Discussion Topics

Managing NU, NMFF, and VA Appointments when Proposing and Administering NIH Career (K) Awards Bruce Elliott, PhD, Executive Director, OSR - Chicago CampusSeptember 21 and 22, 2010

Discussion Topics • Representing academic medical center appointments (NU, NMFF, VA) in NIH proposals • Joint appointments at the VA and the VA Memorandum of Understanding (MOU) • Multiple appointments and what constitutes 100% effort • K awards and the difference between NIH total professional effort and full-time professional effort • How many 8ths you can have at the VA before NIH starts to question making an award • NU’s responsibility for determining the reasonableness of a full-time appointment for faculty with joint VA appointments • The opportunity costs of a K award in terms of both dollars and other grant opportunities • Concurrent effort and salary for other sponsored awards during K

VA Appointments • Faculty member performs activities at both the VA hospital and the university • Clinical Care • Research • Administration • Teaching • Responsibilities formalized in the VA Memorandum of Understanding (VA MOU)

VA MOU Investigators with joint appointments at the VA and NU must have an MOU that specifies the title of the investigator’s appointment, the responsibilities at both the university and the VA, and the percentage of effort available for research. • Ensures no chance for dual compensation or overlap in scientific goals • Combination of NU and VA time constitutes 100 percent of faculty member’s total professional responsibilities and total professional effort

VA MOU Challenges • VA commitment is based on 40-hour workweek and defined in X/8ths • NU commitments expressed as % effort • Major challenge: • How many total hours is reasonable? 60? 65? • Effort reporting – report on total prof effort or NU effort • Full-time professional effort and the making of NIH awards to NU – Does NIH think you have sufficient time at NU to have meaningful effort commitment

What Constitutes 100% Effort at NU All effort expended to meet commitments as an NU faculty member Teaching, research, service, administration • Activities defined in NU appointment letter • For faculty with clinical appointments, effort also includes NMFF • Hours will vary for different faculty members, and may also vary during the year, but effort is independent of hours • Excludes outside professional activities (consulting, study section) VA appointments are not included in NU effort but are included in the concept of total professional effort NIH definition of total professional effort changed in 2004 to effort based on applicant institutional appointment, aka full-time professional effort

VA and NU Effort Reporting • NU grant application may only request NU institutional portion of effort and salary because NU is applicant organization • IBS = The annual compensation paid by an organization for the employee’s appointment… • No salary support may be requested for the VA portion of the joint appointment • Certified NU effort reports exclude VA activities and salary

How to Represent Joint Appointments to NIH Dr. ___________ has an appointment with Northwestern University (NU) and with the affiliated Northwestern Medical Faculty Foundation clinical practice plan (NMFF), and with the Veterans Administration (VA). This arrangement is defined in a formal NU-VA Joint Appointment Memorandum of Understanding. The institutional base salary used in this application represents the combined salary from both NU and NMFF, which is paid by NU under a common paymaster system; it does not include salary from the VA appointment. The number of person months in this application represents NU effort on the proposed project in relation to professional effort for the dual NU and NMFF appointments.

Overview of K Awards • Provides protected time for comprehensive career development experience • NIH ICs implement Ks in different ways; review specific provisions of individual award • General terms and conditions: • Generally require 75% effort commitment • Primarily support recipient’s salary & fringe • Limit salary recovery so cost sharing often required • Modest supply allowance so supplementation often required • Most prohibit recipients from simultaneously recovering salary on any other NIH award in first 3 years of award

What Constitutes K Award Effort • Challenging because different from normal awards – focus on comprehensive career development experience • Allowable activities on K that aren’t allowable on other NIH awards include • Responsible conduct in research • Competitive proposal writing • Certain clinical activities • Little guidance on these activities so describe in proposal to avoid audit issues

K Awards Can Be Expensive for a Department • Require substantial effort commitment to research activities, limiting recipient’s ability to spend time elsewhere (e.g., patient care, other sponsored projects) • Salary is capped at a low amount and because many clinician recipients are highly compensated, substantial cost sharing can be required • To meet 75% commitment, clinicians often have to reduce clinical schedule. This can reduce department income and cause scheduling problems • Effort for research projects that don’t overlap the K award scope must be supported beyond the K effort and salary must come from non-federal sources

K Awards Can Be Expensive for a Department cont’d • F&A recovery is limited to 8% MTDC, far below the university’s negotiated federal rate • Clinicians with VA appointments have additional considerations • A cost-benefit analysis should be done before proposing on a K. The PI and Chair must understand “economics” of Ks and evaluate whether applying is appropriate • In endorsing a K award proposal for his/her faculty member, the chair is agreeing that, if awarded, the PI will be permitted to spend the prescribed % of time on K activities – for 5 years!

K Award Management Practices A challenging component of any institution’s research portfolio! • Does the applicant have significant teaching, administrative, or clinical responsibilities that might interfere with his or her ability to meet the level of effort requirement? • Be aware of K award eligibility requirements, including citizenship, degree, and previous sponsored research support • Consider developing special monitoring for K award recipients. For example, check in with your K award PIs at the midpoint of each budget period to remind them of their effort requirement

K Award Management Practices con’t • At the end of each budget period, confirm that the PI met the effort requirement. • Be proactive. If a compliance issue arises, e.g., a failure to meet an effort requirement, work with NIH to resolve the situation—do not wait until the end of the award.

Transition Point

New Definition of Full-Time Professional Effort for K Awards • NIH previously defined effort requirement as encompassing the entirety of the PI’s professional commitments, both within and outside the applicant organization • A PI’s total professional commitments were included in the denominator of the effort calculation, but only activity taking place at the recipient institution could be included in the numerator • Designed to protect PI’s time but caused potential over-commitments and effort reporting problems and detracted from advantages of Ks. Known as Total Professional Effort • A career award recipient now meets the required commitment for total professional effort as long as: • 1) the individual has a full-time appointment with the applicant organization; and • 2) the minimum percentage of the candidate’s commitment required for the proposed career award experience is covered by that appointment. • This is now called Full-time Professional Effort

New Definition of Full-Time Professional Effort for K Awards con’t • Policy applies to PIs with appointments at the VA and with independent practice plans • Does the faculty member have sufficient time available for the 75% commitment to a K award to meet the test of reasonableness? Example An investigator has a full time appointment at a university and a half time appointment with another organization (VA or independent clinical practice plan) Under this new policy, the investigator can be supported because the candidate can commit at least 75% of their full-time NU appointment to the award

Challenges Presented by Faculty with Joint VA Appointments • Does NIH actually adhere to this policy? • No problem with 4/8 VA appointment but what about 5/8, 8/8? • Does the K award policy apply to non-career awards, such as R01s?

K Awards and Concurrent Support • Effort supported by K award can be used to support other federal projects resulting from K award scope • Varies with IC and award to award • In the last 2 years of the K award • Must have PI status on major award such as R01 or program project component • May take salary from the new award • NINDS encourages R01 funding asap • Effort on additional research support not related to K award cannot be included in the K effort and must be counted in addition to the K effort. Salary can be requested but must come from non-federal sources • Individuals holding K awards may perform clinical activities required by the research-related activities of the K award. Other patient-care effort not required to perform the research under the K must be reported as clinical activities • JIT Other Support and effort reporting can become complicated

Real-Life Examples • PI with an 8/8 VA appointment • PI with an SBIR subcontract and a K award • PI received R01 in 3rd year of K. What NIH said for year 3 and year 4-5

If you wish to discuss specific issues, phone me! Questions Bruce Elliott 3-1780 b-elliott@northwestern.edu

Discussion Topics