Compliance Digest: December 2017

 

Recently, NIH published the following notice regarding the enforcement of closeout deadlines:  Notice Number NOT-OD-18-107.  HHS policy requires that NIH recipients submit the Final Federal Financial Report (FFR), Final Research Performance Progress Report (F-RPPR), and Final Invention Statement and Certification (FIS) within 120 calendar days of the end date for the project period (period of performance).  Non-compliance with this requirement could cause the initiation of a unilateral closeout of the award by NIH.  Failure to submit the Final FFR in a timely manner could result in disallowed costs. 

This should serve as a reminder that sponsors expect Duke University to meet the closeout deadlines and there are consequences for non-compliance. Please continue to make every effort to meet the closeout deadlines, including working with your PI to ensure that all deliverables are submitted in a timely manner.

 
Please contact your Implementation Team with any questions:

• Campus Implementation Team: campus-implementation@duke.edu
• SOM Implementation Team: SOM.Implementation@dm.duke.edu
• OSP Liaison

The National Institutes of Health (NIH) published a Notice (NOT-OD-18-108) reminding recipients that the Standards for Documentation of Personnel Expenses (45 CFR 75.430(i)) has been implemented by NIH.  It specifically notes that “charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed,” while also recognizing that practices at Institutes of Higher Education differ due to the nature of intermingled activities in an academic setting.  As such, Duke’s records of personnel expenses must meet a list of standards set by this regulation.  The policies, procedures, and systems in place at Duke help ensure compliance with these standards. 

This NIH Notice serves as a reminder to actively monitor and manage personnel effort throughout the life of all projects to maintain compliance with this requirement.  Proactive management through communicating with PIs and other personnel working on sponsored projects and/or projecting future effort commitments of PIs are a couple of ways our grant administrators can improve compliance and mitigate risk for these charges.

Notice Number: NOT-OD-18-103

Due to the large number of research awards Duke University received from DHHS, SAP will soon run out of 203-xxxx WBSEs to assign to new awards.  It is expected that the 203-xxxx numbering series will be depleted sometime in Spring 2018.  In response to this, a new numbering system will be implemented for new sponsored research awards from DHHS after all 203-xxxx WBSEs are used.  New awards from DHHS for sponsored research will be given a WBSE with the numbering structure A03-xxxx.  Additional communication will be disseminated as we approach the implementation of this new numbering structure.

Fees associated with wire transfers of funds to foreign recipients are an allowable expense and can be direct charged to a project. Adequate documentation must be provided to confirm the expense is specifically identifiable to the project being charged. In addition, PIs and grant managers should consult award documents to ensure wire fees are not specifically unallowable on the award.

For more information, please visit the International Research Administration section of the RCC website.

Travel costs are the expenses for transportation, lodging, subsistence and related items incurred by individuals who are travelling related to the scope of work of a sponsored project. When charging these costs directly to the project, documentation must be provided to justify that the costs are reasonable and the participation of the individual travelling directly benefits the project. This reference guide reviews A/A/R considerations and documentation procedures for travel charges to a sponsored project, including guidance for those not funded on the project.

A Policy Reference Guide is available on the Topical Summaries page of the RCC website.

NIH has broadened its definition of clinical trial and is instituting the use of a new forms packet for collecting information about human subjects research at the time of proposal submission due on or after January 25, 2018 (NIH Forms E). While the changes are significant and will require additional work by research investigators & administrators, the changes will facilitate transparency in how NIH conducts and supports human subjects and clinical trials research and dissemination of results. Duke is well-prepared for the upcoming changes.  Proposals initiated in SPS and Grants.Duke on or after December 11 will include access to Forms E fields and materials (for due dates on or after January 25, 2018). Questions about these changes can be directed to researchinitiatives@duke.edu.  See ORA website for updates to time/location of planned office hours and for additional resources and information.