School of Medicine-level review in the proposal queue has been around for a while now, but long cycles of funding can prevent even the most well-funded among us from subjection to our scrutiny. And, as in all protocols sponsor-related, new compliance elements are being added all the time. Here’s a quick-reference guide on what we’re looking for, and why:
- The full proposal. We have to see what is going to the agency, even if internal budgets are provided. This way, we can say “yes, we knew that this is what Dr. X communicated to the sponsor, and we can support that with necessary School of Medicine resources.” If you are using the system-to-system submission feature through Evisions, your full proposal is already included! If your proposal needs to be submitted by other means (such a sponsor website), use the “Print to PDF” or similar feature to save a copy of the proposal, and upload the PDF to the “Attachments” section of the Evisions record.
- For subcontracts: if WSU is the subcontractor, we don’t need the prime proposal, but we do need the letter of intent to subcontract, and the supporting documents that are being submitted to the prime recipient institution.
- Your internal budget. If you are doing a detailed budget on a system-to-system submission, you’re probably covered. If, however, you are submitting a budget overview or a modular proposal, we need to verify that the funds requested are commensurate with planned funding. This also helps us check for cost share.
- Cost share commitment forms. Speaking of cost share, any cost share commitment forms must be uploaded to the “Attachments” section of the Evisions record. If there is a cash match commitment in the proposal, there must be evidence of the agreement of the match source uploaded. In addition to the uploaded forms, choose “YES” on the Evisions “Proposal Budget” page as the answer to “Cost Sharing.” This will reveal the ability to enter cost share information, such as department and index, so that the cost sharing department can verify their commitment to the cost share.
- For over-the-cap: In pre-award, we do not require a fully-executed cost share commitment form for the amounts over-the-cap (no Dean signature, no Fiscal Affairs signature) but we do require a department signature for awareness documentation. Please also provide the index that will fund the cost share. Note: over-the-cap cost share is considered “Voluntary.”
- OnCore accountability, or waiver: If you have human subjects, you have to either include OnCore fees in your budget, show how you will be cost sharing the fees, or upload a waiver to “Proposal Attachments.” Waivers are obtained from the Clinical Research Service Center, whether your project is clinical or not. Unfamiliar with the policy? Check out the handbook!
- Correct coding. Evisions coding is super important! The data that is input at this phase is the basis for a whole host of reporting that affects such things as department rankings and investigator credit. To be sure that you are getting full and accurate credit for the submission, be sure the “General Information” is input correctly; take a look at our coding table for guidance, or ask us if you’re not sure.
- Investigator credit: This is done on the “Personnel Roster” page of the Evisions record. If your investigator has a retreat to more than one department, s/he will have to be listed twice (or as many times as s/he has appointments) and the credit split proportionally between departments. Confused? Give us a shout.
Most of what we need to see is what your GCO also needs, with a few additions and for different reasons. We’re not here to duplicate SPA review; we’re here to ensure the School of Medicine can support your project in a compliant way. Remember: it’s extremely important to route your proposal before submission! This way, every source of manpower and resources on your project is aware and on board. The result? Fewer headaches at award time, and more credit where credit is due.
Check your budgets, folks! The Office of Personnel Management has released increased executive level compensations caps effective January 7, 2018.
- Your new salary cap: $189,600.
If you are awarded with a budget that did not included the new cap, you’re welcome to rebudget using the new cap within the limitations of the award, but no new funds will be given by the agency. If you’re submitting for the March 16 NIH deadline (hello out there, R03/R21 resubmissions and renewals!) now is a great time to revise those budgets and any associated cost sharing.
As always, drop us a note at RAS@med.wayne.edu with any questions, and take a look at the notice for more details.
Cost sharing is the art of dedicating effort to a project and getting someone else to pay for it (usually the University). It’s nuanced. It’s subtle. It can drive you crazy.
A true cost share is one in which the effort dedicated is not entirely paid for by the project, usually to alleviate a budget. In order to save you some time, please know that it is very, very rare that these types of cost shares are getting approved nowadays if general funds is involved, here at the med school. Over-the-cap cost share, of course, is picked up as a matter of policy; these are those situations in which grant personnel make a higher salary than the agency cap ($187,000 as of this post, for most federal agencies) and Wayne State needs to pick up the difference. If you’re looking for how to do those calculations, check out our post from February 26, 2014 (note that the salary cap has been raised since then).
In order to help your cost share experience go as smoothly as possible, here are some general questions and answers to help you figure out your next move:
- Is this cost share request solely for over-the-cap charges?
- If your answer is yes, you do not need chair and dean signatures in the pre-award phase, only just-in-time. You do, however, need to make the calculations and note the amount and index in Evisions/SP. We have a brief tutorial on that, too.
- If your answer is no, you need a fully-executed cost share form.
- Who needs to sign the cost share form in order to be considered “fully executed?” The cost share for must be signed by the chair of the department of the cost share request, School of Medicine Fiscal Affairs, and the School of Medicine Vice Dean for Research, in that order.
- There are instances where a business official may sign in the place of the department chair. In order for a business official to proxy for a chair, the Office of the Vice Dean for Research must have a memo on file granting this proxy. This memo must have an end date (so it remains reviewable and renewable in turnover phases), and must specifically mention cost share signatory authority. These memos can be filed with our office.
- What percentage goes in the “Effort %” box on the form? The title of this box is misleading; this is actually a space for the percentage of the investigator’s salary that will be cost shared. You can clarify the percent effort dedicated to the grant in the comments box. For instance: if an investigator has a salary of $250,000 per year and will dedicated 10% effort to a project, the percentage of her salary to be cost shared is: [($250,000-$187,000)/$250,000]*10%, or about 2.5%. That is the number that will go in the box on the form.
To help illustrate these principles, we’ve provided a few examples of redacted, approved cost share forms from our friends in Fiscal Affairs. We also have our handy over-the-cap calculator to help save you same time. As always, please feel free to contact us for guidance. Happy calculating!
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 🙂
While it is your prerogative to choose your index when cost sharing is a necessity, you need verification from several sources that your chosen account will support your intention. Whether your salary is over the cap or sharing is mandated by your announcement, your cost share form (available here, if you need it) needs to pass through a few hands during the preaward phase before it is valid. If you are in the School of Medicine, here are the approvals you need before it goes to SPA:
- Your department chair. This is the signature that goes on the “Unit Head” line. This ensures that your department is aware of the intent to cost share, should the funds get awarded, and is committed to your plan to do so.
- Fiscal Affairs. Though no line is present for the Fiscal Affairs signature, it has been made clear that they need to see and approve your cost share plan at both the pre- and post- stage. This generally goes through the Grants & Contracts Officer in Fiscal Affairs (see their contacts page to make sure you are sending it to the right person).
- Vice Dean for Research. One your cost share form has been returned to you from Fiscal Affairs, you’ll need to send it to the Vice Dean of Research through the Director of Research Administrative Services (that’s us!). Once the intent to cost share has been recorded here, you’ll get it back with a signature (again, no line on the form for this but it IS necessary) and you can then upload into your eProp.
Please keep in mind that if/when your proposal is awarded, you will need approval from Fiscal Affairs a second time; they need to verify that the funds you intended to use for your cost share are still available. We know this can be a confusing and lengthy process, so please feel free to contact us if you have any problems discerning where to go or projecting accurate figures for your form. We’re always happy 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!