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Compliance Digest: April 2017

 

FOCUS ON: Federal-Wide Research Terms & Conditions Issues

NIH, NSF and DOE have published their interpretations of the Uniform Guidance requirements for prior approval. A quick reference tool, known as the Prior Approval Matrix has been posted to the NSF website. The updated Research Terms & Conditions are effective as of April 3, 2017 to new NIH, NSF, and DOE grant and cooperative agreement awards.  While there are some minor changes, we expect to receive clarification at the upcoming Federal Demonstration Partnership (FDP) meeting next month. 

Reminder:  A reduction of 25% or greater of committed effort on a federally sponsored project requires prior approval.  Please review agency specific guidance for details regarding persons on the award required to meet this prior approval requirement.

Research Terms & Conditions

UGC 6.0 – International Currency Exchange Rates

The Uniform Guidance allows the cost of fluctuations in international currency exchange rates to be charged to federally funded projects.  Funding must be available, and prior approval of these charges are required when additional federal funding is needed to cover these costs or when the increased cost results in significantly reducing the scope of the project.  Sponsor prior approvals must be coordinated through your pre-award office.  For further details and recommended best practices at Duke, please read the Uniform Guidance Communication (UGC) 6.0 – International Currency Exchange Rates (pdf).

Increase of Salary Cap for Grants & Cooperative Agreements

The salary limitation (salary cap), based on the Executive Level II of the Federal Executive pay scale, has been increased from $185,100 to $187,000.  This increase to $187,000 is effective January 8, 2017. 

Per NIH Notice NOT-OD-17-049, rebudgeting is allowed to accommodate for the increased salary rate, if funds are available:

“For awards issued in those years that were restricted to Executive Level II (see Salary Cap Summary, FY 1990 – FY 2016), including competing awards already issued in FY2017, if adequate funds are available in active awards, and if the salary cap increase is consistent with the institutional base salary, grantees may rebudget to accommodate the current Executive Level II salary level. However, no additional funds will be provided to these grant awards.”

Some important notes regarding this change:

  • Duke recommends the use of the new $187,000 salary cap for all new and non-competing applications submitted to DHHS and DHHS agencies (except FDA and Indian Health Services). 
  • Applying the new salary cap retroactively to the effective date of January 8, 2017 is optional for departments.

Additional Guidance on DHHS Contracts:  The following guidance is available from the DHHS specifically for application of the salary cap to personnel supported by DHHS contracts containing the 12/15/15 version of HHSAR 352.231-70:

HHSAR 352.231-70:

(d) If this is a multiple-year contract or order, it may be subject to unilateral modification by the Contracting Officer to ensure that an individual is not paid at a rate that exceeds the salary rate limitation provision established in the HHS appropriations act used to fund this contract.

Duke interprets this to mean that certain contracts may not allow the use of the new salary cap due to language restrictions in the original award document.  If you manage a current DHHS-supported contract and need assistance on which salary cap rate should be applied, please contact the appropriate pre-award office (ORC or ORS) for clarification.

Closeout Project Update

Automated Closeout Tools Go Live May 8th – On May 8, 2017 Duke will launch an automated suite of tools, reports and resources designed to support Grant Managers with the timely and accurate closeout of sponsored projects. All tools are located on the Duke@Work portal on the Grants Management tab. These new forms and reports will improve the efficiency of the closeout process and provide increased visibility of documents as they are routed for approval based upon established workflow, and once approved, are imaged for historical reference.

Closeout submissions will no longer be accepted via email after May 2, 2017. Closeout submissions not received by Tuesday, May 2nd must be completed using the automated closeout tools, once available on Monday, May 8th.  If you have due dates that fall during the downtime, reach out to your Implementation Team for guidance.

Additional information will be provided at:

Please contact your Closeout Implementation Team with any questions: