PI Quiz

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:

1. An authorized institutional representative (AOR) signature
2. A detailed budget
3. 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.

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.

True.

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.

Impact:

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.

Find out if your research now meets the new definition of a clinical trial by checking out the decision tree found on the NIH Clinical Trials web page.

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.

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.

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.

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.

Explanation:

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).

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.

See: NIH Research Performance Progress Report (RPPR)

True.

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.

C. A pre-existing piece of equipment in PI Smith’s lab.

Existing equipment cannot be used as cost sharing.

Explanation:

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.

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.”

True.

Source: NIH Other Support

Explanation:

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.

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.

Explanation:

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

• 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?
  Answer: 57%
• 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?
  Answer: 22%

Explanation:

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.

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.

Source: Council on Governmental Relations F and A Frequently Asked Questions