Pre-Award Fundamentals

1. Pre-Award Fundamentals

2. Objectives • Upon completion of this class participants will be able to: • Locate and apply knowledge of basic Federal sponsor rules and regulations • Understand and apply fundamental compliance concepts to research/grant management • Locate and apply Duke University grant management policies and procedures related to proposal development • Have an understanding of a grant manager’s role in proposal development • Locate and have a basic understanding of guidance cited in funding announcements • Understand basic budget development concepts • Understand federal costing guidelines and how to use these guidelines in budget development • Locate and understand basic budgetary components • Understand the proposal submission process Slide 2

3. Learning Outcomes • Upon completion of this class participants will be able to: • Understand and apply basic Federal regulations towards charging costs to Federal awards • Able to understand basic compliance rules of allowability, allocability, consistency, and reasonableness • Ability to distinguish and apply charges based on allowable and unallowable costs • Ability to distinguish differences between direct charges and F&A costs • Understand basic concept of charging Administrative and Clerical costs to Federal awards • Locate and have a basic understanding of guidance cited in funding announcements • Identify and advise the PI of administrative requirements and proposal elements related to proposal preparation Slide 3

4. Learning Outcomes • Ability to understand and apply basic knowledge of who funds sponsored research and the basic funding mechanisms used by sponsors • Ability to understand and apply guidance on funding opportunity announcements from different sponsors • Awareness of various search engines and resources at Duke in order to find funding opportunities for PIs • Ability to understand the basic concepts and terminology related to proposal development • Understand and be able to advise PIs of required proposal elements (Biosketch, Other Support, Facilities & Resources) for proposal preparation • Understand how to include collaborations and subcontractors in proposal budgets and submissions • Ability to advise the PI of submission requirement (paper vs. electronic) Slide 4

5. Compliance Basics: What is Compliance? Slide 5

6. What is Compliance? • Meeting all the obligations associated with accepting funds to conduct research or perform an activity proposed to the sponsor • Establishing internal controls/checks and balances within the university and the department to manage funds effectively and appropriately (according to the rules) • Meeting the stated management requirements of the sponsor and the university • Communicating compliance expectations to all constituencies – including colleagues and faculty researchers (PIs) In the most basic terms, compliance is following the rules. Slide 6

7. Why is Compliance So Important to Duke University? • Federal research investment comes from public funds – taxpayer dollars. It is important that Duke University honor that investment and spend/account for funds wisely • Penalties, fines, and potential loss of federal funding could result if the university is not compliant: • Negative publicity • Large financial settlements • Greatly reduced flexibility in the management of federally provided resources (The federal government could put restrictions and additional reporting burden on the university) • Audit findings • Disallowance of costs (Duke University would have to pay back federal funds) • Extrapolation to University grant portfolio Key point: One small item may be “extrapolated” or used as evidence that other similar items were also non-compliant. This means that a $10.00 item found on an audit may possibly be “extrapolated” to $100,000 and Duke University held responsible for paying Federal funds in that amount. Slide 7

8. Summary • Compliance is following the rules – federal laws, sponsor regulations, and Duke policies • Compliance is important because non-compliance can cost Duke in fines, penalties, and reputation. It can also cause employees to lose their job, or in severe instances, go to jail. • The RAA program is designed to provide you with the tools to monitor compliance Slide 8

9. Rules and Regulations Compliant grant management starts with knowing the rules you must follow… Slide 9

10. Order of Precedence Public Law Institutional Policy 10 Slide 10

11. OMB Circulars Are… • Instructions issued by the Office of Management and Budget to the federal agencies • Purpose: • To assure that grants are managed properly and that federal dollars are spent in accordance with applicable laws and regulations • Agencies then implement into their own requirements • Regulations specifically governing Federally sponsored activities • Codified in Title 2 of the Code of Federal Regulations • 2 C.F.R. Pt. 215 (A-110) • 2 CFR Pt. 220 (A-21) • Not directly applicable to recipients; only applicable through agency implementation All OMB Circulars can be found on this web site: www.whitehouse.gov/omb/grants_default Slide 11

12. OMB Circular A-21: 2CFR Part 220Cost Principles Appendix 1: Circular A-21 Circular A-21 provides guidance on: • Allowabilityof costs • Consistency in cost treatment • Direct and F&A costs • Identification & assignment of F&A costs and calculating F&A cost rates • Guidance for selected cost items • Examples of “major project” where direct charging of administrative costs may be appropriate • Cost Accounting Standards for educational institutions We will discuss Circular A-21 in more detail in the budget development section of this course Slide 12 12

13. OMB Circular A-110 (2CFR Part 215): Administrative Requirements A-110 provides direction as to the systems and processes required to manage grants/contracts at Duke University The circular also provides agencies with guidance on Award instruments Forms “Eligible” recipients Special award conditions Certifications and Representations Procurement standards Reports and records University requirements include: Payments Matching or Cost sharing Accounting for program income Revision of budget and program plans Non-Federal audits Allowable costs Financial management systems standards Property standards Slide 13 13

14. OMB Circular A-110 (Now 2CFR Part 215): Administrative Requirements • Expanded Authorities granted to the recipient institution • Means that agencies can waive cost-related and administrative prior approvals for: • Pre-award Costs (90 days prior to award) • One-time 12 month extension • Carry forward of balances • This means that Duke University is not required to seek Federal permission for these actions, but can authorize these actions on its own. Slide 14 14

15. Appendix 2: Crosswalk to Circulars To Learn More About the Circulars • AGM: Regulatory Environment: A-21, A-110, A-133, F&A • Check the course catalog in the LMS to see a list of available classes • Appendix 2 provides a crosswalk to Circulars that apply to recipients other than universities Slide 15 15

16. Rules and Regulations: Sponsor Guidance Public Law Institutional Policy Slide 16

17. Handout 1: FDP Matrix Sponsor Rules and PoliciesFederal Demonstration Partnership (FDP) • History • FDP began as an experiment in Florida to reduce the need for agency permission for certain actions. Several years ago Federal agencies exerted a great deal more control over how research was managed at Universities. As a result of FDP most research-funding agencies have agreed to reduced management requirements • Purpose • To demonstrate that accountability can be maintained while simplifying research management • The FDP matrix • Provides an overview of the specific actions Universities can take without approval from the Federal agency Slide 17 17

18. Handout 2: Answer Key FDP Matrix Exercise Using the FDP Matrix: Does NASA require prior-approval for initial no-cost extension? • Prior approval waived • Does NIH require prior-approval for pre-award costs exceeding 90 days? • Prior approval required • Does NSF require prior approval to purchase equipment that was not originally in the proposed budget? What about NIH? • NSF: Prior approval waived • NIH: Prior approval waived, unless change in scope • Does the EPA allow a grant recipient to trade in a piece of equipment purchased with project funds in order to buy a replacement? • This is permitted Slide 18

19. Sponsor Rules and Policies: Federal Sponsors • Each federal agency has their own rules, policies, and guidelines that can be more restrictive than the OMB circulars • Review specific agency guidance in policy statements and funding announcements prior to submitting a proposal • NIH Policy Statement: http://grants.nih.gov/grants/policy/nihgps_2013/nihgps_ch2.htm#appl_forms • NSF Policy Statement: http://www.nsf.gov/publications/pub_summ.jsp?ods_key=gpm Slide 19

20. Sponsor Rules and Policies: Non-Federal Sponsors • Non-federal sponsors such as associations, industry, foundations, etc. have different rules and requirements • When managing a non-federal award, it is important to find and understand the rules and requirements of these sponsoring organizations • Sponsor policy manuals • Guidance on sponsor website • Proposal Central • When in doubt, contact your pre-award office (ORA or ORS) for guidance Slide 20 20

21. Susan G. Komen For the Cure Robert Wood Johnson Foundation Sponsor Rules and Policies Non-Federal Agency Policy Manuals Slide 21 21

22. Institutional Implementation • Duke University Policies and Procedures: • General Accounting Procedures (GAPs) are tools to assist in day-to-day tasks • GAPs provide actual procedures for managing grants and contracts, handling consultants, understanding faculty effort, payroll, plant and equipment, and other accounting topics • GAPs: http://www.finsvc.duke.edu/gap/topics.html • The Faculty Handbook: • Faculty Handbook contains policies and procedures pertinent to faculty at Duke University. • The Office of the Provost is responsible for the compilation of the faculty handbook. • Chapter 5 of the faculty handbook specifically addresses Sponsored Research. • Faculty Handbook: http://www.provost.duke.edu/policies/fhb.html Public Law Institutional Policy Slide 22 22

23. Slide 23

24. Order of Precedence: Which Rules Do I Follow? Public Law Institutional Policy http://www.youtube.com/watch?v=szF-_zmCYEs&feature=c4-overview-vl&list=PLFA91D9F37D585F00 24 Slide 24

25. Now that you are familiar with some of the rules that regulate research administration, what is the grant manager’s role in research administration? Slide 25

26. Slide 26

27. What Do Research Administrators Do? • Assist PIs with the creation and submission of proposals • Manage sponsored programs for our faculty • Review, sign and submit proposals on behalf of the Institution • Review and negotiate sponsor terms and conditions for grants, contracts and subagreements • Assure compliance with federal, state and university regulations Slide 27

28. Research Administrator: Roles and Responsibilities • Financial Administrator (Research Administrator, Grant Manager) • Shares responsibility for financial compliance • Manages finances • Reconciles individual expenses to the award budget • Ensures proper documentation is maintained • Prepares non-financial reports • Serves as an advisor to the PI and Chair’s or Dean’s Office on financial/administrative matters • Prepares and/or approves documents for sponsored projects • Financial • Human Resources • Other documents Slide 28

29. Research Administrator: Roles and Responsibilities • Financial Administrator (Research Administrator, Grant Manager) Cont. • Serve PD/PI • Provide assistance to support (funded) research • Keep PI out of trouble • Serve Institution • Keep institution out of trouble • Reports/investigates instances of unresolved financial non-compliance • Seeks the advice and approval of higher authority resources for guidance on proper procedures and resolution of compliance issues • Serve the Sponsor • Ensure sponsor funds are spent according to the award • If a federal award, you are ensuring tax dollars are spent wisely Research administrators wear many hats and have many roles in serving the PI, the Institution, and the Sponsors Slide 29

30. Research Administrator: Roles and Responsibilities Elective Matrix • As part of RAA, you and your supervisor reviewed your role in research administration in your unit and selected applicable electives based on your role • Not every research administrator has the same responsibilities • You can use the decision matrix to help with choosing classes for career development Slide 30

31. The Life Cycle of a Funded Project Slide 31

32. Life Cycle of a Funded Project • Proposal Development • Institutional Clearances • Proposal Submission & Sponsor Review • Award Negotiation & Acceptance • Award & Project Set-Up • Spending Award Funds • Project Monitoring • Approaching Project End Slide 32 Slide 32

33. Pre-Award and Post-Award Most universities define the various functions and activities that occur throughout the life cycle of a funded project as either pre-award or post-award. Slide 33 33

34. Pre-award is the general term applied to the services, functions and responsibilities that involve: Identification of funding sources and guidelines Preparation of a proposal (statement of the work to be done, budgets, personnel roster and resumes/vitae, other proposal required forms) Submission of the proposal according to sponsor requirements Review of the award and negotiation of the award if necessary to adjust to changes Slide 34 34

35. Post-award is the general term applied to the services, functions, and responsibilities that involve: • Setting up the awarded project in the Duke University financial system • Charging costs to the project in accordance with the approved budget and sponsor regulations • Reconciling and adjusting the project budget as needed to accommodate changes in research, corrections to charges, and increases/decreases in the effort levels of individuals working on the project • Reporting on the financial progress of the project, including projecting costs for future expenses and effort of individuals working on the project • Closing the project, including ensuring that all charges are accounted for, incorrect or unallowable charges are removed, all reports are filed, and all revenues accounted for Slide 35

36. Role of Grant Manager in Pre-Award • Facilitate and assist PI with proposal preparation, which may include: • Finding funding opportunities • Updating Biographical Sketch or Other Support • Completing Budget and/or Budget Justification • Communicate and ensure correct formatting and other requirements • Ensure that all proposal elements are complete and meet all sponsor requirements • Ensure the complete proposal is submitted on time to appropriate pre-award office (ORA or ORS) Slide 36

37. Role of PI in Pre-Award • Determine which opportunity to apply for • Develop and write the project description and other scientific-based sections • Communicate budget and other project needs to grant manager • Upload documents into SPS *Remember that every PI has different needs from their grant manager while preparing a proposal for submission Slide 37

38. Role of Pre-Award Offices • Ensures that submissions meet requirements of announcement, as well as regulations and university policies • Check all proposals for correct formatting, submission requirements, appropriate internal approvals (DPAF), etc. • Communicate with grant manager/dept. regarding the successful submission of proposals, including answering dept. questions Slide 38

39. Working Together PI, Grant Manager and ORA/ORS all work together for the success of the proposal submission. Slide 39 Slide 39

40. Finding Funding Slide 40

41. Sources of Sponsored Program Support • Who funds research? • United States Government • State Agencies • Private Industry • Associations, Professional Groups • Foundations • Corporate • Private • Other entities • Foreign Governments • Foreign Corporations • Foreign Organizations Slide 41

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43. Information Sources: How to find Funding The Funding Opportunities Team at the Office of Research Support provides funding workshops and seminars available to both Campus and Medical Center • Other resources provided include: • Funding Alert Newsletter • Grant Deadlines Newsletter • Use Funding Search Subscription Databases: • Pivot (COS): http://pivot.cos.com/ • Foundation Directory Online: http://www.ors.duke.edu/funding-search-tools • FundSource:http://www.decadeofbehavior.org/intro.html • GrantsNet:http://sciencecareers.sciencemag.org/funding • Grants.gov: http://www.grants.gov/web/grants/home.html Slide 43

44. How Federal Funding Becomes Available Slide 44

45. How Federal Sponsors Announce OpportunitiesWhat do the Letters Mean? Slide 45

46. How Federal Sponsors Announce OpportunitiesWhat do the Letters Mean? Slide 46

47. How Federal Sponsors Announce OpportunitiesWhat do the Letters Mean? Slide 47

48. How Federal Sponsors Announce OpportunitiesWhat do the Letters Mean? This is generally true, but you may find exceptions Slide 48

49. Handout 3: Answer Key Funding Announcement Exercise #1 • Your PI calls you from a trip to Colorado to inform you that he/she wants to put in an application for BAA-N00173-02. You quickly write down what looks like the zip code of a foreign country. Now what? Questions to ask yourself: • What type of funding announcement is this? • Broad Agency Announcement • What does this tell me? • This could be a grant, cooperative agreement, or contract • What should I do to find out more information about this project? • Google it! • Look it up the announcement number on grants.gov Slide 49

50. Funding Announcement Exercise #2 You had a pre-work assignment to find two funding announcements using grants.gov. • PA-13-302 • NSF 13-606 Using these announcements, identify the following key elements: • What is the sponsoring agency? • What is the application due date? • What is the maximum project period? • Is Duke University an eligible organization to apply to this announcement? • Where can you go to find more specific application instructions? Slide 50