Diversifying Your Portfolio: Additions to the NSF Conversation

For those of you unable to attend the Tips & Tools meeting last week, Kathryn Wrench’s presentations slides are available HERE.  If you were a part of the discussion, a couple of corrections were subsequently made to the information presented:

 

  • Resubmissions to NSF Programs: Resubmissions are considered new submissions by NSF, if substantially revised. If not substantially revised, the investigator risks return without review, or the Program Official may be kind enough to suggest that the proposal be withdrawn so that NSF does not need to take an adverse action. Some NSF Directorates explicitly prohibit resubmission within 1 year of the original submission, others do not. There is no formal standardized process for the entire organization. The NSF Proposal Review Process is accessible here. The Non-Award Decision actions are accessible here.
  • Salary Cap:  NSF removed their statutory salary cap around 1990. Keep in mind, however, that NSF has a general limit of 2 month’s pay for Senior Personnel. Although that rule is general, we go by it in budgeting unless the program would justify deviation with permission (there are some exceptions permitted to the 2 month limit). Apparently, the agencies that impose a cap are certain components of DHHS, including NIH $183,300, and DOD $952,308. The DOD and other cap provisions outside of DHHS apply to contracts only (more on that here).

 

If you have any questions about submitting an NSF proposal, Kathryn Wrench has indicated that she is happy to take your questions.  RAS is also here to help sort out the details!

Brace Yourselves: Forms D Are Coming

It’s that time again: the form sets for federal submissions are a-changin’.  Be on the look out: Forms D take effect for all submissions on May 25, 2016 and after.  There are, however, many changes that take effect before Forms D are released; these go into effect on and after January 25, 2016.  A version of the following table was handed out at today’s Tips and Tools meeting (PDF here).  Here it is, if you missed it:

 

ATTACHMENT   CHANGE
Biosketch Clarifications

NOT-OD-16-004

  • A URL leading to a publication list is optional, but must lead to a .gov website
  • Publications (peer-reviewed or not) and research products may be cited in both the personal statements and contributions to science.
  • Graphics, figures and tables are not allowed.
 

Effective for January 25, 2016 Submissions

Research Strategy

NOT-OD-16-011 and NOT-OD-16-012

 

New rigor and transparency guidelines will be given to reviewers.  This will affect the way the research strategy is reviewed.
Authentication of Key Biological and/or Chemical Resources

NOT-OD-16-004

 

This is an ENTIRELY NEW ATTACHMENT.
Vertebrate Animals

NOT-OD-16-006

 

  • Veterinary care description no longer required.
  • New guidance on necessary criteria (procedures, justifications, pain/distress minimization; euthanasia).

–    Euthanasia descriptions/justifications only required if not consistent with AVMA.

 

Inclusion of Children

NOT-OD-16-010

 

Age definition of “child” is now lowered from 21 to 18.
TRAINING: Recruitment and Retention Plan to Enhance Diversity

NOT-OD-16-004

 

The focus must be on recruitment.
TRAINING: Human Subjects

NOT-OD-16-004

 

 

  • Language must exist stating explicitly how Wayne State will ensure that trainees only participate in exempt human subjects research or non-exempt human subjects research that has IRB approval.
  • List of potential trainees and associated IRB information no longer required.
TRAINING: Vertebrate Animals

NOT-OD-16-004

 

 

  • Language must exist stating explicitly how Wayne State will ensure that trainees only participate in IACUC-approved vertebrate animal research.
  • List of potential trainees and associated IACUC information no longer required.
TRAINING: Progress Report

NOT-OD-16-004

 

No longer required to report on publications arising from work conducted by the trainee; this will now be requested for Just-in-Time.
 

Effective for May 25, 2016 Submissions – when FORMS D go into effect

TRAINING/FELLOWSHIP: Authentication of Key Biological and/or Chemical Resources

NOT-OD-16-004

 

THIS IS A NEW ATTACHMENT.  It will be required for all Research Plan, Career Development Supplemental, and Fellowship Supplemental sections.
TRAINING/FELLOWSHIP: Plan for the Instruction in Methods for Enhancing Reproducibility

NOT-OD-16-004

 

THIS IS A NEW ATTACHMENT.
Vertebrate Animals

NOT-OD-16-007

 

New questions regarding euthanasia added.
Planned Enrollment/Cumulative Inclusion

NOT-OD-16-004

 

More study descriptors will be added. Additional details will be available prior to the release of the new forms.
Data Safety Monitoring Plan

NOT-OD-16-004

 

THIS IS A NEW ATTACHMENT. This will be included with all clinical trials.
TRAINING: Tables

NOT-OD-16-007

 

 

 

  • Only 8 tables will be required (instead of 12) to minimize individual-level reporting.
  • Tracking of trainee outcomes will be extended from 10 to 15 years.
  • A new NIH system (xTRACT) is now available in eRACommons to help with table preparation.
Assignment Request

NOT-OD-16-008

 

 

This is a new OPTIONAL form.  It is utilized to uniformly request preference in institute, study section, potential conflicts, and necessary expertise.  This replaces the need for some information commonly written in an introduction.
Font Guidelines

NOT-OD-16-004

 

  • Size: 11 points or larger; smaller is acceptable in figures as long as it is legible at 100%
  • Density: no more than 15 characters per linear inch, including characters and spaces
  • Spacing: no more than six lines per vertical inch
  • Color: must be black. Color text in figures is acceptable as long as it is legible.
  • Recommended fonts: Arial, Garamond, Georgia, Helvetica, Palatino Linotype, Times New Roman, Verdana

You Don’t Own Me

Coming or going, the transfer of grant awards raises issues of mechanism and ownership (and territoriality!) for many PIs and administrators.  When considering grant transfers, it is important to keep in mind one central tenet: awards are made to institutions, not to PIs.  Even though the PI applies for the grant and does or directs the research, s/he is doing so on behalf of the institution.  Therefore, should a PI decide to change institutions, s/he must have the permission of the institution to take the grant award along (it is, of course, the prerogative of the institution to keep the project and assign new personnel to the research if it so chooses).  That’s where the relinquishing statement comes in.

 

A relinquishing statement is an official statement relinquishing interests and rights in a research grant; different agencies use different mechanisms for generating these statements.  For NIH, the process is initiated in eRA Commons by a signing official of the institution holding the award.  Other funding agencies who do not use eRA Commons have different mechanisms, so be sure to check for agency-specific guidelines.  NSF, for example, requires that the process be initiated by the PI through FastLane once an agreement has been reached by both the current and future grant holders, and requires the FTR (federal cash transactions report) at the time of the request. For detailed instructions on transferring grants from these two federal agencies, check out the NIH  transfer guide assembled by NIAMS, and section IIB2h of NSF’s PAPPG.

 

Our office has shepherded many a transfer, so feel free to reach out if you have any questions on transfer policy or procedure!

Sharing is Caring…

… about the future of your research.

 

Still adrift on the ocean of public access?  Dr. Akers in the Shiffman Library recently put together a clarifying resource!  Check it out on their site, and take a look at her data sharing policies for researchers too (hint: this is especially important if your research involves any genomic data!).  Remember: access to your data is a very important part of your funding obligations, so make sure you understand your responsibilities.  Questions? We’re here to help, and so is Dr. Akers!

Fringe Media

As you’re wrangling project budgets and preparing submissions, be aware that Wayne’s fringe rates have changed, as have some of the employee groups of job classes.  Think your PI is going to be 26.6%?  Think again; most investigators will fall under a fringe rate of 24.7%.  The biggest difference you will note is that research assistants will no longer have the same rate as faculty; most research personnel will now have a fringe rate of 33.2%.  This will significantly affect your budgets, so plan accordingly.

 

Take a look at the new composite fringe rates here, which are in effect for any proposal of project period starting after October 1, 2015 (eProp rates are being updated to reflect the changes). For a comparison to other years, Fiscal Operations keeps past composite fringe rates posted for reference.

Well, That Was Unexpected: PD/PI Credential Error

Federal government systems are constantly evolving, and sometimes what was fine yesterday is an error today.  During the submission process for an SF424 on Monday, we received the following error, even though the PD/PI eRA Commons ID was very clearly and correctly present in the proper field:

 

NIH has received the electronic grant application Grants.gov Tracking # GRANT00000000 / PI XXXXXXX. NIH was unable to process your application because it was missing critical information required by NIH. NIH requires that the PD/PI’s correct eRA Commons User ID be entered in the ‘Credential’ field for the PD/PI on the R&R Senior/Key Person Profile (Expanded) component of the application.

Because the Credential field was not completed accurately, your application was considered incomplete; therefore the eRA Commons could not fully check the application against the instructions in the application guide and the funding opportunity announcement. You may receive new error and/or warning messages once you submit a changed/corrected application to Grants.gov.

 

After some trial and error, and intrepid GCO found that re-entering the eRA Commons ID in all capital letters (‘GSMITH’ instead of ‘gsmith’) allowed the application to go through.  As a precautionary measure, you may wish to use all caps on your PD/PI credentials going forward!

Watch Your Asterisk

As the June 5 deadline approaches for NIH new R01s, take a moment to double-check your PDF file names (and make sure all of your attachments are PDFs, come to that). NIH systems can be touchy with unexpected character recognition, and no one wants an error at 4:58p next Friday. Remember: file names should be less than 50 characters, including punctuation and spaces. Names CAN contain any of the following characters:

  • A-Z
  • a-z
  • 0-9
  • underscore: _
  • hyphen: –
  • space
  • period
  • parenthesis
  • curly braces: { }
  • square brackets: [ ]
  • tilde: ~
  • exclamation point
  • comma
  • semicolon
  • at sign: @
  • number/pound sign: #
  • dollar sign
  • percent sign
  • plus sign
  • equal sign

 

Names CANNOT contain any of the following:

  • Two or more spaces in a row between words or characters
  • Ampersand: &
  • Apostrophe (note: the official NIH list of acceptable characters includes apostrophes, but we have encountered more than one error when using apostrophes so we recommend avoiding them)

 

Be safe: keep it simple!  For more tips on compliant file attachments, look over NIH’s PDF Guidelines.  Questions about what you’re reading? Drop us a note!

O, What A Tangled Web

No one likes to admit defeat, and most are not particularly excited to shout a mistake from the rooftops.  Self-protection is human nature, but covering tracks in research can land you in some hot water.  HHS defines “research misconduct” as ” fabrication, falsification and plagiarism, and does not include honest error or differences of opinion.” NIH has procedures in place to handle research misconduct claims, but ultimately no power to investigate (except in the case of intramural research).  All research misconduct allegations involving NIH awards (or any agency under the umbrella of HHS) are forwarded to the HHS Office of Research Integrity (ORI) for their oversight.  Just to be clear:

 

  • Fabrication is making up data or results and recording or reporting them.
  • Falsification is manipulating research materials, equipment, or processes, or changing or omitting data or results such that the research is not accurately represented in the research record.
  • Plagiarism is the appropriation of another person’s ideas, processes, results, or words without giving appropriate credit.

 

If a PI is found to have engaged in research misconduct, HHS can take action by means of debarment from eligibility to receive Federal funds for grants and contracts; prohibition from PHS service; certification of information sources by the respondent that is forwarded by the institution; certification of data by the institution; imposition of supervision; submission of a correction of published articles by the respondent; submission of a retraction of published articles; and more, including recalled funds and withdrawal of support for associated PIs.

 

WSU PIs are full of integrity and honor, but panic can blur a bright line. In your moments of most overwhelming, results-driven disappointment, make sure the object you cling to is a life raft and not an anchor.  ORI sanction happens (and just recently did), and it can ruin a career.

On-Again, Off-Again Relationship

Ah, the F&A rate portion of your awards: can’t live with them, can’t – quite literally – live without them.  The F&A rates here at WSU are variable as you well know (we’re in a 52.5% period on-campus right now), and that portion generated by awards is distributed according to the policies set forth in section 03-5 of the WSU Administrative Policy Manual.  Those funds pay the salaries, leases, capital projects, etc. etc. that keep our research infrastructure viable.  Many awards allow you to calculate and request F&A (or indirect costs) on top of a direct cost cap, but many do not.  When this is the case, that 52.5% can swiftly eat into your project budget.  That’s when the 26.0% off-campus rate sure starts to look good.  But when can you use it?

 

What is “Off-Campus” Research?

The definition of “off-campus” applicable to WSU is negotiated in our DHHS agreement. In our case, “off-campus” is agreed to mean:

 

For all activities performed in facilities not owned by the institution and to which rent is directly allocated to the project(s) the off-campus rate will apply.  Grants or contracts will not be subject to more than one F&A cost rate.  If more than 50% of a project is performed off-campus, the off-campus rate will apply to the entire project.

 

This is the standard for determining which rate you can use until our current agreement is renegotiated (in 2020, barring extenuating circumstances).

 

My research is done in a non-WSU facility; is it “off-campus”?

Whether your non-WSU facility research is considered “off-campus” is entirely dependent on the terms of your lease; the terms of your lease is the first place you should check.  If WSU is the responsible party for payment on your space, chances are you should be using the on-campus rate (as that cost is factored into the on-campus F&A rate).  If WSU is not the named responsible party, there is a possibility that the off-campus rate in effect at the time of submission could apply (be sure to build those costs into your proposal!).

 

Even after reading the contract, I’m not really sure who is responsible for my lease.  Who can help?

There are definitely murky circumstances, especially when it comes to leasing DMC space and our affiliation agreements. If you’re not sure,  be sure to contact SPA to find out how your space relates to certain existing blanket agreements. Once you’re sure, we can help you with any adjustments that may need to be made!

Permission to Land Short

In the season of RPPRs and changing budgets, we thought it might be a nice time to once again mention effort reduction on NIH projects.

 

Remember, if you are reducing the effort of key personnel on a grant, you need the permission of your NIH program officer if the amount of effort reduced is 25% or more.  The amount reduced is cumulative; that is, the 25% threshold may be reached by the reduction of two or more efforts per individual in successive project periods.  To revisit an example, take Dr. Alpha: he devotes 25% effort to a project, or 3.0 person months. If he reduces his effort by more than 25% of 3.0 months (which is 0.75 months), he needs permission to reduce.

 

So, if Dr. Alpha reduces his effort in Year 2 by 20% (0.6 months) to 2.4 months, he does not need to request NIH permission. If he reduces his effort again in Year 3 by 10% (0.24 months), he DOES need special permission at that point, because his effort has been reduced from the last approved level by 28%. This is where the “cumulative” term comes into play: once NIH has approved a reduction, all subsequent reductions are measured at 25% of the MOST RECENT approval (as opposed to consistent measurement against the first-year effort levels, if subsequent changes were made). For further details on the 25% thresholds, be sure to read the Section 8 of the NIH Grants Policy Statement. If you need some guidance on calculating your own thresholds, we’re always happy to help!