Office of Sponsored Programs Administration & Accounting

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Notice:

Business Hours: Monday - Friday, 8:00 - 5:00pm

Updates from the Director

Please Observe 5 Business Day Requirement for Submission of Proposals

Recent disruptions in operations caused by computer outages and weather related closings have highlighted a weakness in our processing procedures; specifically, we are not building in sufficient lead time to recover from unexpected issues.  University Policy 2201 states that completed and approved proposals must be submitted to OSP five (5) business days prior to the sponsor’s submission deadline.  While it is in no one’s best interest to strictly enforce this policy, it is obvious that we can no longer ignore a proactive deadline.  Accordingly, Sponsored Programs will be calculating and announcing the “due by” deadline called for by the policy as soon as we learn of a PI’s interest in making a submission.  We will adjust the timing, and tone, of reminder notices to foster completion of the proposal by the internal deadline.   John Hulvey will evaluate submissions on a daily basis and those that are found to be delinquent using this internal deadline will be redirected toward the next funding cycle for that funding opportunity.  The PI and any collaborators will be informed that the proposal will not be submitted for the current cycle and will receive information when the opportunity will be available again, if that date is known.

We hope this change will actually reduce stress and improve the quality of our submissions.  We appreciate your cooperation as we implement this processing change to comply with University Policy.

Timely Topics

Effort Reporting for Fall Semester Delayed

Normally by this time you would have been notified that Fall Effort Reports were ready for certification in the Effort Reporting System (ERS). However, due to an upgrade to the system taking place, the reporting period has been delayed.  We hope to have the system up and going again by mid-February.  As soon as it is ready, we will be sending out Effort Forms for Certification.  Thank you for your patience.

Uniform Guidance Implementation Update

You may be aware that the interim joint final rule implementing the Uniform Guidance (UG) is now available in Federal Register (Vol. 79, No. 244, Friday, December 19, 2014). It can be accessed at https://www.federalregister.gov/articles/2013/12/26/2013-30465/uniform-administrative-requirements-cost-principles-and-audit-requirements-for-federal-awards#h-10The UG is effective for new awards and for selected funding increments, issued on or after December 26, 2014. Though the UG is published, the federal agencies must still roll out their plans to implement the changes the UG mandates. This is called the Revised Research Terms and Conditions (RTC). This process has been delayed. In fact, as noted in December’s newsletter, the National Science Foundation is the only federal agency that has published their implementation of the UG by way of the newly revised Grant Proposal Guide, NSF 15-1.  The National Institutes of Health has not yet issued a revised Grants Policy Statement but it is expected within a month. We will share additional communications as the NIH revised Grants Policy Statement and the federal Research Terms and Conditions become available. 

Most people don’t need to read the lengthy guidance contained in the UG or the elusive Revised Research Terms and Conditions (RTC). However, it’s necessary to know that the UG will change some of the ways the University applies for, receives, and manages federal funding. Research Administrators (Sponsored Programs’ employees) need to know how this changes our business processes as we advise and assist you with funding applications to federal sponsors and administering awards from federal sponsors.

While we await complete guidance and best practices to emerge among institutions of higher education, consider two areas which we do know will change our processes:

Procurement: (2 CFR Part 200.318 – 200.320)

Starting now, all procurements made with federal financial assistance dollars on grants above the UG’s micro-purchase threshold of $3,000 must be competitively bid. This is  different from the State’s $5,000 threshold for purchases made with the Small Purchase Credit Card. On federal grants, we must show that some form of competitive price and cost analysis was completed  in projecting the cost in the proposal (at the pre-award budgeting phase) and prior to making the purchase at the time of award. There are several ways to approach and fulfill this requirement for documentation both at the proposal stage and after the award. We will also advise principal investigators that they may wish to work with Procurement to fulfill these new requirements  at either stage. OSP is here to answer questions about this requirement and to facilitate sharing of information with Procurement as needed.

Regulators anticipated that compliance with this new requirement may be burdensome for many institutions involving changes to policies and business processes, so required implementation of the Procurement Standards has been delayed until the end of the first fiscal year following 12/26/2015 (e.g. July 1, 2016), however we intend to be fully compliant with the Procurement standards well in advance of that date and will work closely with Procurement to guide faculty through the new standards as painlessly as possible.

Determination of Sub-Recipient vs. Contracted Services

The Uniform Guidance (200.330) requires that the University make case-by-case determination as to whether a party that is receiving “pass through” federal funds is a subrecipient or a contractor. Note: The term “contractor” is functionally equivalent to the term “vendor.”  During the budget planning phase OSP staff will help you to determine if you have collaborators associated with your proposed work. These could be Co-PI’s at their respective home institutions or skilled services provided  by a third party.  Now more than ever it’s essential to classify these collaborators either as subrecipients or contractors so that the budget is set up correctly and we collect the proper documentation when preparing  our proposals.

Subrecipient is an entity that:

  • has its performance measured against the objectives of the program.
  • has authority for programmatic decisions.
  • uses the funds to carry out a program of the organization as compared to providing goods or services for a JMU program.
  • has responsibility for adherence to applicable program compliance requirements.
  • Has an integral role in proposal development and intellectual content.
  • typically owns any intellectual property created on its portion of the project.

Contractor (previously Vendor) is an entity that:

  • provides the goods and services as part of their normal business operations and are ancillary to the sponsored program.
  • provides similar goods and services to many different purchasers.
  • performs activities by an unidentified individual or team.
  • exerts little or no discretionary judgment, often performing repetitive tasks
  • operates in a competitive environment (competes with others who provide similar goods and services).
  • is not subject to compliance requirements of the program.
  • Note: Consultants are considered vendors because they are normally not receiving funds “to carry out” a part of the sponsored program.

Should the determination be made that we are working with a subrecipient using federal funds, we will need to collect additional and different information than if we plan to make a procurement for a contractor’s services.  We will provide a checklist/worksheet for this purpose and assist you with the documentation.

Focus on National Institutes of Health

New National Institutes of Health (NIH) Biosketch Format

(NIH Notice Number: NOT-OD-15-032)

A new biographical sketch format is required for all NIH proposal submissions for due dates on or after 5/25/15.  The new format is encouraged for proposals submitted on or after 1/25/15 but is not required.  Instructions and the revised forms are available on the SF 424 (R&R) Forms and Applications page.

Below is a summary of the new format updates:

  • The page limit is extended from 4 to 5 pages.
  • Allows researchers to describe up to 5 of their most significant contributions to science, along with the historical background that framed their research. Investigators can outline the central findings of prior work and the influence of those findings on the investigator’s field.
  • Allows investigators involved in Team Science the opportunity to describe their specific role(s) in the work. Each description can be accompanied by a listing of up to 4 relevant peer-reviewed publications or other non-publication research products, and include a link to a full list of their published work as found in a publicly available digital database such as MyBibliography or The Science Experts Network Curriculum Vitae (SciENcv).

SciENcv is a tool that allows investigators to enter their biographical data once and convert it into biosketches that can be used with both NIH or National Science Foundation grant applications and annual progress reports. SciENcv will be updated to support the new NIH biosketch format by January 2015.

For additional information, please see the NIH Frequently Asked Questions.

NIH News Flash: Late Policy for Application Submission Simplified

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Though permission to submit late is still not provided by the National Institutes of Health centers in advance, under the new late policy NIH will consider accepting applications within the two-week window following the application due date if an acceptable reason is provided in a cover letter submitted with the late application. See NOT-OD-15-039 (Release Date: December 17, 2014) for exceptions (like RFAs stating no late applications will be accepted), steps that must be taken for an application to be considered under the late policy, and examples of reasons why late application will or will not be accepted. This is a significant change from previous policy, which tied different late windows of consideration to different types of applications, and provided no late window of consideration for applications submitted to any RFA (Request for Applications) or PAR (Program Announcement) with special application due dates. This new policy is effective for applications submitted for due dates on or after January 25, 2015.

Examples of Reasons Why Late Applications Might Be Accepted

  • Death of an immediate family member of the PD/PI.
  • Sudden acute severe illness of the PD/PI or immediate family member.
  • Temporary or ad hoc service by a PD/PI on an NIH advisory group during the two months preceding or the two months following the application due date. Examples of qualifying service include: participation in an NIH study section/special emphasis panel, NIH Board of Scientific Counselors, Program Advisory      Committee, or an NIH Advisory Board/Council. Qualifying service does not include participation in NIH activities other than those involved in extramural/intramural peer review or NIH Advisory Council/Board service.
  • Delays due to weather, natural disasters, or other emergency situations, not to exceed the time the applicant organization is closed.
  • For PD/PIs who are eligible for continuous submission (http://grants.nih.gov/grants/peer/continuous_submission.htm), the late application policy applies to activities not covered under the continuous submission policy (i.e., other than R01, R21, and R34 funding opportunities that use standard due dates).

NIH Releases Insider’s Guide to Peer Review for Applicants

A poll of current and former review panel section chairs contributed to this guidance for applicants to improve the quality of their funding proposals. 

Additional videos and resources regarding peer review may be found at the Center for Scientific Review.

Featured Funding Opportunity

National Institute of Standards and Technology (NIST) Summer Undergraduate Research Fellowship (SURF)

INTERNAL RECEIPT DATE: February 10

Funding Opportunity Description: The SURF Program provides research opportunities for undergraduate students to work with internationally known NIST scientists, to expose them to cutting-edge research, and to promote the pursuit of graduate degrees in science and engineering. SURF students will have the opportunity to work one-on-one with our nation's top scientists and engineers. It is anticipated that successful SURF students will move from a position of reliance on guidance from their NIST research advisors to one of research independence during the 11-week period. One goal of these programs is to provide opportunities for our nation's next generation of scientists and engineers to engage in world-class scientific research at NIST, especially in ground-breaking areas of emerging technologies. This carries with it the hope of motivating individuals to pursue PhD’s in biology, chemistry, computer science, engineering, materials science, mathematics, nanoscale science, neutron research, and/or physics, and to consider research careers.

Two Locations: 

REMINDERS:

  • DO NOT APPLY DIRECTLY TO NIST.
  • You must have a faculty member willing to be the Principal Investigator on the project.
  • ALL APPLICATIONS MUST BE RECEIVED AND COORDINATED BY THE OFFICE OF SPONSORED PROGRAMS.

CONTACT US WITH INTEREST AND WE WILL GUIDE YOU THROUGH THE PROCESS. E-mail: jmu_grants@jmu.edu, 568-6872

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