25 YEARS OF ASKING FOR PERMISSION! Research Administration & Prior Approvals Sponsored Programs Administration September 25, 2018 STAYING UP-TO-DATE WITH SPA SPA website SPA-TRAINING listserv
TOPICS TO CONSIDER Do I even need to ask? When do I ask SPA and when do I need to ask the sponsor? Is there a standard set of guidance for federal agencies? What is the right process to follow? WHAT IS PRIOR APPROVAL? Sponsoring agencies permit changes to a projects budget and other post-award changes to meet unanticipated needs and changing circumstances. Some changes can be made without obtaining specific agency approval while other changes require prior written approval from the sponsor.
Degree of discretion can vary by grant and individual grants sometimes contain restrictions and other terms and conditions requiring prior approval. Prior approval means advance written approve from the authorized grants management official at the agency. NIH EXPANDED AUTHORITIES DATE BACK TO OF1994 REVISION TO NIH IMPLEMENTATION EXPANDED AUTHORITIES NIH GUIDE, Volume 23, Number 45, December 23, 1994
Expanded Authority was an increased level of authority that the NIH granted on certain projects, under which a variety of NIH's requirements for prior approval of expenditures and activities were waived Allowed the grantee to take certain actions without obtaining prior approval from NIH. Expanded Authority are granted according to the project type. In certain cases, the general expanded authorities may be overridden by a special term or condition in the Notice of Grant Award. In exercising expanded authorities, grantees must ensure that they exercise proper stewardship over federal funds and that the costs to the awards are allowable, allocable, reasonable, and consistently applied, regardless of the source of funds.
WHAT WERE THE EXPANDED AUTHORITIES? Incur Pre-Award costs 90-calendar days prior to award. Initiate a one-time extension of the expiration date of the award of up to 12 months Carry forward unobligated balances to subsequent funding periods. Waives cost-related (rebudgeting) and administrative prior written approvals required by OMB Circulars A-21 and A-122. Applied to P01s, Ks and Rs. TRANSITION TO RESEARCH TERMS & CONDITIONS OVERLAY TO THE UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS
NIH extended expanded authorities to all NIH awards except for the provision to automatically carry over unobligated balances thus these authorities have become the NIH Standard Terms of Award. Therefore, the term Expanded Authorities is no longer used at NIH. These Research Terms and Conditions (RTC) implement the requirements of the Uniform Guidance, issued by the U.S. Office of Management and Budget, as it applies to research and research-related grants made by most Federal awarding agencies to institutions of higher education and non-profit organizations. The RTC includes a Prior Approval Matrix. The National Science Foundation (NSF) has agreed to continue to serve as the sponsor of the updated version of these RTCs. NIH IMPLEMENTATION OF EXPANDED AUTHORITIES AND INFLUENCE ON VU
PRACTICES In exercising expanded authorities, grantees must ensure that they exercise proper stewardship over federal funds and that the costs to the awards are allowable, allocable, reasonable, and consistently applied, regardless of the source of funds. Many institutions adopted procedures that implemented processes that took the place of agency review. If you have a 20-year service pin, you probably remember the buff sheets used in VU DSR. VUMC also adopted processes that reflected the fact that GCM was an office that had roles much like a VU school. These processes live on in PEER! EXPANDED AUTHORITIES AS IMPLEMENTED BY PREVIOUSLY IMPLEMENT
AT VU VS. RTC TODAY Expanded Authorities-Required approval by VU pre-award office RTC Prior Approval Matrix--No action required from VU pre-award office Incur pre-award costs 90-days prior to award No action required Foreign travel requests No action required
Equipment rebudget request Weve removed these prior approval requests from the administrator portal menu in PEER. No action required (unless change in SOW) OCGA concurs that SPA does not approve these 3 actions Any budget actions submitted to OCGA to implement these 3 actions will not require SPA approval.
THE ACTION THAT DOESNT REQUIRE WRITTEN AGENCY PRIOR APPROVAL BUT DOES REQUIRE SPA REVIEW & SUBMISSION Initiate a one-time extension of the Period of Performance for up to 12 months. Action is needed by SPA since SPA must approve PIs request or notify sponsor request is approved. EXAMPLES THAT ALWAYS REQUIRE WRITTEN AGENCY PRIOR APPROVAL Change in scope Change in the PI/PD Disengagement of the PI/PD for more than three months or a 25% reduction in effort
Incur pre-award costs greater than 90 days Subsequent no-cost extensions beyond 12-months ** SPA should always endorse requests to sponsors indicating AOR approval when any of these requests are made. POSSIBLE INDICATORS OF CHANGE IN SCOPE OF WORK **EXAMPLES FROM NIH Sometimes actions that appear to be okay mask a CHANGE in the Scope of Work! Change in the specific aims approved at the time of award. Change from the approved use of live vertebrate animals or involvement of human subjects.
Transfer of the performance of substantive programmatic work to a third party. If the third party is a foreign component, NIH prior approval is always required. Change in other senior/key personnel not specifically named in the NoA Significant rebudgeting, whether or not the particular expenditure(s) require prior approval. Significant rebudgeting does not apply to modular grants. Purchase of a unit of equipment exceeding $25,000. SPA AND SPONSOR PROCESS FOR PRIOR APPROVALGENERAL TIPS All requests for changes that require Sponsor prior approval must be endorsed by SPA. Here are the steps to be taken to request prior approval for a project change: Check your award document to find the appropriate name and contact information for
the grants or contracts official. This will be your addressee, with a cc: to the program manager/technical director. Include the title of the project (also in the award document) and the sponsors award (reference) number. Include an adequate explanation for why your proposal plan needs to be changed so that the sponsor can evaluate your request. The explanation should show how the change will directly benefit the project. WHEN DO I USE PEER TO OBTAIN SPAS ENDORSEMENT? Change in the PI/PD Disengagement of the PI/PD for more than three months or a 25%
reduction in effort **PEER will prompt you for additional information IF I DONT USE PEER, HOW DO I TRANSMIT TO SPA? Change in scope Incur pre-award costs greater than 90 days Subsequent no-cost extensions beyond 12-months E-mail the letter from the PI to [email protected]
EXAMPLES THAT SOMETIMES REQUIRE WRITTEN AGENCY PRIOR APPROVAL SUBAWARDING while adding new subrecepients doesnt always require agency prior approval, it does always require SPA approval submit this in PEER CARRY-FORWARD UNOBLIGATED BALANCES (NIH often restricts in award notice) TO ADD NEW SUBRECEPIENTS, ALWAYS USE PEER SUBAWARDING while adding new subrecepients doesnt always require agency prior approval, it does
always require SPA approval. **SPA will determine if agency prior approval is also required and may ask for additional information. Logging an AddOn Sub needs SUBRECIPIENT S:
TO REQUEST CARRYFORWARD, E-MAIL [email protected] SEE NIH SUGGESTIONS BELOW. Prior to submitting a request for carryover, the grantee is encouraged to discuss it with their Program Officer (PO) and Grants Management Specialist (GMS). In addition, the grantee must ensure that the Federal Financial Report for the last (and all prior) budget period(s) has been submitted and accepted by the NIH Office of Financial Management. o Carryover requests must be limited to actual needs for the current budget period. Subsequent needs would be considered in future budget periods. All carryover requests must be made in writing (or via email) to the GMS assigned to the project and signed by the Authorized Organization Representative from the grantee
institution. o Requests should be submitted in a timely manner, within one year of the end of the budget period from which the funds were unexpended, and must include the following information: Grant number and PI name Amount of funds to be carried over Explanation for the unobligated balance Plan for expenditure, including a description of activities to be carried out during the carryover period, and how the activities relate to the aims of the project Detailed budget in PHS 398 format (Form Page 4) and justification for all items, including
SUGGESTIONS FOR THE JUSTIFICATION FOR CARRYFORWARD When preparing a justification for a carryover request, grantees should answer the following questions: Why were the funds not spent in the past year? What additional work will be done during the current grant year that is not possible with the budget currently allotted to this year? Thought must be given to how the work will be accelerated; for example, will more staff be hired, effort increased or more assays run? Is the request essential? Are costs reasonable, allowable, necessary and in line with the existing budget? Are there new costs that were previously unforeseen? How will the work be impacted if the funds are not carried over? SUMMARY
Expanded authorities is no longer applicable. Instead use the RTC Appendix of Prior Approval required. Reduce burdenif agency Prior Approval isnt required then SPA only helps with initial 12 month extension. Adding a new subrecepient always requires notification and submission of documents to SPA. SPA should always endorse requests that do require agency prior approval. SPA should always advise if a change could constitute a change in the Scope of Work.
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