PROPOSAL REVIEW 101: What You Need to Know to Be a Pre- Award Research Administrator YOUR FACILITATOR FOR TODAY: Brigette Pfister, MHRD, CRA Director of Sponsored Programs for Humanities & Sciences, Virginia Commonwealth University LEARNING OBJECTIVES Identify and develop crucial skills for the pre-award research administrator. Plan your own professional development related to the crucial skills identified. Review proposals for compliance with applicable rules, regulations, laws, and policies. Communicate effectively with faculty on policy and regulatory issues. Prepare proposals for submission with a minimum of problems or stress. AGENDA Introductions/ Burning Questions Sponsored Program Basics How Pre-Award Works Crucial Skills for Pre- Award Research Administrators Rules and Regulations How to Review a Proposal Budgets Communicating with Faculty INTRODUCTIONS AND BURNING QUESTIONS Tell us: Your Name Your Institution How long have you been a research administrator? What are your burning questions? SPONSORED PROGRAM BASICS: GRANTS VS. GIFTS Sponsored Program There is a quid pro quo Deliverables are required F&A (indirect) costs are provided by sponsor policy Official acceptance is required Specific time frame Application is in response to a solicitation Gift or Donation No exchange of mutual consideration Funds are irrevocable Donative intent is clearly implied Acceptance does not require the University to change magnitude or direction of its current efforts SPONSORED PROGRAM BASICS: GRANT LIFE CYCLE Image courtesy of University of Delaware University of Delaware SPONSORED PROGRAM BASICS: INSTITUTIONAL STRUCTURES Really Centralized There can be only one OSP! (OSP does everything) Centralized Departmental staff do proposal development, and OSP does all pre- award processing Decentralized Most/many pre-award tasks happen in depts/units, but OSP handles final submissions Really Decentralized All pre-award, including submission, happens at dept/unit level. OSP handles award negotiations SPONSORED PROGRAM BASICS: PRE-AWARD VS. POST- AWARD Pre-Award Proposal Preparation Proposal Budgeting Proposal Submissions Award Negotiations Revisions Continuations No-Cost Extensions RPPRs and Progress Reports Post-Award Account Setup Day-to-Day Accounting Invoicing Financial Drawdowns Financial Reporting Effort Reporting Closeout HOW PRE-AWARD WORKS Generates ideas Creates proposal Notifies Dept/College RA Discusses project with Department Chair Faculty Proposal Development Reviews and Approves Sends to OSP Department or College Final Review Final Approval from AOR Final Submission to Sponsor Central OSP PRE-AWARD TIMELINE FOR REVIEW How long does a good pre-award review take? How many proposals can each individual handle at once? How is your workload divided? How experienced is your team? Your faculty? Insufficient lead time is THE #1 stressor of research administrators! The answer: Your Timeline Policy! COMMON PRE-AWARD PITFALLS Insufficient lead time Insufficient training Research administrators Faculty Department staff Poor business practices Inefficiencies Ill-defined institutional policies Missing documentation Subaward materials Consultant letters Principal Investigators If they didnt read the sponsor guidelines If theyre indecisive If they waited to start writing until deadline week CRUCIAL SKILLS FOR RESEARCH ADMINISTRATORS Reading Comprehension Critical Thinking Filtering the Important from the Noise People Skills Judgment Computer Skills Math Communication Time Management READING COMPREHENSION The ability to read text, process it, and understand its meaning 2CFR : Clerical and Administrative Salaries: The salaries of administrative and clerical staff should normally be treated as indirect (F&A) costs. Direct charging of these costs may be appropriate only if all of the following conditions are met: 1. Administrative or clerical services are integral to a project or activity; 2. Individuals involved can be specifically identified with the project or activity; 3. Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and 4. The costs are not recovered as indirect costs. CRITICAL THINKING the intellectually disciplined process of actively and skillfully conceptualizing, applying, analyzing, synthesizing, and/or evaluating information gathered from, or generated by, observation, experience, reflection, reasoning, or communication, as a guide to belief and action clear, reasoned thinking involving critique Dan Kurlands FILTERING THE IMPORTANT FROM THE NOISE The first few years in research administration has been compared to drinking from a firehose Each set of regulations may span 100+ pages Each proposal will involve sponsor guidelines from pages Each institution has policies that may total 100+ pages How do you determine whats important in each situation?? PEOPLE SKILLS The ability to communicate effectively with people in a friendly way, especially in business. The term people skills is used to include both psychological skills and social skills JUDGMENT An opinion or decision that is based on careful thought The act or process of forming an opinion or making a decision after careful thought : the act of judging something or someone The ability to make good decisions about what should be done COMPUTER SKILLS Knowing how to use that machine they give you to work on Microsoft Office Excel, Word, PowerPoint Adobe PDF Professional Accounting Software PeopleSoft, Banner Database Software InfoEd, ClickCommerce, Cayuse, KualiCoeus Sponsor Systems Grants.gov, FastLane MATH SKILLS The ability to work with numbers Operations Addition, Subtraction, Multiplication, Division Fractions and Percentages Algebra Solving for x Khan Academy COMMUNICATION The act or process of using words, sounds, signs, or behaviors to express or exchange information or to express your ideas, thoughts, feelings, etc., to someone else TIME MANAGEMENT The act or process of planning and exercising conscious control over the amount of time spent on specific activities, especially to increase effectiveness, efficiency or productivity It is a meta-activity with the goal to maximize the overall benefit of a set of other activities within the boundary condition of a limited amount of time TAKING CHARGE OF YOUR PROFESSIONAL DEVELOPMENT Research Administration Career Paths Central -> Departmental Departmental -> Central Pick One and Stay There Compliance Universities, Nonprofits, Hospitals, Military And SO MANY MORE OPTIONS DEVELOPING YOUR SKILLS Overall: Practice, Practice, Practice! Listen and Learn Take Advantage of ALL Available Training Including CITI, Responsible Conduct of Research, etc! Ask to Sit in at Meetings Find a Mentor Someone who has already been where you want to go Someone respected in the field Someone who you get along with and enjoy talking to HOW TO REVIEW A PROPOSAL: WHAT YOU NEED TO KNOW BEFORE YOU START Rules & Regs Before 12/26/14 2CFR220 Cost Principles for Educational Institutions Formerly OMB Circular A-21 2CFR215 Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations Formerly OMB Circular A-110 OMB Circular A-133 Audits of States, Local Governments, and Non-Profit Organizations Rules & Regs After 12/26/14 2CFR200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Also known as: Uniform Guidance (UG) OMB-zilla A-81 HOW TO REVIEW A PROPOSAL: WHAT YOU NEED TO KNOW BEFORE YOU START Cost Accounting Standards CAS Consistency in Estimating, Accumulating, & Reporting Costs CAS Consistency in Allocating Costs Incurred for the Same Purpose CAS Accounting for Unallowable Costs CAS Cost Accounting Period RULES AND REGULATIONS: FEDERAL Human Subjects Belmont Report: Ethical Principles and Guidelines for the Protection of Human Subjects of Research Belmont Report 45CFR46: Basic HHS Policy for Protection of Human Research Subjects 45CFR46 Animal Care and Use HEALTH RESEARCH EXTENSION ACT OF 1985 PUBLIC LAW HEALTH RESEARCH EXTENSION ACT OF 1985 Animal Welfare Act RULES AND REGULATIONS: FEDERAL Intellectual Property Overview from Sanford Encyclopedia of Philosophy Overview Bayh-Dole Act, P.L Bayh-Dole Act, P.L Export Control International Traffic in Arms Regulations (ITAR) International Traffic in Arms Regulations Export Administration Regulations (EAR) Export Administration Regulations Office of Foreign Assets Control Regulations (OFAC) OFAC websiteOFAC website RULES AND REGULATIONS: STATE Each state has its own set of rules and regulations These may be different from the federal regulations RULES AND REGULATIONS: YOUR INSTITUTION Your Institutions Policies Faculty effort on research projects Course release Cost sharing and matching Timeline for review F&A Rate Agreement/Fringe Benefits Use of off-campus rates and more EXERCISE: WHAT WOULD YOU DO? HOW TO REVIEW A PROPOSAL Gather Materials Sponsor Guidelines Proposal Documents HR information on the PI and other participants Sponsor Forms and Templates References (2CFR200, institutional policies, etc) GET ORGANIZED Start a Notes File or Comment Log Use a File System that works for you Keep everything together Make it difficult to lose things READ THE SPONSOR GUIDELINES The #1 rule: RTFM Read the Fine Manual! Why? It tells you exactly what the sponsor is looking for The PI may not have read it or may not understand it If the proposal is not compliant, it will not be reviewed You will need these skills: Reading Comprehension Critical Thinking Filtering the Important from the Noise READ THE SPONSOR GUIDELINES Look For: Eligibility rules Deadlines Funding Restrictions F&A costs Funding minimums or maximums Budget categories the sponsor will not fund Terms and conditions Contract language Ask Yourself: Is my institution eligible? Is this a good fit for the PIs research? Is this a good fit for my institution? Are there other documents I need to review? NSF, NIH, USDA, and others have additional info available! OUR FORMS, OUR LIVES Internal Forms Processing Forms Clinical Research Documentation Internal Budget Worksheets Sponsor Forms SF424 FastLane Forms Sponsor-Specific Forms REVIEW THE NARRATIVE MATERIALS: LOOK FOR.. Format Does it meet the specifications in the guidelines? Are all of the documents present? Are all of the subject areas addressed? Suggest using the guidelines as a template! Organizations or people named as partners Are they receiving funds? Endorsing the project? Depending on involvement, you may need a letter from them! REVIEW THE NARRATIVE MATERIALS: LOOK FOR.. Implied Cost Share Dr X will spend 15% of his time on this project when there is no effort in the budget We will leverage $50,000 for this project in the form of volunteer time All cost share must be documented in the budget! Hidden Commitments New lab space! probably needs to be vetted with the department chair first! Typos, Grammatical Errors Yes, PhDs make them all the time Yes, you should say something REVIEW THE NARRATIVE MATERIALS: LOOK FOR.. Human Subjects: Medical procedures Psychological testing or treatment Surveys Focus Groups Using human tissue or cells: make sure you know where its coming from! Animal Care and Use: Vertebrate animals Anything with a spine Kittens, puppies and fluffy bunnies count! Insects do not count! Not just lab animals some studies involving observation of wildlife must be reviewed, too! REVIEW THE NARRATIVE MATERIALS: LOOK FOR.. Hazardous Materials: Radioactive Materials Recombinant DNA Biohazards Select Agents Pathogens Viruses Some bacteria, etc Any point in which the proposal narrative strays from the focus suggested by the guidelines Is the project a good fit? If not, is there another opportunity that would be better? EXERCISE: SAMPLE NARRATIVE WHAT IS A BUDGET? The financial story of your project Two parts: Budget form Itemized list of costs Budget narrative Description of costs How they were calculated Why they are important REVIEWING THE BUDGET You will need these skills: Judgment Math Skills Computer Skills Critical Thinking REVIEW THE BUDGET: LOOK FOR Check all calculations Pay special attention to F&A calculations Make sure the numbers in the budget narrative match those on the budget forms Make sure all items of cost are allowable Make sure all items are properly categorized Salary and fringe benefits should be budgeted separately If graduate assistants are budgeted, their tuition should usually be budgeted too Make sure documentation is present for consultants, subawards, equipment, etc REVIEW THE BUDGET: UNDERSTANDING ALLOWABILITY Sponsors award to many types of organizations who operate under different cost principles Universities Nonprofits Hospitals Individuals Corporations In order to be allowable, a cost must Conform to Cost Principles (2CFR200) Necessary Reasonable Allocable Conform to institutional policy Consistently treated Be budgeted in an appropriate budget category DIRECT AND INDIRECT COSTS Indirect Costs (F&A) costs incurred for common or joint objectives and..cannot be identified readily and specifically with a particular sponsored project..or other activity. (A-21, E.1) Direct Costs costs that can be identified.. with a particular sponsored project..or that can be directly assigned to activities relatively easily with a high degree of accuracy. (A-21, D.1.) DIRECT AND INDIRECT COST EXAMPLES Indirect Costs (F&A) Some Administrative Salaries and Wages Office Space General and Office Supplies And more.. Direct Costs Salary and Wages Fringe Benefits Travel Equipment Supplies And more.. COST SHARE The portion of a projects cost that is paid by the institution or another (non-sponsor) party Types of Cost Share: Mandatory Voluntary Committed Voluntary Uncommitted Cost Overrun COST SHARE RULES Same Allowability rules as Direct Costs Necessary Reasonable Allocable Costs must be incurred during the same project period Must be verifiable from institutions records Must be in support of the same project Funds can only be cost shared once Federal funds generally cannot be used as cost share, especially on another federal project! COST SHARE: WHY NOT? Cost Share Myths: It will make proposals more competitive Usually doesnt unless sponsor specifies It impacts reviewers funding decisions They may not even see it! What Cost Share Really Does: Lower the institutions F&A recovery Use up scarce resources Create additional administrative burden BUDGET CATEGORIES Salaries and Wages Fringe Benefits Materials and Supplies Equipment Travel Consultants Subawards Participant Support Patient Care Other Costs Tuition Usage fees Rent Et cetera BUDGET CATEGORIES Salary and Wages Usually the largest cost category Includes faculty effort, Postdocs, Students, etc Everyone paid by your institution Must have associated fringe benefits in the budget Generally Unallowable: Housekeeping IT staff Research administrators, etc 2CFR BUDGET CATEGORIES Fringe Benefits Negotiated with federal government alongside our F&A rates Must be budgeted for all direct salaries and wages There are usually several rates Faculty/FT Summer/PT Students To Calculate: Individuals salary on the project x Fringe Rate BUDGET CATEGORIES Travel Costs Necessary and reasonable Typical travel budgets include: Airfare/transportation Lodging Per Diem Registration Unallowable costs that can be travel related: Alcoholic beverages Entertainment Dry cleaning BUDGET CATEGORIES Travel (continued) Domestic or International? Foreign Travel usually requires approval from the university at minimum before the travel happens 2CFR Potential issues: Duty of care: the university has to know where its people are located when on official business Export control: travel may be restricted or you may not be able to take certain items/info with you BUDGET CATEGORIES Equipment Federal definition: $5000 or more per item, with useful life of more than one year Always get a quotation! Things often erroneously budgeted as equipment: Computers Cameras Chainsaws Not kidding. Seriously. BUDGET CATEGORIES Materials and Supplies Tangible property Meant to be consumed or used up Must be allocable! Generally Unallowable: Office supplies Furniture General use computers Food BUDGET CATEGORIES Consultants Cant be faculty at your institution Your faculty must be budgeted in Salary & Wages Limited participation in the project Only party who stands to profit or lose from participation In business for themselves Consultants must: Submit a signed letter with the rate and total dollar amount BUDGET CATEGORIES Subawards Usually another university or legal entity Partner on the project with substantial involvement Subaward package includes: AOR-signed letter or face page (SF424 or PHS398) Scope of work Budget and budget narrative CVs for key personnel Any other information required by the sponsor CONSULTANT OR SUBAWARD? Consultant Is in business for him or herself Stands to profit or lose from participation Limited part of project Must be external to your institution Full F&A is calculated Subaward Handles a substantial piece of the project Rules and Regs flow down F&A is calculated only on the first $25,000 BUDGET CATEGORIES Patient Care Mainly found in clinical trials Cost of caring for human subjects Both patient care and participant support costs are exempt from F&A Participant Support Items or funds that go directly to program participants Incentives for research subjects are not necessarily participant support! Training materials BUDGET CATEGORIES Other Costs Rent for off-campus space Postage Printing Costs Long distance telephone Advertising Tuition costs for graduate students Equipment usage fees Software TOTAL DIRECT COSTS All of these budget categories equal your Total Direct Costs The amount your PI will be able to spend, in other words.. MODIFIED TOTAL DIRECT COSTS MTDC = Total Direct Costs Exclusions Equipment Tuition Amount of each subaward in excess of initial $25,000 Patient Care Participant Support Rent Capital improvements (construction, etc) SALARY AND WAGES BASE If your institution uses a salary and wages base, you would calculate your F&A on the Salary and Wages total rather than calculating MTDC. INDIRECT COSTS F&A (Indirect Costs) Rates are negotiated with the federal cognizant agency DHHS or ONR Classifications Research, Training, or Other On-Campus or Off- Campus To Determine Which Rate To Use: Look at your institutions NICRA What type of project is it? Where is the work taking place? SPONSOR-LIMITED F&A RATES A sponsor may only pay a certain percentage, or may not allow F&A at all Must be in writing Must be an actual policy that applies to all Examples: NIH F31 fellowships do not separately reimburse F&A US Dept of Education limits F&A to 8% INDIRECT COST CALCULATIONS Calculate Total Direct Costs Calculate Modified Total Direct Costs Multiply the MTDC by the applicable F&A rate Indirect Costs = Rate x Modified Total Direct Costs (MTDC) TOTAL BUDGET CALCULATION Total Budget = Total Direct Costs + Indirect Costs Most common error: using MTDC instead of total direct costs! You have completed your proposal review! Youre not done yet, though! Now you have to communicate with your PI to resolve issues. COMMUNICATING WITH FACULTY Summarize your notes in anto the faculty member Numbered list One issue per number Tell them about all changes Make sure they know what action is needed This gives you: A running to-do list for you and the PI Clear documentation of where the proposal is in the process THE WORLD OF FACULTY A PhD takes an average of 8.2 years to complete A scientist then may do a postdoctoral appointment of 2-4 years Faculty start at Assistant Professor on the tenure track, with hopes of eventually making it to Full Professor There are reviews and checks along the way, but generally they have 3-5 years to earn tenure If they are denied, it can be career ending (or at least career changing) Getting a grant is often a condition of tenure, as is a certain number of publications THE WORLD OF FACULTY Faculty lives revolve around three areas: Teaching Classes, classes, and more classes Research Conducting experiments, developing projects, writing proposals, and writing scholarly papers Service Serving on committees, chairing committees, etc This amounts to hour weeks in some cases No overtime Very little support Departmental politics can cause stress BUT they have academic freedom and can spend their time on the subject matter they are passionate about! THIS GRANT COULD MEAN Tenure for the faculty PI Jobs for the postdocs, graduate students, and others listed in the budget Development of new research or technology that could change the world Every grant is a big deal, in other words! THINGS TO REMEMBER: Faculty are people, too Diversity Culture Life outside the academe You are on the same team Be professional But its okay to be friends Your Credibility and Integrity are of utmost importance! Know what youre talking about before you engage! EGOS AND UNFRIENDLY TYPES Assume Positive Intent Take Nothing Personally Understand that it comes with the territory Dont take the bait Dont be afraid to ask for help But dont immediately run for the hills either! COMMUNICATING NO Guidance, not Gatekeeping No, Im not letting you do that vs. Thats an unallowable cost under 2CFR200, but lets talk about what you really need.. Focus on honoring intent: How CAN we do what needs to be done CHAPTER AND VERSE How much information is too much? May vary from one faculty member to another Use direct quotes when you need to....But explain in plain language whenever possible! Use your Judgment People Skills Communication WHEN TO CALL IN THE BIG GUNS Judicious use of the Dean Card Dont cc the boss on everything! Yours OR the faculty members! When to call for backup: The faculty member is abusive You dont fully understand the issues or know what to do Multiple attempts to explain have been unsuccessful Youre losing your temper STRESS FREE SUBMISSIONS Get information as soon as you can, well ahead of the deadline Get organized Work through the issues with the PI Send for approvals well ahead of the deadline crunch Anticipate issues and questions Be proactive Stay calm Take breaks YOUR FACILITATOR FOR TODAY: Brigette Pfister, MHRD, CRA Director of Sponsored Programs for Humanities & Sciences, Virginia Commonwealth University QUESTIONS? REFERENCES AND ACKNOWLEDGEMENTS David Smelser, University of Tennessee (Research Administration Memes) Grants.gov Glossary RACC CRA Body of Knowledge Stanford University DoResearch (Export Controls) Stanford University DoResearch Uniform Guidance (2CFR200) Uniform Guidance