Trick or Treat: Gift or Grant?

Just as no trick goes unpunished and no treat is without corollary, no amount of money or material enters our fair University without strings attached.  So how does one determine which course of action to take when receiving a resource?  The first step is to figure out what it is, exactly, you are receiving!  These guidelines below may help:

 

GIFTS

Gifts, to paraphrase Executive Order 04-5, are contributions received for use in furtherance of the WSU’s mission that are not in exchange for some service, product or property rendered by WSU (the donor may, however, place restrictions on the contribution and still classify as a gift).  A full text definition of a gift as given by Executive Order 04-5 is available here, and is upheld in APPM 1.7.6 – 1.4.

Who Needs To Know About Your Gift: Communicate with the Office of the Provost and the Vice President for Development and Alumni Affairs; any gifts solicited either verbally or in writing from corporations, foundations or individuals must receive prior approval from these two entities.  Once received, a gift check (which must be made out to Wayne State University) should then be brought to the Dean of Students Office.

 

GRANTS

Executive Order 04-5 similarly defines a “grant” as “a contribution received by the University for either restricted or unrestricted use in furtherance of the institution’s mission that typically comes from a corporation, foundation or other organization, not an individual.”  The similar definitions leave all sorts of gray areas, but the trick here is to determine which subdivision the grant falls into:

  • NON-SPECIFIC Grants are those received by the university that do NOT result from a specific grant proposal.  This type of grant that many institutions may opt to designate as a gift for internal accounting purposes.
  • Who Needs To Know About Your Non-Specific Grant: Just like gifts, the Office of the Provost and the Vice President for Development and Alumni Affairs need to know of the solicitation ahead of time, and the Dean of Students Office must receive the check.
  • SPECIFIC Grants are those received by the university that DO result from a specific grant proposal submitted by the university (or department therein).  There is a defined contribution of university resources or services as a condition of the grant, and an accounting of the use of funds and results is almost always a requirement (any and all research grants meet this requirement).
  • Who Needs To Know About Your Specific Grant: Wayne State University’s Sponsored Program Administration office must be the entity through which you submit for any specific grants.

 

But wait… what about CONTRACTS?

Contracts are also defined within Executive Order 04-5, as well as APPM 1.7.6 as “an agreement between the University and another entity to provide an economic benefit for compensation. The agreement is binding and creates a quid pro quo relationship between the University and the entity.”  While university policy is to determine the intent of awarding party when determining contract or grant classification, it is helpful to consider the nature of the intended result of the contract: is there a promise to absolutely deliver a product/service in exchange for consideration (i.e. money)?  If so, it’s probably a contract. If, on the other hand, resources are being granted on the basis of reasonable hopes a task can be accomplished (i.e. a hypothesis-based project), it’s likely a grant.

Who Needs To Know About Your Contract: The Office of the Vice President for Research must review any contract before it is signed; additionally, it is recommended that the division of Technology Commercialization be the first contact if the contract involves the School of Medicine, due to the likely scientific nature and plausible discovery associated therewith.  SPA’s Contract division will be responsible for the administration of executed contracts, but will also assist in negotiation procedures before finalization.

 

The treats of funding aren’t without their tricks to processing, but come and knock on RAS’s door if you need a little help in your determination.  Happy Halloween!

 

(*UPDATE* This “Gift or Grant” matrix may help you in determining whether you are dealing with a gift or grant.)

JIT Jitters

JIT is an acronym for “Just-In-Time” and refers to the time frame during an application period in which applicants send information to the NIH only if an award is likely. The JIT process is meant to decrease the administrative burden for the 80 percent or so of applications that will not receive funding, and also provides NIH with the most current information “just-in-time” for the award. JIT information includes up-to-date information in categories such as Other Support, IACUC, IRB, and Human Subjects Education Documentation. When “JIT” is posted in the “Action” column of an NIH eRA Commons account, it signifies that the application has completed the peer review process and has received a rank for which funding may be possible.

When To Respond to a JIT Request

A “JIT” link next to a grant number on the eRA Commons is not a request for JIT information. The appearance of this link signifies that an application has completed the peer review process and has received a rank for which funding may be possible. Wait to submit the JIT response until a specific JIT request from NIH grants management has been received by the PI or SPA. The JIT request may include a specific due date; the response should be prepared and submitted to SPA a minimum of five full business days prior to the NIH due date. You should allow SPA additional time for review if the response due date falls on a major NIH deadline.  And of course, RAS is always here to help!

 

 

A Herculean Effort

Effort reporting is the proverbial thorn in the side of all persons working on federally funded grants.  Most grant personnel categorize effort reporting as mysterious, annoying and distracting from the conduct of vital research.

Effort reporting, however, is directly vital to the execution of all grant-funded research: it is the way institutions prove to federal auditors that employees did, indeed, work on a specific federally funded project during the specific time requested in the application, and at the correlating level of effort.  The funding agencies need to know that dedicated monies are being spent according to the terms of the notice of grant award/contract and as defined (and required!) by the U.S. Office of Management and Budgets (OMB). Remember, salary and fringes are allowable costs within the OMB – as long as the paid individual is working on the grant’s objectives and if appropriate “time and effort” records are maintained.

Having trouble certifying yourself or an employee?  Here are some instructions developed by the research support staff in CLAS on how to use the system:

Sub Culture

Subawards allow another organization to perform some activities for your grant under your supervision. They enable collaborations between you – the grantee, or prime – and the subawardee. This arrangement does not involve the NIH, but the details of the work are included in your application so the initial peer review committee can evaluate (unlike a purchase contract).  Be sure to involve your GCO in SPA since the subcontract will probably require agreements between the organizations.  You may also need to include Technology Commercialization if there will be intellectual property involved.

 

When managing subawards, as the prime institution you are fully responsible for all actions of the subaward related to the award and all contact with NIH.  As the prime, WSU (not the subawardee) is accountable to NIH for the performance of the research project, spending of grant funds by all parties, reporting requirements, negotiating animal and human subjects assurances, and other obligations for the grant.

Remember:

  • WSU still needs to play a substantive role in the research; we cannot act as a pass-through for funds to another institution;
  • If information is needed from any subawardees, NIH will contact WSU as the prime;
  • If there’s a problem with a subawardee, WSU will be expected to resolve it;
  • A subaward can be added to a project anytime!

Shows Us What You’re Working With: Consultants, Collaborators and Co-Is

The age-old attempt at definitions of consultants vs. collaborators is one wrangled by both administrators and PIs alike. A wicket more sticky presents itself when comparing collaborators and co-investigators!  So when, then, is it appropriate to use each classification?

Consultant vs. Collaborator

Let’s start by comparing consultants and collaborators: occasionally, people play BOTH roles.  The term “consultant” is used when a person is providing advice or services. They may participate significantly in the research, but often they help fill in smaller gaps, for example, providing a key supply, technical review, or equipment set-up/adjustment. Consultants do not receive a salary from your grant but may receive a fee. When paying them, WSU will need to issue a Form 1099 Misc to the IRS.

Collaborators always play an active role in the research. They are not paid a fee, but the grant may pay part of their salary in person months through a consortium agreement or subaward. Collaborators are issued a Form W-2 (from their institution if other than WSU) as opposed to the 1099.

Consultants are easiest to define: they provide advice and services for a fee. This is clearly stated in letters of support, which include the fee structure.


For more information on using subawards and subcontracts, stay tuned next week!

 

Collaborator vs. Co-I

Co-Investigators and collaborators both traditionally have effort assigned on a project and can have (but are not required to have) compensation, which may explain why they are often terms used interchangeably.  They are, however, different animals! Collaborators are associated with the grantee institution and Co-Investigators can come from either the institution or another institution.  The biggest difference is the level of involvement in the scientific thinking of the project.  Think of it as a continuum from PI to co-investigator to collaborator regarding the theory and logistics of the project itself.  There is somewhat subjective leeway given on how “levels of involvement” are perceived in the context of specific scientific fields; keep in mind what the normal roles are and expectations are in your scientific community.

In your application, the Personnel Justification will ask you to explain the roles of these people and ask you to provide letters. If any difference exists in the scientific communities as to how these terms are used, the letters will be the place to explain this.  Be sure that the letters outlining the roles of the personnel are very closely matched to the expectations set forth by the PI in the “Personnel Justification” section. Reviewers can tell when a person listed is actually wanted on the project, or if they’re just listed because their prominence in the field is an attempt to boost the score!

 

Other Significant Contributors

This is the section where you can list your prestige-boosting personnel that aren’t as material to the project.  Other Significant Contributors are similar to co-investigators, but don’t have defined effort, just effort as needed. In terms of the continuum, this is the person that would be called if you’re having trouble with this particular experiment, need a fresh pair of eyes for data interpretation, etc.