent of modified total direct costs, which may be used indefinitely. See Uniform Guidance Sections 200.331(a)(xiii) and 200.414(f).
If a PI has submitted a competing renewal (Type 2) application to NIH, an Interim Research Performance Progress Report (Interim-RPPR) is not required while their renewal application is under consideration. True or False?
The PI must still submit an Interim-RPPR no later than 120 calendar days from the period of performance end date. If the competing renewal (Type 2) application is funded, NIH will treat the Interim-RPPR as the annual performance report for the final year of the previous competitive segment.
If the competing renewal (Type 2) application is not funded, NIH will treat the Interim-RPPR as the institution’s Final-RPPR. To reduce burden, NIH will not require recipients to submit an additional Final-RPPR if the renewal application is not funded.
If UC Berkeley is a subrecipient of federal funds and a State of California agency is a pass-through entity, as defined in the Uniform Guidance (2 CFR 200.93 and 2 CFR 200.74), then UC Berkeley should budget and receive its federally negotiated indirect cost rate for the project. True or False?
However, the Facilities and Administrative (F&A) recovery rate for projects supported by State of California funding has been established by the UC Office of the President (UCOP) and includes a series of rates which increase incrementally over 4.5 years from 25% to 40%. These rates are applied to a Modified Total Direct Cost (MTDC) base (as defined in each UC campus’ federally negotiated rate agreement). For the current rate schedule, see State of California Proposal Guidance.
PI Smith plans to submit a research proposal to a federal sponsor that pays the University’s negotiated F&A rate for research. This particular grant competition requires 25% cost sharing. Which of the following sources of cost sharing would never be an acceptable way to meet this cost sharing requirement?
- Cost sharing from one of PI Smith’s non-federal awards.
- Donated volunteer services from a third party.
- A pre-existing piece of equipment in PI Smith’s lab.
- Answers (A) and (C) are not acceptable cost sharing.
C. A pre-existing piece of equipment in PI Smith’s lab.
Existing equipment cannot be used as cost sharing.
The sponsor is already paying for a portion of this equipment as part of the University’s F&A, and to be used as cost sharing a piece of equipment must be “purchased” during the project period, not before or after. Although not appropriate for cost sharing, such equipment can be described in the proposal under facilities/resources as available to the PI for carrying out the project.
Answer (A) is not correct because the PI may utilize funds from non-federal awards as the source of cost sharing on federal awards when specifically allowed by both the non-federal and federal sponsor.
Answer (B) is not correct because donated volunteer services from a third party are allowable as long as the value of these services can be substantiated and documented for cost sharing reporting purposes.
Prof. La Croix purchased 100 gift cards worth $5.00 each with his NIH grant funds. The gift cards were to be given as human subject payments to adult female participants involved in his study of the effect of chocolate on the brain. His NIH grant terminated two years ago, and there are 50 gift cards remaining.
What should Prof. La Croix do with these gift cards?
- Even though the project is closed out, Prof. La Croix should work with Contracts and Grants Accounting (CGA) to transfer the cost of the gift cards off of the closed NIH award to a discretionary fund so that CGA can issue a refund to NIH.
- Since gift cards are considered “supplies”, according to §200.314 of the Uniform Guidance, title to the cards rests with the University after acquisition, and Prof. La Croix can now do with the cards as he sees fit as long as it is for NIH approved purposes.
- Since the gift cards were purchased with NIH funds, PI La Croix can now use the remaining gift cards for human subject payments to female participants involved in his current NIH study on the negative effects of chocolate addiction.
A. Even though the project is closed out, Prof. La Croix should work with Contracts and Grants Accounting (CGA) to transfer the cost of the gift cards off of the closed NIH award to a discretionary fund so that CGA can issue a refund to NIH.
According to the Human Subject Payment Guidelines on the UC Berkeley Controller’s website, “purchasing non-returnable gift cards is discouraged; however, if gift cards are the payment method used, the contract/grant must be reimbursed for any undisbursed gift cards.”
Information on “Other Support” is required in NIH and other PHS agency Research Performance Progress Reports (RPPRs) for all senior/key personnel, excluding consultants, when there has been a change in active other support. Other Support is not required in progress reports for Program Directors, training faculty, and other individuals involved in the oversight of training grants. True or False?
Source: NIH Other Support
Recipients of NIH and other PHS Agency funds are responsible for submitting complete and accurate progress reports. Failure to accurately report changes in “other support” has resulted in delays and reduction in funding support based on NIH staff evaluation and identification of scientific overlap in funding sources.
Which of the following is true for research and research-related grants made by the Federal awarding agencies:
- When the grant ends, the non-Federal entity must submit, no later than 90 calendar days after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award. The Federal awarding agency or pass-through entity may approve extensions when requested by the non-Federal entity.
- When the grant ends, the non-Federal entity must submit, no later than 120 calendar days after the end date of the period of performance, all financial, performance, and other reports required by the terms and conditions of the Federal award. The Federal awarding agency or pass-through entity may approve extensions when requested by the non-Federal entity.
- When the grant ends, the non-Federal entity must submit all required financial, performance, and other reports according to agency specific reporting requirements found in the award even if the award is subject to Uniform Guidance and RTC reporting conditions.
C. When the grant ends, the non-Federal entity must submit all required financial, performance, and other reports according to agency specific reporting requirements found in the award even if the award is subject to Uniform Guidance and RTC reporting conditions.
Under Section §200.343 of the Uniform Guidance (Closeout) required reports must be submitted no later than 90 days after the end date of the project period of performance. However, federal agencies do not always behave in a “uniform” manner.
When “Research Terms and Conditions” (RTC) apply, all required financial, performance, and other reports under the terms and conditions of the Federal award typically must be submitted no later than 120 calendar days after the end date of the period of performance.
However, a federal agency—even one that is subject to the Uniform Guidance and participates in RTC—may have agency specific reporting requirements, and these reporting requirements always supersede both the Uniform Guidance and RTC reporting guidelines.
It is therefore important to read the terms and conditions of each award carefully in addition to SPO’s Proposal Award Summary (PAS) to find out if there are any agency specific reporting requirements to be addressed. Remember, delinquent reports can result in:
- Delay of review and processing of PI’s pending proposals
- Delay of processing of additional funding and administrative actions, e.g. no cost extensions for all identified PIs and co-PIs on a given award
- Unilateral closeout of an active grant
- Withholding support for the institution’s other active awards
- Placing the PI’s institution in a debt status to the U.S. government
Fill in the blanks:
- What percentage of direct cost expenditures most closely reflects is the actual overhead (F&A) costs of conducting organized research on campus? ___%
- What is the University’s current negotiated overhead (F&A) rate for organized research on campus? ___%
- What is the University’s effective overhead (F&A) rate of recovery, i.e., the percentage of direct cost expenditures that is actually generated as F&A? ___%
- What percentage of direct cost expenditures most closely reflects is the actual overhead (F&A) costs of conducting organized research on campus?
Answer: Over 70%
- What is the University’s current negotiated overhead (F&A) rate for organized research on campus?
- What is the University’s effective overhead (F&A) rate of recovery, i.e., the percentage of direct cost expenditures that is actually generated as F&A?
The Facilities and Administrative (F&A) rate proposal submitted by the University to the federal Department of Health and Human Services, UC Berkeley’s cognizant agency, includes all appropriate University facilities and administrative costs. However, the federal government caps what the University can recover for its administrative costs to 26%, even though UC Berkeley’s administrative costs (like our peer institutions) are higher.
The effective rate is lower because not all grants generate full overhead (F&A). Also, federal grants exclude certain costs (e.g. equipment) from overhead calculations.The difference between what it really costs to conduct organized research at UC Berkeley and what is actually recovered by the University is a pain point and a concern for all who are interested in adequately supporting University research.
Under a federal award, if the subrecipient gets to charge its full F&A costs and the University then collects F&A on the first $25K of the subaward, this is double dipping. True or False?
There is no double-dipping since two institutions are involved in the research and both incur administrative costs. The subrecipient is reimbursed for its full F&A costs since the work is performed on its premises. The University also incurs F&A costs in administering the agreement with the subawardee, i.e. executing the agreement, monitoring expenses, processing invoices, making payments, reporting to the prime sponsor, etc. Paying F&A costs only on the first $25k of the subaward is the government’s way of recognizing that subawards incur less administrative costs than on-campus projects.