Applied [Budget] Transfer

If you’re welcoming a new faculty member to your department, there’s a good chance that you’re welcoming a new project or two as well.  Once you have received the NIH-approved relinquishing statement from the former institution, you’ll need to put together a new budget to satisfy both SPA and the Change of Grantee Organization SF 424.  (On a related note, the NIH made some updates to the SF 424 Application Guide and released it last Friday, July 25, 2014.  Edits are noted in purple.)  When building your transfer budget, these points may be helpful:

 

  • Your first year budget should match the amount on the approved relinquishing statement.  Any following out years should match the awarded direct costs on the original Notice of Grant Award (NOGA).
  • While direct costs must match the NOGA, indirects are permitted to be generated based on Wayne State University’s applicable F&A rates.  This will change the overall dollar amounts awarded in each year; that’s OK.
  • Modular submission is not permitted for a transfer/change of grantee organization.  HOWEVER, if desired, an award that was submitted as modular during the proposal phase has the option during transfer to complete only the costs for the PD/PI (Section A), and include the remainder of the direct costs under Section F (Other Direct Costs) Item 8, and Section H (Indirect Costs).  Otherwise, a detailed budget should be utilized.

 

If you’re fortunate enough to be transferring an award to your department, we’re here to help with any questions you may have!  For further details, take a look at the text of PA-14-078.

 

 

Amending Expectations

The kind folks at Wayne’s Institutional Review Board (IRB) has been holding sessions to remind, refresh and renew the understanding of our application and approval process.  One of the most common processes in IRB is amending a current approval to reflect a new or altered project.  When planning your project timeline, it’s helpful to know some of the most common issues that prevent a timely amendment approval:

  • Changes to a project that are not adequately explained
  • Reasons for the change are not adequately explained
  • Missing documents
  • Revisions are not highlighted
  • Wrong submission type

(These issues were highlighted by Wayne State University IRB in their July presentation.)

 

Remember that any time there is an increase in the population that would be exposed to the risks of a study, detailed explanation is required.  In addition to an account of changes (with references and details where necessary), you must also:

  • Use the exact, accurate project title
  • Note the expiration and continuation dates
  • Ensure the funding source is up to date
  • Revise all documents affected

 

Delays in IRB approval can materially affect data collection; make your life easier with a few precautionary steps to ensure the smoothest application possible!  If you would like some clarification on an IRB issue, send an email to RAS and we’ll arrange for an IRB representative to present at Tips & Tools.  If you have a specific IRB question on a specific study submission, Ray-Nitra Pugh, IRB Education Coordinator, is an excellent resource!

Every Effort for Progress

The structure of effort reporting on the RPPR (Research Performance Progress Report) can be a bit tricky to decipher.  A few key points to keep in mind:

 

  • Effort must be rounded to the nearest whole person month on progress reports, even though proposals still use fractional requests.  This is mandated by the OMB. ** Note: even though NIH defines a PD/PI as having effort greater than zero, there may be some instances where the PD/PI has 0.4 person month or less.  In this case, it is appropriate to report zero person months in the RPPR
  • Persons reported on an RPPR must either be the PD/PI or have worked at least one person month during the reporting period.  In the case of a person who is not PD/PI and has worked less than one month, rounding is not appropriate.   A non-PD/PI who has worked 24 days, then, should not be reported on your RPPR even though the nearest whole person month is 1 month.
  • Keep in mind that effort reporting in section D.1 on an RPPR is retrospective; that is, you are reporting effort that took place in the past.  Rules pertaining to reductions in effort of 25% or more from the Notice of Award will, however, be applicable in section D.2.a; a “yes” answer here would require prior approval.  If reductions are forthcoming, you will need to get approval from your agency for current and future reporting periods.

 

If you are unclear as to how you should be reporting effort on your RPPR, RAS is here to help you sort it out.  The NIH RPPR FAQs page  is also a great resource for more information.

Warning: Explicit Language

Most proposal project periods are not going to neatly start on October 1, and will therefore span multiple rate periods in our DHHS agreement.  In order to draw the necessary attention to Wayne State’s variable negotiated rates (and how to express them), you should include language in your budget justification under an “Indirect Costs” heading.  For a little guidance, take a look at the sample language provided here:

* Note:  The italicized portion of this language comes directly from our rate agreement.

 

Indirect Cost Calculations

Wayne State University uses Modified Total Direct Cost (MTDC) to calculate indirect costs.  Modified total direct costs, consisting of all salaries and wages, fringe benefits, materials, supplies, services, travel and subgrants and subcontracts up to the first $25,000 of each subgrant or subcontract (regardless of the period covered by the subgrant or subcontract).  Modified total direct costs shall exclude equipment, capital expenditures, charges for patient care, student tuition remission, rental costs of off-site facilities, scholarships, and fellowships as well as the portion of each subgrant and subcontract in excess of $25,000. The Wayne State University F&A Rate Agreement is negotiated with the Department of Health and Human Services (DHHS), fully executed on November 6, 2014. The agreement has varied rates per fiscal year (10/1 – 9/30). Two F&A rates are applicable to [NUMBER OF PERIODS THAT SPAN MORE THAN ONE RATE] periods:

  • Project Period [X] (beginning [PROJECT PERIOD X START DATE]): [RATE A]% applies for [FIRST NUMBER OF MONTHS] months, [RATE B]% applies for [REMAINING NUMBER OF MONTHS IN PERIOD] …

[APPLICABLE RATE]% applies to all remaining periods.

 

Practical Application: If, for instance, you have a project with 5 periods that beings on April 1, 2015, the indirect cost language included in your budget justification may look like this:

 

Indirect Cost Calculations

Wayne State University uses Modified Total Direct Cost (MTDC) to calculate indirect costs.  Modified total direct costs, consisting of all salaries and wages, fringe benefits, materials, supplies, services, travel and subgrants and subcontracts up to the first $25,000 of each subgrant or subcontract (regardless of the period covered by the subgrant or subcontract).  Modified total direct costs shall exclude equipment, capital expenditures, charges for patient care, student tuition remission, rental costs of off-site facilities, scholarships, and fellowships as well as the portion of each subgrant and subcontract in excess of $25,000. The Wayne State University F&A Rate Agreement is negotiated with the Department of Health and Human Services (DHHS), fully executed on November 6, 2014. The agreement has varied rates per fiscal year (10/1 – 9/30). Two F&A rates are applicable to [2] periods:

  • Project Period 1 (beginning [04/01/2015]): [52.5]% applies for [6] months, [53.0]% applies for [6] months
  • Project Period 2 (beginning [04/01/2016]): [53.0]% applies for [6] months, [54.0]% applies for [6] months

[54.0]% applies to all remaining periods.

 

Feel free to copy-and-paste and change the [BRACKETED/BOLDED] values to those that apply to your project; this material was intended to be shared!  In case you missed it earlier this week, our F&A calculation spreadsheet will help you figure out your own values.  Let us know if you have questions!