Expanded Clearinghouse Pilot February 2016 – June 2017 (UNC-CH joined Cohort 2: August 18, 2016 – June 2017) 1 We’ve been selected to join a national demonstration.

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Presentation transcript:

Expanded Clearinghouse Pilot February 2016 – June 2017 (UNC-CH joined Cohort 2: August 18, 2016 – June 2017) 1 We’ve been selected to join a national demonstration pilot project!

Remember how the FDP FCOI Clearinghouse saved pass-through entities and subrecipients from having to swap written confirmations that we each had PHS- compliant FCOI policies? ( ) Now we welcome its big sister: The FDP Expanded Clearinghouse! 2

Goal of Pilot Reduce administrative burden associated with verifying standard information required for subrecipient issuance and monitoring Eliminate swapping of subrecipient commitment forms completed on a transaction-by-transaction basis in favor of accessing an on-line, up-to-date standardized, streamlined subrecipient data repository (an “entity profile”) Determine whether such a repository effectively reduces the data collection and review burden for or pass-through entities and subrecipients alike 3

Contents of Profile Entity Information Demographic Information (name, address, type, small business status, parent information, etc.) Entity Identification Numbers and Codes Entity Rate Agreements Department of Defense Registration Numbers Department of Education Registration Numbers Assurances and Agency Approvals (Accreditations) DOD/ONR System Reviews Entity Key Contacts 4

Contents of Profile (continued) Entity Certifications Conflict of Interest Debarment and Suspension Lobbying Affirmative Action Compliance FFATA Single Audit Information (will eventually also include Financial Questionnaire option) Single Audit Status & Links Core info about any findings, deficiencies, material weaknesses Entity Official Certification 5

Core Elements of Pilot Institutions participate as both a subrecipient and as a pass- through entity Participants formally agree to terms of the Pilot (done) Participants create their Entity Profile (done) FDP posts each participant’s Entity Profile (completed and available as of today, August 18th) PTEs access their participating subrecipients’ on-line Entity Profile in lieu of sending a subrecipient commitment form for each subaward between the parties (throughout the pilot) Transaction-specific information may still be shared Participants track how many subwards are transacted via this mechanism (OSR will track throughout the pilot, reported quarterly) Participants evaluate the pilot (at least twice) 6

At Time of Proposal Still acceptable & expected to collect from the Subrecipient at time of proposal: Statement of Work Budget Any other forms needed for the proposal Small business plans, biosketches or other support, certifications required at time of proposal, etc. Subrecipient’s proposal endorsement Signature of the Subrecipient’s SPA office and/or indication they are willing to enter into a subaward if proposal is funded 7

Process Changes to Plan For When We are the Subrecipient: DO NOT COMPLETE a Subrecipient Commitment Form for a pass-through entity participating in the pilot Instead, please remind the other institution that we are a pilot Expanded Clearinghouse institution – see sample language on the next slide Please be kind - remembering that many pilot institutions are large and decentralized – so it may take awhile for this updated process to filter down to all parts of the organization. 8 When We are the Pass-through Entity: DO NOT COLLECT a Subrecipient Commitment Form from another participating pilot institution

Sample Language for Pushing Back if you are asked to complete a Subrecipient Commitment form by another pilot institution “I am writing to let you know that the [YOUR OWN INSTITUTION’S NAME] is a pilot participant in the FDP Expanded Clearinghouse. It is my understanding that your organization is also a pilot participant. As a part of the pilot, both our organizations have agreed that effective August 19, 2016, we will not send or require completion of a subrecipient commitment forms, but will instead use our profile that is posted on-line at the FDP Expanded Clearinghouse site ( 219)” 9

At Time of Proposal or Award Okay to ask for or to complete a “transaction- specific” request but only for data elements NOT included on the entity profile, such as: Human subjects approval for that project Animal subjects approval for that project 10 Getting pushback? Talk to X or Y (Subaward Team)

11 Participating Institutions – Cohort 1 Augusta University Research Institute, Inc. Brandeis University Brown University (WG) California Institute of Technology Cedars-Sinai Health System Dana-Farber Cancer Institute Duke University Florida State University (WG) Georgia Institute of Technology Harvard University Harvard Medical School Harvard T.H. Chan School of Public Health Icahn School of Medicine at Mount Sinai (WG) Institute for Systems Biology (ERI) (WG) Johns Hopkins University (WG) Michigan Technological University New York University, Washington Square Campus Northern Illinois University (ERI) Northwestern University – Chicago Campus (WG) Northwestern University – Evanston Campus (WG) Oregon Health & Science University Partners – Brigham and Women's Hospital Partners – Massachusetts General Hospital Partners – McLean Hospital Purdue University (WG) Syracuse University Tufts University – Health Sciences Campus (Boston) Tufts University – Medford/Somerville Campus University of Alabama University of Alabama, Huntsville (WG) University of Arkansas for Medical Sciences University of Cincinnati University of Florida University of Kansas Center for Research, Inc. University of Kansas Medical Center Research Institute, Inc. University of Miami – All Campuses Dept of Education University of Miami – Coral Gables Campus University of Miami – Miller School of Medicine University of Miami – Rosenstiel School of Marine & Atmospheric Science University of Minnesota – Crookston University of Minnesota – Duluth University of Minnesota – Morris University of Minnesota – Twin Cities (WG) University of South Alabama (ERI) University of Tennessee Health Science Center University of Tennessee, Knoxville University of Texas Medical Branch at Galveston University of Texas at Austin (WG) University of Washington (WG) University of Wisconsin-Madison (WG) Vanderbilt University (WG) Vanderbilt University Medical Center Washington University Wayne State University

12 Participating Institutions – Cohort 2 Arizona State University Case Western Reserve University Clemson University Colorado State University Cornell University Emory University Florida A&M University (ERI) Florida International University Indiana University Indiana University Medical Center Iowa State University Massachusetts Institute of Technology Medical University of South Carolina Nevada System of Higher Education (Sponsored Programs Office) Nevada System of Higher Education – Desert Research Institute Nevada System of Higher Education – University of Nevada, Las Vegas Nevada System of Higher Education – University of Nevada, Reno North Caroline State University Northeastern University Pennsylvania State University The Pennsylvania State University College of Medicine Research Foundation for the State University of New York – Stony Brook University Rockefeller University Stanford University Texas Tech University University of Alabama, Birmingham University of California, Berkeley University of California, Davis University of California, Irvine University of California, Los Angeles University of California, Riverside University of California, San Francisco University of Central Florida University of Colorado, Boulder University of Hawaii University of Idaho University of Illinois, Chicago University of Kentucky University of Maryland, Baltimore University of Maryland, College Park University of Massachusetts, Medical School University of Michigan University of Missouri University of Nebraska-Lincoln University of North Carolina, Chapel Hill University of Notre Dame University of Pittsburgh University of Rochester University of Texas Health Science Center at San Antonio University of Texas at Dallas (ERI) Yale University

Next Steps The FDP has gone live with Cohort 2 entity profiles today so we will “Go-Live” with the pilot tomorrow, August 19 th. Effective August 19, 2016: Please do not collect or complete subrecipient forms from participating institutions (for proposals that include a sub, check the pilot lists and if participating, verify through the clearinghouse profile. For proposals in which we are the sub, do not complete a subrecipient form if the Prime is participating in the pilot) At time of award, OSR and SPO will use the EC to obtain the information you need to issue a subaward or to do a risk assessment for participating institutions (more details coming) OSR has been asked to do our subaward tracking You may be asked to participate in evaluations, as appropriate 13