Grant Management Community News: September 2013
- New CAS Monitoring
- New Electronic Form to Request Administrative Action by ORA
- New PHS 398 Paper Forms and Instructions and New SF 424 (R&R) Application Guide Instructions
- eRA Commons ID to be Required for Graduate & Undergraduate Student Roles (Faculty Advisory)
- New PI Training Coming Soon (Faculty Advisory)
- NIH Policy Update on Subaccounting and Grants Closeout (Faculty Advisory)
- Tech Talk: eRA@Duke
- A-81 Update
- 2013 Symposium for Research Administrators: SAVE THE DATE
- Peer Institutions Settle False Claims Act Lawsuits (Faculty Advisory)
- The New Duke University Ethics & Compliance Office
- Compliance Corner
- Federal Hot Topics
- Grant Management Community Job Opportunities
- Current Training Opportunities
Federal awards that have a budget in place for approved clerical and administrative costs are now subject to monitoring for overspending. Management metric reports will include Federal projects whose overspending is twice the budgeted amount for that cost category and $2,500 over the budgeted amount. For example, if your project has budgeted $2,500 in G/L 600066 and you’ve charged $5,000, this project would be included in the management report as being overspent and non-compliant. In contrast, if your project has budgeted $500 in G/L 693600 and you’ve charged $1,500, this project is considered compliant and would not be in the management report. A revised Direct Cost Exception Form is required to increase the originally approved budget of CAS items.
The Office of Research Administration (ORA) has new web forms available for requesting actions from ORA, rather than sending e-mail requests. The “Request to Add Sponsor to SPS” web form should be completed and submitted if a sponsor is not currently in SPS and needs to be added. For requests such as a carry-over request, rebudget, PI status request, etc., the “Administrative Actions Request” web form should be completed and submitted to ORA.
All PHS 398 paper applications with submission due date on or after September 25, 2013 are required to use the 8/2012 version of the forms and instructions. The previous version of the form (06/09) is still available but is only for responding to FOAs with due dates prior to September 25, 2013. As previously announced, electronic application submissions will transition to new forms with a Competition ID of FORMS-C. Application instructions for the new forms are now available. Read more.
During the next year, an eRA Commons ID will be required for all individuals in graduate and undergraduate student roles with at least one person month or more participation in NIH-funded projects. Beginning October 18, 2013, the NIH RPPR forms will generate a warning if it is submitted without an eRA Commons ID for these individuals. The PHS 2590 will also be modified to prompt for this information starting October 18, 2013. Beginning in October 2014, any RPPRs submitted without the eRA Commons ID for graduate and undergraduate students will receive an error and will not be accepted by the NIH. Read more.
RCC announces the availability of the 2013 Principal Investigator Continuing Education on-line module to be released in early October. As a reminder, this continuing education module is required for all Principal Investigators. The 2013 module will also be required for Project Leaders, Core Leaders, Project Directors, multiple Principal Investigators/co- Principal Investigators, and PI Fellows. No new sponsored program award will be set up until the new 2013 module has been completed by all individuals who serve in the roles listed above on the project. Further details regarding the release date and deadline of completion of the training will be announced in the coming weeks.
The National Institutes of Health (NIH) is transitioning grant award payments to Payment Management System (PMS) subaccounts, which is an award-by-award method of payment very different from the current pooling method. NIH anticipates that for new and continuing awards issued after October 1, 2013, payment will be made through the PMS subaccounts, with full implementation by the end of FY2014. Read more.
This could have a significant impact both on back-office (OSP, ORA, ORS) and departmental responsibilities as it relates to non-competing renewals. A SubAcct Workgroup is being assembled under Jim Luther’s leadership to a) provide feedback to federal officials to advocate to adjust the implementation date and b) develop the strategy by which Duke will adjust its business processes in the eventuality of this change. Significant additional communication will be forthcoming over the next two weeks.
Federal regulations state that final financial reports must be submitted to the funding agency within 90 days of the end of the performance period. The Government Accountability Office (GAO) found that over $794 million in funding remained in the PMS on expired grant accounts. Therefore, the Division of Payment Management (DPM) is implementing a new PMS grant closeout/expiration process in an effort to closeout grants in a timely manner after their performance periods have expired. As part of this process, awards that are 90 days past the performance period will be flagged in the PMS, with the potential for a hold to be placed on the cash draw, or payment. An implementation date has not yet been established.
Although a specific implementation date has not been set, it is anticipated that with the implementation of SubAcct Reporting, it is likely to be in effect as soon as January 2014. If this is the case, most HHS agencies will not allow any adjustments to a project if > 90 days after the end-date. Significant communication will be forthcoming.
Attention Grant Managers! This is important new process that will significantly impact Duke, particularly untimely and/or incomplete closeout documentation. Read more.
The eRA@Duke (Electronic Research Administration at Duke) Project proceeds with ongoing efforts on project workstreams including Notice of Award, CAS/Rebudgeting and Fund Code & Plan Setup. Early Fall 2013 will bring additional releases for Notice of Award to include functionality in SPS Web that will provide stage-setting for Fund Code Setup in SAP going forward.
During Q4 2013 the pilot of the CAS/Rebudgeting workstream will go live with CAS Reporting and the online CAS/Rebudget Form. Full rollout of these workstream deliverables will occur early in Q1 2014. The Fund Code & Plan Setup workstream continues with process mapping and goal go live in Q3 2014. Finally, the Closeout workstream, the most intricate of the workstreams with likely the most powerful value-add, will start work in Q3 2013.
Please look for additional project updates in subsequent newsletters, as well as an eRA@Duke webpage coming soon. Should you have any questions or comments regarding eRA@Duke, please do not hesitate to contact Meredith Woods, Project Lead, at meredith.woodsduke.edu.
Due to comments and recommendations submitted to the Office of Management and Budget (OMB) regarding the Proposed Uniform Guidance (A-81), Council on Government Relations (COGR) submitted an addendum in July 2013 to their original comment letter to the OMB. This addendum reiterated COGR’s priorities in the Grants Reform initiative, while also recognizing the issues that may cause undue burden on educational institutions. Some of the issues reiterated by COGR in this addendum that could greatly impact educational institutions include subrecipient monitoring, effort reporting, performance and financial reporting, and procurement standards. To read the addendum submitted to the OMB, please visit http://www.cogr.edu/.
The annual 2013 Symposium for Research Administrators will be held on Thursday, November 7, 2013 at the Hilton Durham near Duke University. This year’s Symposium focuses on Dynamics for Tomorrow’s Research Administration and will provide insight into the many changes and enhancements occurring both federally and institutionally. To register for the 2013 Symposium for Research Administrators and learn about how to become a volunteer, please visit the Symposium webpage.
RCC is looking for pictures of people, buildings, technology, etc. at Duke from past years to display as we look back at what Duke University was and what it is today. Please share your memories in pictures of days gone by: old technologies, colleagues in their younger years, older buildings and grounds… Thanks for sharing!
A civil suit was filed by a former employee and whistleblower of a peer institution claiming that a cancer researcher directed and authorized spending of grant funds for personal travel and consulting fees for unqualified friends and family members. This resulted in a federal False Claims Act lawsuit due to the institution submitting false claims to the National Institutes of Health (NIH) for spending that did not meet grant guidelines. After an investigation by the Office of Inspector General, the Federal Bureau of Investigation, NIH, and the U.S. Attorney’s Office, the institution agreed on a settlement requiring them to pay $2.98 million back to the United States government.
Departmental grant administrators/managers can help ensure proper charging by determining allowability of costs. A cost that is not related to the project and/or not necessary for the project, should be charged to an alternate funding source. Due diligence at the department level can prevent improper charging to funded projects.
Another university reached a settlement also in a False Claims Act lawsuit, requiring them to pay back $1.5 million to the U.S. government. The institution billed Medicaid and Medicare for clinical trials services that the clinical trial sponsor agreed to pay and, in some cases, did already pay. A whistleblower filed suit against the institution, and the investigation by the U.S. Attorney’s Office for Northern District of Georgia, Department of Health & Human Services, Office Inspector General, FBI, and Georgia Medicaid Fraud Control Unit resulted in the settlement and pay back.
The School of Medicine Compliance Office (SOMCO) is now the Duke University Ethics & Compliance Office. For more information about the Duke University Ethics & Compliance Office, please visit their website.
Compliance Corner provides you with guidance on things to consider as you submit or approve a travel/expense report and AP check request through the new electronic system. Also, a recent Department of Health and Human Services audit of the University of Colorado Denver found that the institution must pay back $1,419,524 due to questioned costs, while a National Science Foundation (NSF) audit of the University of Wisconsin-Madison resulted in $2,134,379 in questioned costs. Read more.
This month’s hot topics include the National Institutes of Health (NIH) webinar slides and chapter videos about how to prepare and submit multi-project applications using ASSIST. Read more.
Faculty Advisory Discuss the topic with your PI
Current Training Opportunities (Updated as of 09/05/13)
Continuing Education Reminder: Remember: All Research Costing Compliance classes now require that attendees pass a brief assessment with a score of at least 80% in order to receive continuing education credit. This includes the mandatory Management of Selected Post Award Issues, all Continuing Education/Elective classes, and all AGM classes (for AGM program participants and continuing education credit). If you do not pass the assessment with at least an 80% or greater, you must attend another offering of the class and take the assessment again to earn the continuing education credit. Read more.
For all certified Grant Managers: You must earn five credits throughout the fiscal year (7/1/13 – 6/30/14), of which one must be 2014 Management of Selected Post Award Issues. Please check your completed training on the RCC Training Tracker. Please note that it is updated monthly with current training data. All questions/concerns regarding RCC training or continuing education credits should be submitted to rcc-certduke.edu. Please do not submit inquiries to individual RCC staff. Read more.
FY14 Available Classes
- *FY14 Management of Selected Post Award Issues – September 25, 2013, October 17, 2013, and October 29, 2013
Continuing Education/Elective Classes:
- *Award Setup (formerly Establishing a Funded Project) – October 23, 2013
- *Subaward Management: Doing Business with a Foreign Site – September 17, 2013
- *Reconciliation of Sponsored Projects – September 26, 2013, and November 26, 2013
- *Regulatory Environment-The Circulars – September 19, 2013
- *Export Controls for the Grant Manager – October 16, 2013
- *Advanced Sponsored Projects Reporting – October 2, 2013, and November 20, 2013
Other Duke Training Opportunities:
- Office of Research Administration (ORA):
- *Sponsored Projects System (SPS) – October 8, 2013
- *Pre-Award Grants and Contracts (GC101 & GC201) – October 2 & 3, 2013
- *eSubmissions – September 25, 2013, and November 13, 2013
- *RPPR/eSNAP – September 25, 2013, and November 13, 2013
- *Other Support – October 22, 2013
- Office of Research Support (ORS):
- Introduction to Export Controls – December 12, 2013
- *Grant Managers Meeting – December 2, 2013
- *Grants, Compliance and Contracts 102 – October 9, 2013
- *Grants, Compliance and Contracts 103 – November 14, 2013
- SAP and University Reporting:
(Although they do not qualify for continuing education credits, these classes will be of interest to entry-level grant managers)
- Introduction to SAP @ Duke – Online
- Introduction to SAP Business Warehouse for the University (0010) – September 17, 2013, and December 19, 2013
- SAP University Reporting: Sponsored Projects – October 23, 2013, November 7, 2013, and December 11, 2013
- Introduction to Duke Accounting and Business Practice – September 19, 2013, October 17, 2013, November 14, 2013, and December 12, 2013
- Introduction to Duke G/L Accounts – September 25, 2013, October 24, 2013, November 20, 2013, and December 19, 2013
- Faculty Projection and Reporting Tool – October 30, 2013, and December 5, 2013
- 2013 Annual Meeting – October 26-30, 2013 in New Orleans, LA
- National Organization of Research Development Professionals (NORDP)
*These classes qualify for continuing education credits for RCC certifications.
"Grant Management Community News" is produced by Duke's Office of Research Costing Compliance. Please contact us with comments or suggestions regarding the newsletter. An archive of newsletters is available online.
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