Say Hello, Waiver Goodbye

In a department, administrators and PIs have a lot of room to negotiate with other institutions when it comes to budgets involving awards and subcontracts.  Personnel effort?  That’s a classic.  Materials and supplies?  Probably your first stop.  Indirect cost percentage?  Slow your roll, holmes.

 

If the project is federally-sponsored, chances are slim that you’ll be successful in  your quest F&A reduction below our negotiated 54%*.   There are times when a lower F&A rate is acceptable without waiver/permission; for instance, the funding opportunity announcement caps the rate at lower than our negotiated rate, or the award is being transferred from another entity with direct cost equivalency.  Anything else requires a waiver with approval from the Vice Dean and SPA.  You cannot negotiate a reduced F&A on your own.

 

Here at Wayne State, the waiver request process begins with an IDC Waiver form. The Research Administrator and the PI should initiate the request, and it must be approved by the PI, the department chair, and the Vice Dean for Research before being sent for approval to SPA. The Vice Dean for Research will consider requests for Indirect (F&A) cost waivers in very limited circumstances, so be sure your justification is sound.  Here are some examples that may be considered on a case-by-case basis:

  • Capped awards
  • Seed grants which may attract larger awards
  • Only available source of funds in an area
  • Strategic partnerships
  • Awards which include equipment or building funds

 

If you’re just trying to make a proposal look more competitive, or  the PI/department failed to submit the proposal via approved institutional channels (e.g., through the Vice Dean or SPA) prior to submission to the sponsor, you’re out of luck.  Wayne State’s acceptance of an award with an unapproved F&A reduction does not constitute acceptance of the rate.  If you are awarded with a reduced F&A that was not properly approved, you must renegotiate at the time of award, otherwise the department will be responsible for cost-sharing the portion of the F&A not paid by the sponsor.

 

Questions?  You know where to find us!

 


* 54% is our federally-negotiated rate at the time of this post.

Cayuse Your Own Adventure: Cost Share Edition

Now that February 6 has come and gone, most everyone has had experience with what we’re looking for at the brand-spankin’-new School of Medicine level of approval.  One of our major review points is cost share, and whether an index has been identified if it exists.  Not sure how to record that on the SP side of Evisions?  Don’t fret; you’re not alone.  Here is a step-by-step guide to recording your index for approval (click on images to see full mark-up):

 

1. Go to proposal budget:

 

2. Find “Cost Sharing” heading; choose “Yes”

 

3. When the cost sharing options box appears, choose “Voluntary”

 

4. Choose “Salary Cap.” Enter the amount of cost share. Refer to calculations in the comments line. Don’t forget to actually upload the cost share calculations document to “Proposal Attachments.” (Note: SoM is not requiring signatures for over-the-cap cost sharing at this time.)

5. Click the “Add Unit” link to assign your department to cost share and record the index. Use the search icon to find your department. Note: you can add more than one unit of account if you are splitting the amount between departments or accounts.

 

 

6. Choose “Add Unit” once the appropriate information has been entered.

 

7.  Congratulations! You’ve added your cost share record to your proposal.

 

 

(Don’t forget to insert the number into the budget line by scrolling all the way down to the bottom of your page, so you don’t get the nasty error message.)

Let us know if you have any problems; we can walk you through it 🙂

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!

COFAR, So Good

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!

 

 

You’re Certifiable

It’s that time of year again: effort reporting and certification is upon us.  Wayne State relies upon effort reporting for faculty and staff on grants to confirm that salaries and wages charged to sponsored projects are reasonable for the agreements in place and the actual work performed.  Without effort reporting and certification compliance, financial penalties and expenditure disallowances could result.

 

In order to help navigate the effort certification system, the folks at CLAS put together some very helpful materials:

 

And for further reading on the process itself, check out SPA’s effort reporting page.  If you have any difficulty with the system or figuring out who needs to certify whom, RAS has been there and can offer guidance!

No Agreement, No Rate, No Problem

When utilizing subcontracts on a proposal, occasionally we run into domestic institutions who have no negotiated federal rate agreement.  This means (among other things) that there is no F&A rate.  If the subcontracting institution doesn’t require administrative overhead in their role on the project, it’s not necessary to grant them these costs.  But what if they do require administrative costs?  Scientists gotta science, administrators gotta administer!

 

For cases like these, there is a minimal threshold set by the federal government for institutions with no negotiated rate: it has been 8%, but has been increased by the OMB Uniform Guidance to 10% for domestic institutions, effective December 26, 2014 (as stated in Section 200.110).  We have been successful here at using the 10% rate on proposals as of late.  To view the full text of the Final OMB Uniform Guidance regarding the increase of the de minimis threshold, take a look at Subpart E, 200.414 on the Federal Register site.  For a breakdown interpretation of the language (for this and other changes), check out the table produced by The Huron Consulting Group, or our post entitled “Super Circular, Super Fun“!

 

RAS is here to help if you have any questions on how to budget your subcontracts with no negotiated rate.  Feel free to reach out if you need us!

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.