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Jeff Warner Contract and Grant Officer Danielle VandenBos Esq. Contract and Grant Officer FEDERAL UPDATE Spring QRAM - Monday, March 14, 2012
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NIH Fiscal Policy - FY 2012 NRSA Budgetary Levels NIH Efficient Spending – Conference Gants NIH Resubmissions NIH – LikeThis DHHS – Salary Limitation NIH E-Submission Supplement Requests Important ARRA Information E-Verify FAR Clause NSF Senior Project Personnel Multiple PI Assurance DoD – Enhanced IRB Requirements Sponsor Climate in Washington Subaward Proposal Package Spring QRAM - Monday, March 14, 2012 FEDERAL UPDATE AGENDA:
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Non-competing awards will be issued without cost of living/inflationary adjustments in FY 2012 and inflationary increases for future year commitments will be discontinued for all competing and non-competing research (SPA recommends to continue to budget proposals with these increases). However adjustments for special needs (such as equipment and added personnel) will continue to be accommodated. FY 2012 awards that have already been issued will be revised to adjust the award level and future year commitments in accordance with these principles. Spring QRAM - Monday, March 14, 2012 NIH FISCAL POLICY FOR GRANT AWARDS – FY 2012 NOT-OD-12-036
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This Notice establishes new stipend levels for fiscal year (FY) 2012 Kirschstein-NRSA awards for undergraduate,predoctoral, and postdoctoral trainees and fellows (i.e. issued on or after October 1, 2011). Tuition, fees and training-related expenses for trainees and institutional allowances for Fellows remain unchanged. All FY 2012 awards issued using FY 2011 stipend levels will be revised to increase the stipend category to the FY 2012 level. For institutional training grants already awarded in FY 2012, if trainees have been appointed to the FY 2012 budget period, the grantee institution must amend those appointments to reflect the FY 2012 stipend level once the revised award is received. Spring QRAM - Monday, March 14, 2012 RUTH L. KIRSCHSTEIN NATIONAL RESEARCH SERVICE AWARD (NRSA) STIPENDS, TUITION/FEES AND OTHER BUDGETARY LEVELS EFFECTIVE FOR FISCAL YEAR 2012 NOT-OD-12-033
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Effective with grant awards issued on/after January 27, 2012, a new term and condition which prohibits food/meal costs from being supported or charged to NIH-supported conference grants will be included: “Direct charges for meals/food and beverages are unallowable charges to this project.” The new policy applies to awards supporting a Conference and/or Scientific Meeting (i.e. R13s and U13s); however, other grant mechanisms that are specifically issued to support conferences will be considered on a case by case basis. For conference grants previously awarded with FY2012 funds, NIH will not revise the award to modify the terms and conditions of the grants. Spring QRAM - Monday, March 14, 2012 NEW NIH POLICY ON EFFICIENT SPENDING RELATED TO GRANTS SUPPORTING CONFERENCES AND MEETINGS NOT-OD-12-041
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Resubmission– A proposal submitted to make a significant change (e.g., scope of work, budget, facilities, subawards, etc.) to a previously submitted proposal not yet funded by the sponsor and where the sponsor requires submission of a revised full proposal. Please remember to include the previous proposal number in section 5 of the AA Form. Please remember to include the Federal Identifier in the applicable section of the SF 424 (4A). The Federal Identifier is the Institute Code and Serial Number assigned to the previous submission (ex. CA123456). This number is available in the eRA Commons. Spring QRAM - Monday, March 14, 2012 NIH RESUBMISSIONS
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LikeThis is a new search tool to aid Principal Investigators in finding and learning about other research projects that have similar goals and objectives as their own. By entering specific scientific terms or accessing their own grant applications or grants and clicking on LikeThis, investigators will be provided a listing of similar funded projects and/or publications. LikeThis is available from the eRA Commons home page under the Additional Links section along the right side of the page. Spring QRAM - Monday, March 14, 2012 NIH - LIKETHIS (A THESAURUS-BASED SEARCH TOOL)
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LikeThis provides a powerful and integrated search tool in a user friendly interface. With the ability to find similar projects and publications, Principal Investigators can more quickly and efficiently: find out new ideas for research based on what NIH has awarded in the past; see what NIH is doing in his or her area of interest; use the information as a decision tool to determine if they need to come up with a fresh research idea; and figure out in which study section his or her application should be reviewed. Spring QRAM - Monday, March 14, 2012 NIH - LIKETHIS (A THESAURUS-BASED SEARCH TOOL)
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The Department of Health and Human Services (“DHHS”) budget signed on December 23, 2011 includes a reduction in the salary cap from Executive Level I ($199,700) to Executive Level II ($179,700). Budget periods awarded using previous fiscal year funds use the salary cap that was in effect for that particular fiscal year. The salary cap does apply to all subawards and subcontracts. Please note that the Executive Level II salary cap will apply to all DHHS entities, not just NIH and AHRQ. However, NIH and AHRQ are the only agencies that have issued implementation guidance. We will forward additional guidance as it becomes available. Spring QRAM - Monday, March 14, 2012 SALARY LIMITATION ON GRANTS, COOPERATIVE AGREEMENTS AND CONTRACTS FROM NIH AND AHRQ NOT-OD-12-035 & NOT-HS-12-007
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When the issue date of an award is on or before December 22, 2011 initial issue date of an award is on or after December 23 If the award is a non-competing renewal AND initial issue date is on or after December 23 The following will apply: The FY 2012 award will remain at the $199,700 salary cap and the following years will be adjusted downward to the $179,700 cap or the cap in effect when the new non-competing renewal is issued.non-competing renewal The $179,700 salary cap will apply. If the award is a new or competing award, NIH will issue a revised Notice of Award, adjusting the award and the following years to reflect the new salary cap. The new cap applies but NIH will not adjust the award. Principal Investigators may re-budget the “funds freed as a result of the lower cap” into other budget categories. Future non-competing renewals, however, will be at the salary cap of Executive Level II in effect at the issue date of the renewal.budget Spring QRAM - Monday, March 14, 2012 SALARY LIMITATION ON GRANTS, COOPERATIVE AGREEMENTS AND CONTRACTS FROM NIH AND AHRQ NOT-OD-12-035 & NOT-HS-12-007
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UCI Implementation: Sponsored Projects has modified its awards synopsis so that the Contract and Grant Officers can advise departments on which salary cap applies to awarded funds from DHHS agencies. The award synopsis contains a code in the upper right hand corner that indicates either “Exec LvL I” or “Exec LvL II.” Spring QRAM - Monday, March 14, 2012 SALARY LIMITATION ON GRANTS, COOPERATIVE AGREEMENTS AND CONTRACTS FROM NIH AND AHRQ NOT-OD-12-035 & NOT-HS-12-007
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Administrative Supplement requests may now be submitted through either the eRA Commons or Grants.gov, as described in NOT-OD-12-024 (notification of the availability of the two pilot processes), or through the existing, paper-based process.NOT-OD-12-024 NIH has published the first administrative supplement FOA (Funding Opportunity Announcement). This FOA (PA-12-100) is available for prior approval requests to nearly all active grant awards. PA-12-100 NIH will soon also publish FOAs for Research Supplements to Promote Diversity. Once published, applicants are encouraged to use one of the two new electronic processes. Spring QRAM - Monday, March 14, 2012 NEW ELECTRONIC SUBMISSION PROCESS NOW AVAILABLE FOR ADMINISTRATIVE SUPPLEMENT REQUESTS NOT-OD-12-043
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Pilot System for Forms-Based Submissions through Grants.gov: Applicants choosing this method will need to complete a full supplement application package using the SF424 (R&R) forms available on Grants.gov. They will need to provide information in all required fields, and provide additional information justifying the supplemental dollars. Spring QRAM - Monday, March 14, 2012 NEW ELECTRONIC SUBMISSION PROCESS NOW AVAILABLE FOR ADMINISTRATIVE SUPPLEMENT REQUESTS NOT-OD-12-043
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Pilot System for Streamlined Supplement Requests through eRA Commons: PDs/PIs and AORs will login to the eRA Commons, identify the parent award that a supplement is being requested for, and prepare an administrative supplement request.eRA Commons The system will utilize data from the previous award and pre- populate as much of the request as possible. Applicants only need to provide information justifying the supplement. Spring QRAM - Monday, March 14, 2012 NEW ELECTRONIC SUBMISSION PROCESS NOW AVAILABLE FOR ADMINISTRATIVE SUPPLEMENT REQUESTS NOT-OD-12-043
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On September 15, 2011, the Office of Management and Budget (OMB) issued Memorandum M-11-34, “Accelerating Spending of Remaining Funds from the American Recovery and Reinvestment Act.” Budget The memo directed Federal agencies to accelerate the spending of ARRA funds as a way to support the President's ongoing efforts to "drive the economy forward and create jobs” and to take steps to complete Recovery Act projects by September 30, 2013. The National Institutes for Health (NIH) and the National Science Foundation (NSF) have provided separate guidance on meeting the accelerated spending goal.NIH Spring QRAM - Monday, March 14, 2012 IMPORTANT INFORMATION REGARDING ARRA AWARDS
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For awards scheduled to end on or BEFORE September 30, 2013 If a no-cost extension is necessary, it must be requested by JUNE 1, 2012, regardless of the end date of the award. no-cost extension Grantees may still exercise their one- time, grantee-approved no-cost extension as long as the period of performance with the extension does not extend beyond September 30, 2013. period of performance However, if a Principal Investigator requires an extension beyond September 30, 2013, he/she must follow the guidance for “awards that are scheduled to end after September 30, 2013.” For awards that are scheduled to end AFTER September 30, 2013 If a no-cost extension is necessary, it must be requested by June 2, 2012. The NIH Grants Management Officer for the award must be notified in writing via the appropriate Contract and Grant Officer in Sponsored Projects of the request for an extension. The request for extension must explain why an extension of the project is vital for its completion. Spring QRAM - Monday, March 14, 2012 IMPORTANT INFORMATION REGARDING ARRA AWARDS – NIH GUIDANCE
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If a no-cost extension is necessary, it must be requested by June 2, 2012, regardless of the end date of the award. no-cost extension Grantees may still exercise their one-time, grantee-approved no-cost extension as long as the period of performance with the extension does not extend beyond September 30, 2013. period of performance The deadline for an extension past September 30, 2013 was March 2 nd. Awards that are scheduled to end AFTER September 30, 2013, were required to submit their plan to accelerate completion was due to the Program Official on March 2 nd. NSF will amend awards to ensure that the period of performance does not extend beyond September 30, 2013 in order to comply with the OMB memorandum Spring QRAM - Monday, March 14, 2012 IMPORTANT INFORMATION REGARDING ARRA AWARDS – NSF GUIDANCE
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Sponsored Projects strongly encourages Principal Investigators to responsibly accelerate spending on their ARRA awards to the greatest extent possible because waivers are not guaranteed. Spring QRAM - Monday, March 14, 2012 IMPORTANT INFORMATION REGARDING ARRA AWARDS
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Effective September 8, 2009, all employers who receive specific federal contracts are required to comply with E-Verify, an Internet-based system operated by the Department of Homeland Security (DHS) in partnership with the Social Security Administration (SSA). The E-Verify program provides an Internet-based means of verifying employment eligibility of workers employed in the United States. E-Verify electronically compares information contained on the Form I-9 with records contained in the Social Security Administration (SSA) and DHS databases to verify the identity and employment eligibility of employees. Spring QRAM - Monday, March 14, 2012 FAR CLAUSE: E-VERIFY REQUIREMENT 52.222-54
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UC, as a federal contractor, must verify qualifying new and existing employees, including employees who may be assigned through a transfer to a qualified federal contract/subcontract. Grants are not subject to the federal rule, only qualified federal contracts/subcontracts. The E-Verify process must be done in a nondiscriminatory manner and, in the case of new hires, only after the individual has accepted an offer of employment and completed the Form I-9. Please see all UC E-Verify Guidelines here: http://snap.uci.edu/viewXmlFile.jsp?resourceID=4365 Spring QRAM - Monday, March 14, 2012 FAR CLAUSE: E-VERIFY REQUIREMENT 52.222-54
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NSF limits salary compensation for senior project personnel to no more than two months of their regular salary in any one year. This limit includes salary compensation received from all NSF- funded grants. If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award. Spring QRAM - Monday, March 14, 2012 NSF - SENIOR PROJECT PERSONNEL SALARIES & WAGES POLICY
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The Administrative Approval (“AA”) form contains the NIH PI assurance. Thus, all UCI Principal Investigators on a Multiple Principal Investigator NIH application must sign the Administrative Approval (“AA”) form. Only the Chair/Dean/Director signatures are required from the Lead/Contact PIs administering unit. For NIH’s 2590 progress report, the PI assurance statement must be retained for all named PI’s on the project. For all prior approval requests, each PI on project must endorse the request. Spring QRAM - Monday, March 14, 2012 MULTIPLE PI ASSURANCE
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In 2006, the Department of the Defense (DoD) enhanced its human subject protection requirements, including the application of those requirements to extramural performers. UCI has signed an assurance with the DoD which requires that UCI apply DoD regulations and policies for the protection of human research participants when conducting, reviewing, approving, overseeing, supporting or managing DoD supported human subject research. Sponsored Projects conducts a protocol match prior to issuing synopses; if it is found these extra requirements are not met, SPA will hold the award. Please see guidance concerning these requirements here: http://www.research.uci.edu/ora/hrpp/deptOfDefense.htm Spring QRAM - Monday, March 14, 2012 DOD – ENHANCED IRB REQUIREMENTS
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Please ensure all prior approval requests are routed through Sponsored Projects prior to submission. All Federal Agencies are under new scrutiny to focus on all areas of non-compliance and unallowable costs. NIH is pushing for more timely submissions of Just-in-Time requests. As there are fewer funds available to support NIH administrative staff, the JIT review process is taking more time which results in longer delays in receiving funds. The Air Force Office of Scientific Research recently published a memo clarifying their No Cost Extension policy. Their policy allows for extensions; however, they are only issued in situations where they are both properly documented and truly warranted. These requests are considered on a case-by-case basis. Spring QRAM - Monday, March 14, 2012 SPONSOR CLIMATE IN WASHINGTON
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Subrecipient Commitment Form: All Subrecipients must complete this form when submitting a proposal to UCI. Detailed Scope of Work Detailed Budget and Justification Spring QRAM - Monday, March 14, 2012 SUBAWARD PROPOSAL PACKAGE
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Should you have any questions, please feel free to contact your Contract and Grant Officer. Jonathan Lew: 949-824-3029 or jlew@uci.edujlew@uci.edu Alison Yeung: 949-824-2644 or alison.yeung@research.uci.edualison.yeung@research.uci.edu Danielle VadenBos Esq.: 949-824-7109 or vandenbd@uci.eduvandenbd@uci.edu Leighsa Washington: 949-824-2460 or lrwashin@uci.edulrwashin@uci.edu Jeff Warner: 949-824-4781 or warnerj@uci.eduwarnerj@uci.edu Spring QRAM - Monday, March 14, 2012 CONTRACT AND GRANT OFFICERS
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