Federal Panel: Q&A/Discussion NACCA - Leading Excellence in Research Costing Practices General Conference: 10/3 – 10/5, 2017

Questions: F&A Topic Area 1. Submission of F&A Rate Proposals – EFLOW Process: The PowerPoint presentation Arif Karim provided at last year’s NACCA conference mentions an EFLOW process for submitting F&A rate proposals in the Spring of 2017. Is this something new? We have been sending the proposals electronically to the CAS email address.  We were wondering if something is changing or if the Spring of 2017 was the deadline for all universities to submit electronically.  Do you have any additional information on this? 

Questions: F&A Topic Area 2.   Reassignments of F&A Proposals to other HHS CAS offices: Our institution’s most recent F&A proposal submission was shifted from the assigned CAS office to another region for review and negotiation. Do you see this as a trend going forward?

Questions: F&A Topic Area 3.  Regarding the UG F&A rate extensions: Should an institution request an extension (up to four years) at its current predetermined rate even if it suspects it may not be anywhere close to that rate when it submits a proposal in four years?   In other words, does the “review and approval of the cognizant agency” required by 200.414(g) involve a justification of being able to sustain the existing rate? Is there any risk that the government may take action if they determine there has been an over-recovery during the extension period on a predetermined rate?

Questions: F&A Topic Area 4.  F&A Rate Negotiations with Subrecipients Assume a pass-through entity negotiates an F&A rate with a Subrecipient because the Subrecipient does not have a federally-negotiated F&A rate agreement and does not wish to use the de Minimus rate. What types of information/documentation should the pass-through entity require from the Subrecipient to support the negotiation of the rate? How should the pass-through entity protect itself from potential unallowable costs or other potential problems with the rate?

Questions: F&A Topic Area 5.  Utility Cost Adjustment For applying the Relative Energy Utilization Index (REUI) when calculating the UCA, can any of the following be considered “research laboratory space” – greenhouses, dry research labs, research offices where research is conducted in lieu of in a laboratory? For applying the REUI, can utility-related costs (e.g., maintenance of utility systems, staff working in power plants, etc.) be included in the utility pool? The industry best-practice is to fully burden utility rates with all properly allocated expenses. Are we expected to have one set of rates to charge auxiliaries and a different set for the utility cost pools for F&A?

Questions: F&A Topic Area 6.  F&A on Genomic Arrays: One issue we've not heard much about in recent months is the limit of F&A on genomic arrays. Has there been any update to this policy? https://urldefense.proofpoint.com/v2/url?u=http-3A__grants.nih.gov_grants_guide_notice-2Dfiles_NOT-2DOD-2D10-2D097.html&d=DwIF-g&c=imBPVzF25OnBgGmVOlcsiEgHoG1i6YHLR0Sj_gZ4adc&r=Xl4DPKHuIlzIQA2pS1psvpRmxlxKbuNZiBr6AFx1bao&m=j9jd_YPbdUNxDMTf__M8-cfan5nuSy4Z7wnbQL6mp48&s=u8UpqmxjgQMTKrOQqYXGfRE6AO3cr5JbFfrciSpG2xQ&e=  

Questions: Cost Sharing Topic Area 7. Definitions & Interpretations of UG Sections 200.29; 200.99 & 200.306. What are best practices & recommendations on treating, tracking/monitoring cost share when it’s not mandatory, but is stated (in $$ or effort – measurable & in writing) in the submitted proposal, e.g., in the scope of work, or other resources & facilities section, though not in the budget section?  Plus, when such type of a "cost share” is not specifically referenced in the actual award document.

Questions: Cost Sharing Topic Area 8. A faculty commits two months of paid effort in the proposal budget for a federal research award but later decides to charge the federal award for 1 month only, while still working on the project for 2 months. If a non-federal source is charged for the second month of salary, would you consider this cost sharing? If not, does it still need to be considered part of the base?

Questions: Cost Sharing Topic Area 9. Would you consider quantified effort promised in a proposal with no associated dollar amounts, cost sharing?

Questions: Effort Reporting Topic Area 10. Please provide pilot payroll certification updates, including the results of the most recent audit reports; best practices & recommendations for internal controls.

Questions: Effort Reporting Topic Area 11. NIH Pioneer awards - compliance issues with respect to the requirement that faculty detail their committed effort as a percentage of their “protected research time.” - How is “protected research time” defined? - What is required to “detail” their effort? Awards are submitted without a budget; if awarded, PIs are required to commit a major portion (at least 51%) of their research effort to activities supported by the award. Is summer effort counted? Effort expended toward teaching, administrative, or clinical duties should not be included in this calculation

Questions: Other Areas 12. Software Capitalization Level What is the guidance? We’ve heard that the best practice was for an IHE to use $25,000,but based upon what guidance? Do we need to consider changing this based upon UG definitions? Should we be looking at other guidelines as well? §200.33 Equipment. Equipment means tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-Federal entity for financial statement purposes, or $5,000. See also §§200.12 Capital assets, 200.20 Computing devices, 200.48 General purpose equipment, 200.58 Information technology systems, 200.89 Special purpose equipment, and 200.94 Supplies. §200.58 Information technology systems. Information technology systems means computing devices, ancillary equipment, software, firmware, and similar procedures, services (including support services), and related resources. See also §§200.20 Computing devices and 200.33 Equipment.

Questions: Other Areas 13. Unused Leave Payments Does FAQ UG 200.431-2 (charging payments of unused leave to employees terminated or retiring) affect universities? Universities aren’t listed (only state, local, and Indian Tribal governments are listed). In the latest UG FAQ, UG 200.431-2 says that state, local, and Indian Tribal governments using the cash basis of accounting must charge unused leave as a general administrative expense. However, 200.431 deleted the requirement to charge these costs as indirect costs when using the cash basis of accounting.

Questions: Other Areas 14. Publication Costs What was the thought process for singling out publication costs after the period of performance but prior to closeout? This can cause some last minute scrambling at closeout to still ensure all costs are accounted for and drawn by having this exception and requires additional documentation for audit to explain why this one type of costs can be incurred after the project period end date. See next slide for UG language…..

Questions: Other Areas 14. Publication Costs (Cont.) §200.461 Publication and printing costs. Publication costs for electronic and print media, including distribution, promotion, and general handling are allowable. If these costs are not identifiable with a particular cost objective, they should be allocated as indirect costs to all benefiting activities of the non-Federal entity. Page charges for professional journal publications are allowable where: The publications report work supported by the Federal Government; and The charges are levied impartially on all items published by the journal, whether or not under a Federal award. The non-Federal entity may charge the Federal award before closeout for the costs of publication or sharing of research results if the costs are not incurred during the period of performance of the Federal award.

Questions: Other Areas 15. Equipment: When a sponsored project is terminated and a federally purchased equipment item vests with the University, is the University required to report back to the federal government on the sale of the equipment with a fair market value > $5,000 or is this requirement limited to when the award is active?

Questions: Other Areas 16. Controlled Unclassified Information NIST 800-171: Which awards must comply by December 31, 2017? Application to DOD contracts vs. all contracts/ all sponsored awards? Timing etc. How to ensure that central administration is informed when a PI receives CUI?

Questions: Other Areas 17. Research Data Storage: As data storage has moved to electronic mediums there seems to be more questions about how long to retain data and the costs of doing so. Uniform guidance clearly addresses financial records but research data seems to default to HIPPA, FISMA and other regulations. Are there specific requirements to how long research data must be stored and when there are grant specific requirements how do you pay for fees after the period of performance is over. PI's was to pre-pay for services which is frowned upon. What is the trend you are seeing on how to account for these costs; are institutions moving towards service centers/chargeback systems, direct charging of projects or absorbing within their IT services budget as part of F&A recovery?

Questions: Other Areas 17. Research Data Storage (Cont.) The new NIST requirements as well as other data storage requirements have placed a heavy burden on IHE infrastructure. We have several questions regarding these costs: We recognize there should be a defined level of IT infrastructure that is an indirect cost supported by F&A funds. For storage costs above the normal baseline of IT infrastructure do you think it is appropriate to charge these costs direct to grants? If yes, is it more appropriate to direct charge these costs through a service center, through the purchase of the specific equipment used for storage or some other method? If through an equipment purchase, do you consider this equipment general purpose or special purpose equipment? Some grants require storage of research results for years after the grant has ended. If the charge is through a service center, is it allowable to direct charge the grant for future storage costs before the grant ends?