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National Science Foundation

National Science Foundation. Annual Training Presented by Lisa Wilson Director, Office of Sponsored Programs Presented by: Doris Nyaga Pre-Awards Coordinator Presented by: Joyce Y. Johnson Post-Awards Coordinator. AGENDA NSF Policies and Procedures.

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National Science Foundation

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  1. National Science Foundation Annual Training Presented by Lisa Wilson Director, Office of Sponsored Programs Presented by: Doris Nyaga Pre-Awards Coordinator Presented by: Joyce Y. Johnson Post-Awards Coordinator Office of Sponsored Programs

  2. AGENDANSF Policies and Procedures Pre-Awards – Doris Nyaga (proposals) Post – Awards – Joyce Johnson (awards) IT Specialist – Won Eason (communications) OSP Director – Lisa Wilson (risks and new systems) Improve systems, increase productivity, effectiveness,, and maximize award recovery of research administration. Stay out of the Gray! Because we don’t look good in orange jumpsuits! Office of Sponsored Programs

  3. The Regulatory EnvironmentFederal, State, Private, BOR, FVSU, OSPLaws, Rules, Regulations, Policies and Procedures Office of Sponsored Programs

  4. U.S. Department of Justice WASHINGTON, D.C. — Northwestern University will pay the United States $5.5 million to settle allegations that the school violated the False Claims Act with regard to claims in connection with federally-sponsored medical research grants, the Justice Department announced today. The government alleged that Northwestern misled the United States into paying more money than the Chicago-area school was lawfully entitled to receive. http://www.usdoj.gov/opa/pr/2003/February/03_civ_076.htm Office of Sponsored Programs

  5. Why Should You Care About Compliance? University of MinnesotaMisuse of federal funds $32 million Northwestern University Committed Time and Effort $5 million Yale University Cost Transfers/Salary Charges $7.6 million New York University Medical CenterInflated Research Grant Costs$15.5 million Florida International UniversityEffort Certification & Direct Cost Disallowances$11.5 million Harvard/BIDMC Costing Issues $3.25 million Johns Hopkins University Effort Certifications$15.5 million East Carolina University Questioned Costs HHS/OIG Audit $2.4 million University of Alabama BirminghamEffort Certification & Clinical Research Billing $3.4 million Duke University Administrative and Clerical Expenses on Awards $1.7 million 5 Office of Sponsored Programs Office of Sponsored Programs

  6. NSF Policy Updates Compliance Workforce Growth - A November 9 article in The Hill addresses the recent growth in Federal Regulations associated with compliance. While the article focuses on the growth of business employment in this area, the same is true for non-profits and education. GRC’s Efficiency and Compliance Taskforce, led by Sandra George (georges@aascu.org) is attempting to address the associated issues that results from this recent expansion of regulation. GRC has also instituted a partnership with the Association of University Technology Managers (AUTM) to share resources with members related to compliance as well as technology transfer. Also, keep checking the GRC Sample Policies Library as we continue to expand its contents and add agency specific A new version of the NSF Proposal & Award Policies & Procedures Guide (PAPPG), (NSF 14-1) has been issued.  The PAPPG is comprised of documents relating to the Foundation's proposal and award process and consists of the: (a) Grant Proposal Guide (GPG) for guidance on the preparation and submission of proposals to NSF; and (b) Award & Administration Guide (AAG) to guide, manage, and monitor the award and administration of grants and cooperative agreements made by the Foundation. This new version of the PAPPG will be effective for proposalssubmitted,or due, on or after February 24, 2014 Office of Sponsored Programs

  7. Components of an Effective Compliance Program NIH OIG issued a notice in the Federal Register regarding the elements considered necessary for a comprehensive compliance program. (68 FR52783-52784 September 5, 2003) Conduct internal monitoring and auditing Enforce standards through well publicized disciplinary guidelines Respond promptly to detected problems, taking corrective action, and report to Federal agencies Define roles responsibilities – oversight responsibility • Implement written policies and procedures • Designate a compliance officer and committee • Conduct effective training and education • Develop effective lines of communication Office of Sponsored Programs

  8. Pre Awards Doris Nyaga Office of Sponsored Programs

  9. The Sponsored Program Lifecycle 9 Office of Sponsored Programs Office of Sponsored Programs

  10. FDP Demonstration • Several school are participating in an FDP demonstration • Ongoing FDP PR Certification demonstration should be expanded. • A-21 audit standards during demonstration have been suspended • Goal: extend demonstration and if successful have OMB provide clearance to transition away from ER Office of Sponsored Programs

  11. Post Awards Joyce Johnson Office of Sponsored Programs

  12. PROPOSAL AWARD POLICIES PROCEDURES GUIDEhttp://www.nsf.gov/publications/pub_summ.jsp?ods_key=papp Award Administration Guide Summary of Changes NSF 13-1 January 2013 Significant Changes to the AAG • Chapter II.F. Records Retention and Audit, has been supplemented with a new paragraph that specifies that awards issued by the National Science Foundation (NSF) meet the definition of "Research and Development" at OMB Circular A-133 §.105. As such, auditees should identify NSF awards as part of the R&D cluster on the Schedule of Expenditures of Federal Awards (SEFA). • Chapter III, Financial Requirements and Payments, has been revised to implement, during FY 2013, the Award Cash Management $ervice (ACM$). ACM$ will replace the current FastLane Cash Request service and end the cash pooling method of award payments. Under ACM$, awardees will submit award level detail with each payment request. Office of Sponsored Programs

  13. Chapter V.D, Indirect Costs, has been revised to clarify NSF’s policy on indirect cost recovery. Except as noted in AAG V.B.8 and VI.G.5, or in an NSF program solicitation, the applicable indirect cost rate(s) negotiated by the organization with the cognizant negotiating agency must be used in computing indirect costs (F&A) for a proposal. A statement also has been added that foreign grantees are not eligible for indirect cost rate recovery unless the foreign grantee has a previously negotiated rate agreement with a U.S. Federal agency that has a practice of negotiating rates with foreign entities. • Clarifications and Other Changes to the AAG • Chapter II.E, Technical Reporting Requirements, has been updated to state that project reports must contain information on all activities of the project, including any activities to address the broader impacts criterion that are not intrinsic to the research. • Chapter IV.A, Conflict of Interest Policies, has been modified to specify that, when the Office of the General Counsel (OGC) is notified of an unmanageable conflict of interest (COI) via FastLane, OGC will contact the institution making the report, obtain a copy of that institution’s policy, and follow up with the institution regarding what actions the institution will take with respect to the reported COI. • Chapter V.B.8, Participant Support Costs, has been augmented with language explaining that an allowance for indirect costs associated with participant support costs may be established or negotiated in advance when circumstances indicate that the grantee could be expected to incur significant expenses in administering participant payments (moved from Indirect Costs). • Chapter VI.B, Protection of Living Organisms, has been supplemented with additional guidance in Section 4, Vertebrate Animals, which addresses wildlife research. Office of Sponsored Programs

  14. Basic Considerations Expenditures under NSF cost reimbursement grants are governed by the Federal cost principles and must conform with NSF policies, grant special provisions and grantee internal policies. Grantees should ensure that costs claimed under NSF grants are necessary, reasonable, allocable, and allowable under the applicable cost principles, NSF policy, and/or the program solicitation. In the event a grantee anticipates charging an item of direct cost that might subsequently be disputed, an authorized official of the grantee organization should discuss the matter with the cognizant NSF Grants and Agreements Officer and document the conditions or factors surrounding the item in order to avoid possible subsequent disallowance. Chapter V - Allowability of Costs Office of Sponsored Programs

  15. NSF Salary and Wages Policy • Limits salary compensation for senior personnel • Two (2) months of regular salary in any one year • All NSF funded grants. Office of Sponsored Programs

  16. NSF regards research as one of the normal functions of faculty members at institutions of higher education. • Compensation for time normally spent on research within the term of the appointment is deemed to be included within the faculty member’s regular organizational salary. Office of Sponsored Programs

  17. NSF Funds many NOT be used to: • Augment the total salary or salary rate of faculty members during the period covered by the term of the faculty appointment, or • To reimburse faculty members for consulting or other time in addition to a regular full-time organizational salary covering the same general period of employment. Office of Sponsored Programs

  18. Examples: • Calendar Year Appointment (12 mos) for PI is $120,000 • NSF pays up to $20,000 per year on all NSF projects. $120,000 / 12 X 2 = $20,000 • Academic Appointment (9 mos) for PI is $90,000 • NSF reimbursement must be charged to the grant when it is used • NSF pays up to $20,000 during the academic year on all NSF projects. $90,000 /9 = $10,000 x 2 = $20,000 • Summer Salary for PI with $90K academic appointment • NSF pays up to $20K for two summer months • Two months outside of PI appointment term Office of Sponsored Programs

  19. Unusual cases • Salary in excess of two months must: • Be disclosed in the proposal budget • Justified in the Budget Justification • Specifically approved by NSF in the Award Notice Office of Sponsored Programs

  20. Current & Pending Support • Submitted with your proposal. • All current project support from whatever source. • Include the proposed project • All projects requiring a portion of time of • Principal Investigator • Senior personnel • Even if they receive no salary support from the project(s). Office of Sponsored Programs

  21. Office of Sponsored Programs

  22. Total award amount • Total award period(including indirect costs) • Number of person-months per year to be devoted to the project (regardless of the source of support) may be averaged if the amount varies each year. • Provide information for all proposals already submitted or submitted concurrently to other possible sponsors, including NSF. Office of Sponsored Programs

  23. Concurrent submission of a proposal to other organizations will not prejudice its review by NSF. • Biological Sciences Directorate is an exception to this policy, see GPG Chapter I.G.2. • If the project now being submitted has been funded previously by a source other than NSF, the information above must be furnished for the last period of funding. Office of Sponsored Programs

  24. USG Office of Internal Audit and Compliance Volume 2, Issue 4, March 2013 • Federal agency regulations control the calculation and characterization of grant related billing and the final authorities are the grant and contract • documents, granting agency policies and procedures, and Circulars for • Educational and Non-Profit Institutions 2CFR, part 220 (OMB Circular A-21). • Federal guidance is given on additional pay for Faculty • researchers. Office of Sponsored Programs

  25. This should be addressed on a case by case basis paying close attention to the terms, conditions and policies relevant to the sponsored project and those of the BOR. The following authoritative sources are summarized related to the issue of Extra Compensation: 1.BOR Policy 8.3.12.4 addresses Extra Compensation as it relates to Faculty: a. Research and Saturday classes will ordinarily be carried by USG personnel as part of their normal workload without additional financial compensation. Adequate allowance in time assigned for the extra duties shall be made by a proportionate decrease in the teaching load; b. Extra compensation may be paid, however, when all four of the following conditions exist: Office of Sponsored Programs

  26. (1)The work is carried in addition to a normal full load, (2) No qualified person is available to carry the work as part of his/her normal load, (3) the work produces sufficient income to be self supporting, (4) The additional duties are not so heavy as to interfere with the performance of regular duties. c. Although not stated, it should be understood that extra compensation allowed under state regulations and BOR policy would be typically funded by State appropriations or auxiliary funds. Institutions should follow federal, state, BOR and institutional terms, conditions, policies and procedures, and advanced approvals applicable to the sponsored project concerning use of federal funds for extra compensation. Office of Sponsored Programs

  27. 2. USG Business Procedures Manual, Payroll Section 5.3.2 states: “Extra compensation may be paid to employees for tasks performed after normal business hours for duties not included in the employee’s normal job responsibilities, provided the following three criteria are met: a. Tasks must be outside of the employee’s regular department; and, b. The Department Agreement Form must be completed and signed by the appropriate department heads; and, c. The employee must meet at least one of the criteria listed below (Criteria also can be found in the Official Code of Georgia Annotated Section 45-10-25): Chaplain, Fireman, Dentist, Certified Oral or Manual Interpreter for Deaf Persons, Registered Nurse, Licensed Practical Nurse, Psychologist, Teacher or instructor of an evening or night course or program, Professional holding a doctoral or master’s degree from an accredited college or university, or Part-time employee. Office of Sponsored Programs

  28. d. An employee meeting all three criteria listed above may be paid extra compensation for a task for another department during normal job hours if the task is not part of the employee’s normal job responsibilities, and the employee takes annual leave for the portion of time used for the task receiving extra compensation. 3. Federal Regulations a. Only address extra compensation for faculty researchers. b. NSF11-1 January 2011, Chapter II, C. g.(i) (a) states: “NSF regards research as one of the normal functions of faculty members at institutions of higher education…NSF award funds may not be used to augment the total salary or salary rate of faculty members during the period covered by the term of faculty appointment…”. c. OMB Circular A-21 J.10.d (1): “Charges for work performed on sponsored agreements …are allowable at the base salary rate. In no event will charges to sponsored agreements … exceed the proportionate share of the base salary for that period…” Office of Sponsored Programs

  29. d. Exceptions to the process in b. above are rare, but should be included: If faculty members with sponsored support cannot be released from teaching duties, but still perform grant related research, the situation should be 1) documented, 2) notification sent to the granting agency or prime award recipient (in the case of sub-recipient contracts), and 3) approval received in advance of paying extra compensation. Office of Sponsored Programs

  30. For Faculty research staff with nine or ten month contracts, summer semester grant effort can result in extra compensation known as summer salary, if included in the approved grant budget. a. Summer salary calculation involves dividing the contracted base salary by the number of teaching months, usually nine, and multiplying the result by the grant effort percentage times the number of summer months when effort occurred. (Example: For 25 % effort over a period of two summer months: $72,000 base salary divided by 9 = $8,000 per month times 2 months times 25% effort = $4,000 in total summer salary). $72,000/9 = $8,000 x .25 = $2,000 x 2 = $4,000 Leaves 75% Effort Office of Sponsored Programs

  31. b. National Science Foundation (NSF) restricts the summer salary from grants to two months or 2/9 of the annual contracted pay (NSF Grants Policy Manual, Section 611 1.b.2). HHS, Department of Education, and Department of Energy do not have this restriction. c. Federal regulations specifically prohibit effort “worked” during Fall or Spring semester and “reported” in the Summer. Office of Sponsored Programs

  32. To summarize: Federal grant funds normally should not be used as a source for additional pay but instead are used to “buyout” the effort of faculty researchers, i.e., course release time. Unique circumstances as in the case of faculty who cannot be released from their teaching responsibilities are eligible for extra compensation: if permitted by institutional policy and procedures allowed by the contract included in the budget, and if approved in advance by the granting agency. USG Business Procedures Manual 5.3.2 states: Under no circumstances should an employee receive extra compensation for a task while receiving normal compensation for the same time period.” Penalties may be imposed for falsely certifying an effort report or incorrectly billing a granting agency. Both the institution and the certifier may be charged with violations of law. Office of Sponsored Programs

  33. Citations: • Office of Management & Budget (OMB) Circular A-21 Section J.10 (2 CFR 220) • NSF 11-1 January 2011, Chapter II – Proposal Preparation Instructions – C. Proposal Contents, 2.g.(i)(a) • USG Business Procedures Manual, Section 5.3.2 Extra Compensation • BOR Policy 8.3.12.4 • NSF Grants Policy Manual, Section 611 1.b.2 Office of Sponsored Programs

  34. Question? Office of Sponsored Programs

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