Compliance Digest: June 2017

Since the revised Research Terms & Conditions took effect on April 3, 2017, additional updates have been made regarding the RTC.  Appendices are updated and available online, including:

• Appendix A – Prior Approval Matrix (pdf)
• Appendix B – Subaward Requirements (pdf)
• Appendix C – National Policy Requirements (pdf)

NCURA recently offered a webinar about these updated Research Terms & Conditions, which will be made available in the LMS to view for continuing education credit. Further details about this will be communicated in the coming weeks.

Federal Research Terms & Conditions

The Uniform Guidance addresses the allowability of charging travel visa fees to federally sponsored projects in 2 CFR Part §200.463 – Recruiting Costs.  Keep in mind the different types of travel visas and their purpose when determining if they can be charged to a federally sponsored project.  The UG allows short-term travel visas fees to be charged to federally sponsored projects, if they are necessary for the project.  Since long-term visas are typically not allocable to a particular project, ORA/ORS should be contacted before charging fees for long-terms visas.

For further details and recommended best practices at Duke, please read the Uniform Guidance Communication (UGC) 7.0 – Travel Visas (pdf).

Please do NOT approve Manual Salary Cost Transfers (MSCT) iForms using Reason Code 05 (Year-end adjustment of effort) on July 12, 2017 from 12:00 noon to July 13, 2017 at 8:01 am.  This period is designated as “quiet time” after Fiscal Period 12 closes and before Period 13 opens. Approving the MSCT iForm during “quiet time” will cause the transaction to post in Fiscal Year 2018, Fiscal Period 01.
If you have initiated a MSCT iForm that has not yet been approved, please forward this email to the approver. 

For questions regarding this message, please email ECRT-Support@duke.edu

The NSF Proposal & Award Policy Newsletter recently featured answers to questions they often receive about participant support costs.  These costs must be budgeted and expended in a particular way that can lead to confusion and/or non-compliance with NSF policies.  An entire page of the May/June 2017 newsletter is dedicated to answering these questions and hopefully reducing confusion surrounding participant support costs in an NSF proposal budget and/or award. 

NSF Proposal & Award Policy Newsletter (May/June 2017) (pdf)

A former grants specialist at Meharry Medical College (MMC) in Tennessee pleaded guilty to embezzling $133,000 of Federal funds.  Over the past several years, this former MMC employee wrote dozens of checks to herself and created false invoices and approved these payments to herself.  She now faces a prison term of up to 10 years and a fine up to $250,000. 

Duke University appreciates and expects the assistance of all employees in maintaining compliance.  Suspected financial non-compliance or fraudulent activity should be reported. 

U.S. Attorney’s Office, Middle District of Tennessee Press Release
Reporting Non-Compliance at Duke (pdf)