Understanding the Life Cycle of an Award, part II

1. Understanding the Life Cycle of an Award, part II Presented at the NSPAA 18th Conference Charleston, South Carolina June 6, 2013 by Ms. Patricia GibbS Elizabeth City State University Mrs. Gwendolyn Mitchell Ulmer South Carolina State University Dr. Mildred Huff Ofosu Morgan State University

2. AGENDA • Overview • Startup • Negotiation • Grants Management • Reporting and Close-Out • Discussion • Q&A

3. Start Up & negotiation Patricia Gibbs Elizabeth City State university

4. Congratulations on your new award!!! Now what should you do? • First, review your sponsor requirements and make a note of special terms and conditions • Be sure to review information with the post award staff for clarification • Participate in the post-award orientation  meeting with Sponsored Programs, Business and Finance and other relevant administrative units • Obtain assigned account number and review budget set up with Business and Finance staff • Spend funds according to approved agency budget • Document goal/objective progress throughout the performance period • Adhere to all agency and university required reporting requirements

5. Implementation of Award Continued… • Work with the Office of Sponsored Programs to resolve programmatic issues during implementation • Work with the Office of Business and Finance to resolve financial issues during implementation • Seek prior approval from the funding agency before making major changes to the scope of the project or budget • Prepare to close out grant 90 days prior to the end of project or whatever time frame is listed in the award conditions • Review project progress to determine if additional time is needed • Submit close-out reports according to agency guidelines • Retain the file for the appropriate time noted in award terms and conditions

6. Award Negotiation • The agency/sponsor negotiator is your partner not the enemy. • You should work together with the sponsor to reach a mutual agreement . • Remember to review your University’s policy, state laws, and federal regulations before you begin negotiation. • Keep the PI aware of the process, but not directly involved in the negotiation • Determine what the university’s (must haves) are for acceptance. • What are the relationships you need to consider? (PI, university, federal or private sponsor) • What resources are available at the institution for which sets of issues (Legal Affairs, Compliance, Technology Transfer, etc.)? • Are Federal funds involved, either as the sponsor of the research or within the Lab where the research will occur? • Are there other sources of funding -- state or Private Foundation?

7. Contract Issues: The Problem Areas • Export controls/access: Is the material really export controlled? Access and publication restrictions may void fundamental research exemption • Intellectual Property (data ownership, rights/license options) • Confidentiality: How are confidential materials defined? Do they include your institution’s information? Who decides what is to be kept confidential? For what period of time? What cannot be considered confidential? • Indemnification: What limits does your institution require; is yours a state institution? Is the clause reasonable for the level of risk involved? (hint: consider any potential uses permitted by the sponsor for developed IP) • Technical direction: Who controls changes to the scope of work? Are these changes limited to changes within the scope of work? What parameters are permitted at your institution?

8. Contract Issues: Other Problem Areas • Termination • Billing/payment • Financial and technical reporting • Jurisdiction/State laws • Disputes • Audit and retention of records

9. Conducting the Negotiation • Public Institutions have less negotiating room than private. • Likewise, private foundations have more negotiating room than federal or state sponsors. • If responding to their RFP or RFQ, provide an exceptions letter noting areas of concern and stressing willingness to discuss issues of “mutual interest .” • Remember that the counterpart negotiator is your partner not the enemy. • Know who the right contacts are – for technical and administrative / business purposes. • Emails may be impersonal. There is no substitute for verbal communication to resolve hardest issues or work out contracts where just a few issues exist. • Be creative, diplomatic, knowledgeable, firm and persuasive -- but always open.

10. NEGOTIATION: REMINDERS • Explain who you are. • Be up-front and honest. • Work to develop trust. • Be patient but persistent. • Document conversation. • Use the telephone and e-mail carefully. • Do not rush or be rushed into decisions. • Know when to fold ‘em.

11. Grants Management Gwendolyn Mitchell UlmeR South Carolina State University

12. Grant Management • The Award Document • Post Award Conference • Project Set-up • Expanded Authority • Prior Approvals • Time and Effort Certification • Compliance

13. Grants Management • The Award Document • Review Terms and Condition • Special Terms and Conditions • A-21 – Cost Principles for Educational Institutions (Relocated to 2 CFR Part 220) • A-110 Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and Other Nonprofit Organizations (Relocated to 2 CFR Part 215) • A-133 Audits of Institutions of Higher Education and Other Nonprofit Institutions (Not Yet Codified) • Post Award Conference • The purpose of the Post Award Conference is to review the terms and conditions, policies and procedures of the award with regards to grant management to include reporting requirements, fiscal requirements, compliance requirements and other relevant information that is necessary for the Principal Investigator to successfully manage the grant award.

14. Grants Management • Project Set-up • Enter Award information into Database • Set-up Information into Financial System • Expanded Authority The Federal Government’s Office of Management and Budget(OMB) reduced the number of prior approval in order to streamline the Grant Management process through the use of Expanded Authority. URL: www.whitehouse.gov/omb/circulars/index-education.html.

15. Grants Management • Prior Approvals • No Cost Extension • Change in Principal Investigator(PI) • Change in PI Status • Change in Scope of Work (SOW)/Objective • Change in Effort/PI Leave of Absence

16. Grants Management • Re-budgeting • Personnel Cost • Participant Support/Trainee Cost • Cost Transfer • Sub-Awards • Vendor Vs. Consultant

17. Grants Management • Compliance • Time and Effort Certification 2 CFR Part 220 (OMB Circular A-21 section J.10) • Human Subject/Institutional Review Board http://www.hhs.gov/ohrp/humansubjects/guidance/45cfr46.html • Export Control http://www.bis.doc.gov/policiesandregulations/ear/

18. Grants Management Effective Grants Management: • Set-Up the Project • Perform the Work • Monitor the Project • Manage the Funds • Close-Out the Project

19. Reporting & close out Dr. Mildred Huff Ofosu Morgan State University

20. NIH Reporting Requirements • Financial report • Progress report • Other required reports • Annual invention utilization • Lobbying disclosures • Conflict of interest • Audit reports • Specialized programmatic reports • (Publication of results in peer-reviewed journals)

21. Official receipt point for most required reports • (1)The Grants Management Office (GMO) –for most required reports • (2) eRA Commons for Streamlined Noncompeting Award Process (SNAP) • Use SNAP for noncompeting awards and Fellowships • Federal Financial Reports (FFRs) must be electronically submitted annually to OFM through eRA Commons eFFR feature • FFRs must be submitted not later that 90 days after the end of the calendar quarter. • PAPER EXPENDITURE REPORTS ARE NOT ACCEPTED for FFRs.

22. A Non-Competing Continuation Progress Reports • Research Performance Progress Report (RPPR)* • For each additional budget period within a previously approved project period • Updated budget (exception SNAP) • All personnel reports • *A federal wide format for the submission of required annual or other interim RPRR will replace eSNAP and PHS 416-9 performance reporting on grant and cooperative agreement awards during FY 2013

23. Modified Annual Progress Reports (eSNAP) • A streamlined version of the annual progress report requirements; is due the 15th of the month preceding the month in which the budget period ends. • What is not needed: IRB, IACUC, detailed budget information • Answers to following questions are required? • Has there been a change in the other support of senior/key personnel since the last reporting period? • Will there be, a significant change in the level of effort in the next budget period? • Is it anticipated that an estimated unobligated balance will be greater than 25% of current year’s total approved budget?

24. Modified Financial Reporting Requirements • FFR required only at end of a competitive segment rather than annually • A New Form SF425 – called the Federal Financial Report (FRR) is used for collecting financial data. • FFR must be submitted within 90 days after end of the competitive segment • Must report on the cumulative support awarded for entire segment • Grantees are also required to submit quarterly FFR cash transaction data to PMS

25. Financial Reports • Two types are typically used: • Cash transaction data-submitted directly to PMS, quarterly • Expenditure data is submitted directly to NIH • The SF425 – called the Federal Financial Report (FRR) is used for collecting both types of financial data. (Note: SF272 and SF269 forms are no longer accepted) • Quarterly reports are due 30 days following the end of each calendar quarter Note: Quarterly reports are not required for awards issued to foreign institutions after Oct. 1, 2012.

26. Closeout Documents • Final Grant Progress Reports • Final Invention Statement and Certifications • Financial Status Reports (These must be submitted within 90 calendar days at the end of the grant support) • Failure to submit timely and accurate closeout documents may affect future funding to the organization

27. Invention Reporting • Contractor may retain the entire right, title, and interest throughout the world to each subject invention • The contractor will disclose each subject invention to the Federal Agency within two months after the inventor discloses it in writing to contractor personnel responsible for patent matters. The disclosure to the agency shall be in the form of a written report and shall identify the contract under which the invention was made and the inventor(s).

28. Record Retention and Access • Retain financial and programmatic records, supporting documents, statistical records and all other records that are required by the terms of a grant for a three years from the date the annual FFR is submitted. • For awards under SNAP, retain for 3 years from the date the FFR for the entire competitive segment is submitted • Foreign institutions and foreign agencies must retain records fro 3 years from date of submission of annual FFR to NIH

29. Audit • Audit is a systematic review or appraisal made to determine whether internal accounting and other control systems provide reasonable assurance of the following: • Financial operations are properly conducted • Financial reports are timely, fair, and accurately • The entity has compiled with applicable laws, regulations and other grant terms • Resources are managed and used economically and efficiently • Desired results and objectives are being achieved effectively

30. NASA – Reporting Requirements • Two types of technical reports are required: • Annual Progress Report • Submit a brief progress report to Prog. Officer 60 days before the anniversary date of award • SF425 is due at end of each Federal fiscal quarter • Summary of Research • Submit to the NASA Awards Officer and Technical Officer at completion of period of performance • Include substantive results, references to all published materials • Due within 90 days after the end of the award Other Reports:Financial, property, Invention, other specialized reports for certain types of grants( ex. Education); export controlled data cannot be disclosed in the public domain

31. NSF – Reporting Requirements • Research Performance Progress Report (RPRR), a new reporting format for research and research-related projects • On March 18, 2013, NSF transitioned all project reporting from FastLane to Research.gov • All annual, interim project reports and the Project Outcomes Reports must be submitted through Research.gov • Use your FastLane user ID and password to login to Research.gov • Can view information on the new Project Report Dashboard

32. Project Outcomes Report • Is prepared by the PI for the general public that provides insight into the outcomes of NSF-funded research • Is a required report for all funded projects funded on or after January 4, 2010 • Both research outcomes and citations of published documents resulting from research funded by NSF must be made available to the public • Go to Research.gov - Research Spending & Results - to review outcome reports

33. Contact Information: • Patricia Gibbs • Director of Sponsored Programs • Elizabeth City State University • Elizabeth City, North Carolina • pjgibbs@mail.ecsu.edu • 252.335.3250 • Gwendolyn Mitchell Ulmer • Interim Director of Post Award Administration/Grants Administrator • South Carolina State University • Orangeburg, SC • gmitche3@scsu.edu • 803.536.8212 • Mildred Huff Ofosu • Assistant Vice President of Sponsored ProgramsMorgan State University Baltimore, MD 21251mildred.ofosu@morgan.edu443.885.4505