1. Research Administration for Scientists Tim Quigg, Associate Chair and Lecturer Computer Science Department, UNC-Chapel Hill OMB Circular A-110: Administrative Requirements COMP 918: Research Administration for Scientists © Copyright 2011 Timothy L. Quigg All Rights Reserved

2. Research Administration for Scientists A-110: Administrative Requirements  Uniform administrative requirements for grants and agreements (not contracts) with institutions of higher education, hospitals and other non-profit organizations  Federal agencies shall not impose additional or inconsistent requirements … unless specifically required by law or executive order

3. Research Administration for Scientists Administrative Requirements for:  Financial Management Systems  Program Income  Budget and Program Revisions  Expanded Authority  Equipment  Intangible Property  Procurement Standards  Reports and Records (Performance and Financial)  Termination  Enforcement  Close-Out  Cost Sharing

4. Research Administration for Scientists Standards for Financial Management Systems  Accurate, current and complete disclosure of financial results by project  Effective control over funds, property and assets  Comparison of outlays with budget amounts  Written procedures to minimize the time elapsing between the transfer of funds from U.S. treasury and payment of program expenses  Written procedures to determine allocability and allowability of costs

5. Research Administration for Scientists Program Income “gross income earned by recipient that is directly generated by a supported activity or earned as a result of the award.” Examples:  Fees for services  Rental of property acquired under award  Sale of items fabricated under award

6. Research Administration for Scientists Program Income Consistent with agency regulations or the T&C’s of the award, Program Income may usually be retained by recipient and used in one or more of the following ways:  Added to project and used to further project objectives  Used to finance the non-federal share of project  Deducted from federal funds IMPORTANT: If you anticipate having program income, deal with it at proposal time!

7. Research Administration for Scientists Budget and Program Revisions Normally prior approval from awarding agencies is required for:  Change in scope or objective of project  Change in key personnel (specified in proposal and award)  Either absence for more than 3 months or a 25% reduction in effort by the PI  Need for additional federal funding  Transfer of funds between direct and indirect costs and from training allowances to any other category  Sub awards or contracting of any work unless included in application and approved in award

8. Research Administration for Scientists Waiver of Agency Approvals  Expanded Authority – agencies may allow recipients to develop their own systems (IPAS) for approving certain actions:  Incur pre-award costs 90 days prior to award  Expenses must be consistent with budget  Can go more than 90 days with agency approval  All pre-award costs are at recipient’s risk if award is not made  Initiate a one-time no-cost extension of the project period for up to one year  10 days prior to expiration date  Provide reasons (fund balance is not a reason)!  Carry forward balances to subsequent funding periods

9. Research Administration for Scientists Equipment “tangible, nonexpendable personal property charged directly to the award having a useful life of more than one year and an acquisition cost of $5,000 or more per unit. (Less if consistent with recipient policy)”  Title vests with recipient (usually)  When project ends, residual equipment must be used for:  Other projects funded by that agency  Other federally funded projects  Adequate property management system

10. Research Administration for Scientists Intangible Property Details the rights of recipients and the government with regard to:  Copyright – recipient may copyright any work developed under the award  Must grant a royalty-free, nonexclusive, irrevocable right to reproduce, publish or otherwise use the work for federal purposes or to authorize others to do so

11. Research Administration for Scientists Intangible Property  Patent – recipient may patent any invention developed under award (subject to 37CFR Part 401)  Government-use license  “March-In” rights  Research Data – obtain, reproduce, publish or otherwise use the data produced under award and authorize others to do so for federal purposes

12. Research Administration for Scientists Procurement Standards “procuring supplies, expendable property, equipment, real property and other services with federal funds.”  Codes of Conduct – Conflict of Interest  Competition – Open and free  Written Procurement Procedures  Utilization of small businesses, minority-owned firms and women’s business enterprises whenever possible

13. Research Administration for Scientists Program Performance (Progress) Reports: PI Responsibility  Performance reports (not less frequent than annual nor more frequent than quarterly)  Comparison of actual accomplishments with approved goals/objectives for period  Reasons why goals were not met (if applicable)  Other pertinent information including analysis of any cost overruns  Notification of any developments that may have a significant impact on the award-supported activities  Recipients shall monitor sub recipients (including audit requirements)

14. Research Administration for Scientists Financial Reports: usually completed by OSR  Financial Status Report (SF-269 or 269A)  Not less than quarterly or more frequently than monthly  Due 30 days after end of period  Report of Federal Cash Transaction (SF-272)  Used when funds are advance  Records retention - Three years from submission of final expenditure report

15. Research Administration for Scientists Termination  Award may be terminated only if one of the following applies:  By agency, if recipient materially fails to comply with T&Cs of award.  By agency with consent of recipient, if both agree on termination conditions and effective date.  By recipient upon written notification to agency setting forth the reasons and effective date. Partial terminations must be accepted by agency.

16. Research Administration for Scientists Enforcement  In cases where a recipient materially fails to comply with the T&Cs, the agency may:  Temporarily withhold cash payments  Disallow all or part of the cost of an activity  Suspend or terminate award  Withhold further awards  Awarding agencies shall provide recipient an opportunity for a hearing, appeal or administrative proceeding

17. Research Administration for Scientists Closeout Procedures  Recipients shall submit to agency within 90 days all financial, performance and other required reports  “ Sticky Issues”  Invention Report  Encumbered Expenses  Equipment

18. Research Administration for Scientists Cost Sharing “that portion of project or program costs not borne by the federal government (cash and third party in- kind).”  Verifiable in recipient’s records  Not included as contribution for any other federally-assisted project  Necessary and reasonable for proper and efficient accomplishment of project objectives  Allowable under applicable cost principles

19. Research Administration for Scientists Cost Sharing “that portion of project or program costs not borne by the federal government (cash and third party in- kind).”  Value for contributions of services and property must comply with applicable cost principles  Not paid by federal government under other award (a few exceptions)  Included in approved budget  NOTE: Unrecovered indirect costs may be used as cost share with prior approval of awarding agency

20. Research Administration for Scientists Types of Cost Sharing  Voluntary Committed, offered either in excess of mandatory requirement or when not a stated condition of the award  NOTE: Commitments in proposals become requirements in award!  Cost share provided from University sources is considered cash  Value of non-cash contributions provided by a third party is considered in-kind  Mandatory, required, condition of award

21. Research Administration for Scientists

22. Timing  Cost share must be expenditures incurred or services rendered during the period of award  Some agencies expect / require expenditures to occur at same pace as federal dollars

23. Research Administration for Scientists Examples of Cost Sharing  Employee time, including fringe benefits  Equipment  Volunteer time or other contributed items  Unrecovered F&A - if approved by sponsor  Subrecipient (or subcontractor) cost- sharing  Directly related supplies and services

24. Research Administration for Scientists Sources of Cost Sharing  University funds  Unrecovered Facilities and Administrative Costs  Third party contributions  Other Non-Federal Sponsored Projects (rarely allowed)

25. Research Administration for Scientists Unallowable Cost Share  Items not allowable under A-21  Items normally treated as Indirect  Specifically Unallowable Costs  Cost share used on other projects

26. Research Administration for Scientists Repercussions of Unmet Cost Share  Identify amount and proportion unmet  Identify programmatic effect  Notify agency immediately  Agency may require repayment of a proportionate share of grant funds Note: Unsatisfactory documentation may be treated as unmet cost share!

27. Research Administration for Scientists Recharge Centers A Recharge Operation is a facility, center, operation, function, account, or activity whose output is susceptible of measurement on a workload or other quantitative basis. The costs associated with these activities are separately accounted for and charged to users in proportion to services rendered. The primary purpose of a recharge operation is to provide specific services to the university community although services may be provided on an incidental basis to external users.

28. Research Administration for Scientists Examples  Copy Machine Charges  Glass Shop  Computer Services  Lab Animals  Electric Power/Utilities

29. Research Administration for Scientists Alternate Names  Service Center/Service Facility:  $50,000 - $1,000,000/year  Usually not university wide in scope  Special Service Facilities (SSF):  A-21 Section J.44 – “institutional services involving the use of highly complex or specialized facilities such as electronic computers, wind tunnels, and reactors …”  University-wide  > $1,000,000/year  Recharge Center:  < $50,000/year

30. Research Administration for Scientists Characteristics  The costs of each service must include its direct costs; and when appropriate, its allocable share of facilities and administrative costs.  The cost of each service should be directly billed to users based on a schedule of rates that does not discriminate between federally and non- federally supported activity.  Break even operation – rates should not recover more than the total costs of the center over a long-term period. A period is normally defined as one year.

31. Research Administration for Scientists Relationship BTW F&A and Recharge Center Operation/Costs Certain costs such as the cost of capitalized equipment should be included in either the facilities and administrative costs proposal or in the rates of a recharge operation. If the cost for the same piece of equipment is included in both the proposal and a recharge operations rate there is the potential that the federal government could be double charged for the same cost.

32. Research Administration for Scientists Equipment Capitalization  Depreciation prorates a portion of the cost of “capitalizable” equipment to each period the equipment is in use. In other words, even though the recharge operation pays for a piece of equipment in full during the year of acquisition, the recharge can only include in its rates the depreciation amount attributable to the current year.  Automobiles – 4 years  Computers – 6 years  All other equipment – 10 years

33. Research Administration for Scientists External Users  Commercial entities; and students, faculty, or staff acting in a personal capacity (versus in their student or employee role within the University).  Inappropriate outside use of recharge facilities could jeopardize The University of North Carolina at Chapel Hill’s tax-exempt status.  Umstead Act