Now that Uniform Guidance (2 CFR 200) has been in place for a good, solid month and proposal deadlines are looming large, here are few highlights to changes from the way things were previously done:
- Administrative salaries [§200.413 (c)]: They’re now allowable, even for non-“major projects,” as long as the cost is “integral” (read: the services are essential, vital, or fundamental to the project or activity)
- Computing Devices [§200.343]: These are now considered a “supply” when less than $5,000. They must be “essential and allocable,” but not necessarily solely dedicated, to the performance of a federal award
- If the device is NOT solely dedicated, you must justify its use in the project and allocate costs appropriately
- Cost sharing [§200.306 (a)]: Cost sharing (matching, not inclusive of over-the-cap salary payment) cannot be used during the merit review of proposals, unless specified in a notice of funding opportunity
- PD/PI Disengagement [§200.308]: Prior approval is required for the disengagement of a PD/PI for more than three months, or a 25 percent reduction in time devoted to the project; project directors can be away from campus and remain engaged in the project at the proposed and awarded levels
- The difference here is the term “disengagement” rather than “absence;” this recognizes that a PI/PD can be off campus and still engaged in the research, which would not require prior written approval
- Publication Costs [§200.461 (3)]: Anticipated publication charges that will occur outside of the period of performance CAN be charged
- Subawards [§200.332]: Fixed price subawards require prior approval and limit each subaward to $150,000
If you have any questions about how these changes may affect your award or your proposal, let us know. We’re here to answer any questions you may have in developing your budget or award strategy!
How many of your grants are pending closeout? Do you know which of your PIs have progress reports coming due? Have you ever been completely surprised by the issuance of a NoGA? You just may save yourself some frustration with the help of Commons Quick Queries.
Commons Quick Queries helps you to identify –
- Grants Pending Closeout: Returns a list of NIH grants due for closeout for the over the last number of days selected (you will need Wayne State’s complete complete IPF number: 9110501). This list will not include NIH fellowships. This report does, however, include no-cost extensions, and the date all final reports are due in compliance with the NIH Grants Policy Statement.
- Commons Registered Organizations: Returns a list of all organizations registered in the eRA Commons (this can be helpful for subcontracting and patterning purposes).
- Progress Report Search by IPF Number: Returns a list of progress reports that are due within the next 4 months for a selected grantee institution. To find an institution, you must enter the complete IPF number (Wayne State’s is 9110501; note that any record showing as “Yes” to SNAP is actually due on the 15th of the month instead of the 1st as shown in the query results). Notably NOT included: progress reports for Multi-year Funded awards (MYF), which are always due on or before the anniversary of the budget/project period start date of the award and are uploaded as a PDF through the eRA Commons.
- IPF Number Search: Returns a list of grantee institutions based on a name search (again, helpful for partnering institutions, or if you are a sub on a project that will need a progress report from your portion).
- Issued Notice of (Grant) Award: Returns a list of all NoGAs issued in the over the last number of days selected (up to 90), based on the IPF.
These tools will help you stay on top of your (or your department’s) upcoming obligations to the NIH. If you have any questions about what to do with the information you find, we’re here to help!
Consider this post a virtual toast to the NIH for agreeing to cover more of your salary! In case you missed it last week, the NIH salary cap has been raised from $181,500 to $183,300. This means that all proposals going out after January 11, 2015 should use the $183,300 cap, and all internal cost sharing should be calculated using this number as well. Remember, NIH competing grant awards with salary levels below the new cap(s) that are issued on or after the January 11, 2015 effective date, are allowed to reflect adjustments to the current and all future years; that is, you may rebudget to accommodate the current Executive Level II salary level and contractors may charge at the higher level. Keep in mind, however, that your award amount will not increase and total estimated cost of the contract will not be modified. For more information on applicability of the salary cap, see NOT-OD-15-049.
As always, if your investigator is over the salary cap, his or her department must absorb the difference. Cost sharing must be requested and documented before the application is submitted, and the cost share form can be found here. Here’s a calculation refresher for a PI with 10% effort and a $200,000 base salary:
[Non-Allowable Salary in a Year] = ( [Investigator Institutional Base] x [Investigator Project Effort] ) – ( [NIH Salary Cap] x [Investigator Project Effort] )
[Non-Allowable Salary in a Year] = ($200,000 x 10%) – ($183,300 x 10%)
And of course, don’t forget the fringes:
[Salary Cost Shared] x [Applicable Fringe Rate] = [Fringes Cost Shared]
[$1,670] x [26.6%]
For further details on the magic of cost sharing, take a look at our previous post entitled “Pop a Cap in Your Salary“; you may also find this over-the-cap calculator helpful. If you need help with your calculations or figuring out which rates apply, drop us a line. Cheers!
Welcome back, SOM! As we begin 2015, many of the federal administrative changes that you’ve been reading about are now officially in effect. You’ve heard and seen (ad nauseam) that the OMB Uniform Guidance is officially official as of December 26, 2014; but there other impending changes that you should note as well:
- December 4, 2014: Modification to identification of marked changes in resubmissions in effect [NOT-OD-15-030]
- January 11, 2015: The NIH salary cap is increased to $183,300 [Salary Cap Summary]
- January 25, 2015: New late submission policy is in effect [NOT-OD-15-039]
- January 25. 2015: Implementation of the new genomic data sharing policy begins [NOT-OD-15-027]
- End of January 2015 target: ASSIST will be an option for R03s and R21s [NOT-OD-15-044]
- On or after May 25, 2015: New biosketch formats will be required (though they are encouraged now; this was changed from the original January 25 deadline) [NOT-OD-15-032]
For a more comprehensive look at the changes you can expect, take a look at the administration timeline created by the NIH here. Feel free to reach out if you have any questions!