FREE SLIDERS

If you came here looking for ways to get your hands on some delicious mini-burgers, this post is not for you.

 

If, however, you’re looking for a way to simplify unallowable cost determination under the Super Circular, rejoice!  Cost-allocation software company CostTree is giving away handy pocket sliders to aid you in your cost determination quests (and if you’re not into print materials, they have a digital version, too).

 

To get yours, head on over to the CostTree request site and input your vitals.  It’s helpful, it’s nice-looking, and it’s free for the low, low cost of being added to a mailing list.  Happy allocating!

No Such Thing as a Free NCE

In case you missed it, Joe Schumaker wrote a good piece this month aligning requests for no cost extensions with the classic Dickens novel, Oliver Twist.  Here’s your bottom line: there can only be one (yes, that was a Highlander reference riffed from a Dickens reference.  All about the classics today, folks).

 

NIH provides an “expanded authorities” clause in almost all Standard Terms of Award that waives the requirement for prior approval No Cost Extension (NCE), among other actions.  If the text of the award allows, the grantee is permitted one NCE (that is, to extend the final budget period of a grant’s project period by up to 12 months, with no new funds).  This is usually done within 90 days of project end, when the Extension link appears in the “Action” column of the “Status” search results screen. Anything beyond that one request will require permission.

 

As NIH adjusts NCE guidelines to meet the requirements outlined in the Uniform Guidance, they have audibly noticed an increasing trend of people asking for NCEs in the middle of the project period. You can do this, but this is your one shot.  That is: if you get a permitted NCE in the middle of your project period, you won’t see your Extension link at the end of your project period;  you’ve already used your expanded authority, even though you had to obtain permission to do so.  Further, if you choose not to use the entire allowable 12 months (like you ask for, say, a 4 month extension), you can’t ask for the remainder of what’s allowable (8 months, in this case) without permission: it still counts as a second extension.

 

So, Warriors, be careful what you wish for; beyond that, know what you’re wishing for.  If you’re unsure of your best strategy, let us know: we’ll help you talk it out and figure what’s best for you!

 

 

Guidance on Guidance for the Guidance

Greetings, research community!  As a follow-up to our Wednesday post, we’d like to draw your attention to a new resource on our homepage: Uniform Guidance Changes for 2015.  In this document, we’ve highlighted the major changes and how they might affect your proposals going forward.  Let us know if you have questions!

The Very Model of a Modern Major General Conditions Guideline

The NIH announced on February 5, 2015 their guide to NIH-specific implementation of the Office of Management and Budget (OMB)’s Uniform Guidelines (UG), in place since December 26, 2014.  The NIH Interim Grant General Conditions apply to all new and supplemental funding provided by Notices of Award issued on or after December 26, 2014; they contain no surprises if you’ve been keeping up with the road to implementation!  If you need a refresher on how we got here, take a look at some of our older posts, like Super Circular, Super Fun, which highlights some of the new provisions in the UG; and Ch-Ch-Changes, which also has a link to the NIH Administration Timeline.

 

To comb over the NIH Interim Guidelines yourself, the full document can be accessed here.  These will be in effect until an updated NIH Grants Policy Statement is published (which won’t be until after the HHS comment period closes).  NIH has provided a frequently asked questions page regarding the interim guidelines, on which you may be able to find an answer to any general questions you may have.  If your question is more specific than an FAQ page can handle, give us a try!  We’re always happy to help with interpretation and applicability!

 

Update: 03/05/15

Looking for some information on what, exactly, has changed? Check out our handy Uniform Guidance Changes: 2015 page!

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!

 

 

Ch-Ch-Changes

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!

Your Vacation Could Be a Real Turkey

The issue of unused leave at retirement or termination has been a real eyebrow-raiser at the institutional level when it comes to the new Uniform Guidance.  There was language added in the UG – which was NOT in the proposed guidance – regarding a cash basis of accounting, making unused leave payments allowable as an indirect cost. But salary and fringes have always been treated as direct costs; is this an inconsistency?  Does this mean that other funding mechanisms are not?  What are the implications if it is over the 26% cap?  How does this affect accrual-based institutions (like Wayne State)?

 

Some suggestions have been made that include negotiating with the cognizant agency (in our case, DHHS) to put this benefit into the fringe rate, to be charged to all sources of funding.  Is this legitimate?  What do you think?  Take a look at the video provided by NCURA, see if you recognize and of WSU’s policies in the discussion, and be on the lookout for changes as more clarity is provided on UG: