What Do You Want From Me? A Field Guide to SoM-Level Review

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:

 

  1. 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.

 

  1. 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.

 

  1. 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.”

 

  1. 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!

 

  1. 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.

Up, Up and Away: Salary Cap

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.

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 🙂

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!

 

 

Raising a Glass to Raising the Cap

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%)

= $1,670

And of course, don’t forget the fringes:

[Salary Cost Shared] x [Applicable Fringe Rate] = [Fringes Cost Shared]

[$1,670] x [26.6%]

= $444.22

 

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!

Pop a Cap in Your Salary

Most people know by now that the NIH cap on compensated salary has been raised to $181,500, and that all new proposals should reflect this number in their budgets.  Budgets, though, have two distinct fields that rely on this number; what exactly do you do with it?

  1. The “Institutional Base Salary” field. You have your choice on how to handle this field.  You may enter the actual institutional base salary (even if over the current NIH salary cap) OR, if your investigator would prefer not to reveal actual salary, you can input the cap number ($181,500) and add  an asterisk (*).  If you use an asterisk, provide an explanation in the budget justification that the researcher has elected not to include actual salary information and a statement that the institutional base salary exceeds the salary cap (if applicable). If this option is selected, PIs must still submit one copy of the application to NIH that does include the institutional base salary. SPA prefers that you state the actual salary in your explanation if you elect not to include it in the budget worksheet, as this satisfies the requirement.
  2. The “Salary Requested” field. If your investigator is over the salary cap, your salary requested is the effort percentage multiplied by the salary cap.  For instance, if your investigator’s institutional base salary (note: do NOT include attachment or additional assignment amounts) is $200,000 and s/he will be devoting 10% effort to the project, your salary requested is [10% x $181,500] = $18,150.

This, of course, brings us to voluntary uncommitted cost sharing.  If your investigator is over the NIH salary cap, this means that his or her department must absorb the difference; this is known as mandatory cost share. Cost sharing must be requested and documented before the application is submitted, and the form can be found here.  To calculate how much your will need to request in cost sharing in a single year, you will need to determine the investigator’s institutional base salary (from Banner NBAJOBS screen) and the amount of effort the investigator will be devoting to the project:

[Non-Allowable Salary in a Year] = ( [Investigator Institutional Base] x [Investigator Project Effort] ) – ( [NIH Salary Cap] x [Investigator Project Effort] )

So, using the example numbers from above for an investigator with an institutional base of $200,000:

[Non-Allowable Salary in a Year] = ($200,000 x 10%) – ($181,500 x 10%)

= $1,850

Don’t forget to request the applicable fringes in each year as well; these are also considered to be above the NIH salary cap.  In our example above, we would request the department to pick up the the Wayne State University fringe rate 26.8% in addition to the salary over the cap.  Fringes, then, would be calculated as $1,850 x 26.8% = $495.80  The departmental cost share request for the year we just calculated, then, would be  $1,850 salary + $495.80 fringes, for a total amount of $2,345.80 in that year.  This downloadable spreadsheet may help you in your calculations; don’t forget to calculate each year of the project separately if you have included projected salary increases or adjustments in effort percentages in different years.