october 17, 2006 - university of iowa · october 17, 2006 • dsp updates o nih change in deadlines...
TRANSCRIPT
October 17, 2006
• DSP Updates o NIH Change in Deadlines - Jennifer Lassner o Grants.gov training schedule announced - Jennifer Lassner
• GAO Updates o New staff: Melissa Adrian o Grants in Deficit Status
• SSN Policy Jane Drews • Report from Contracts Lean Event and Implementation - Twila Reighley, Wendy Beaver and Lisa
Leff • New subcontract process - Wendy Beaver • F&A Policy - Twila Reighley • Audit Issues - Audra Haddy • Cost Transfers - Audra Haddy
o Advanced MFKs • OMB-A21 Costing Issues - Direct Charging to Federal Grants - Audra Haddy
CHANGE IN STANDARD RECEIPT DATES Receipt Cycle I
Receipt Cycle II
Receipt Cycle III
Program Project Grants and Center Grants – all P Series new, renewal, resubmission, revision*
January 25 (old date Feb. 1)
May 25 (old date June 1)
September 25 (old date Oct. 1)
Research Grants – R10, R18, R24, R25 new, renewal, resubmission, revision*
January 25 (old date Feb 1, March 1)
May 25 (old date June1, July 1)
September 25 (old date Oct. 1, Nov. 1)
Research-Related and Other Programs – all S and G Series, C06, M01 new, renewal, resubmission, revision*
January 25 (old date Feb. 1)
May 25 (old date June 1)
September 25 (old date Oct. 1)
Institutional Ruth L. Kirschstein National Research Service Awards - T Series (Training)** new, renewal, resubmission, revision*
January 25 (old date Jan. 10)
May 25 (old date May 10)
September 25 (old date Sept. 10)
Research Grants - R01 new
February 5 (old date Feb. 1)
June 5 (old date June 1)
October 5 (old date Oct. 1)
Research Career Development – all K series new
Feb 12 (old date Feb. 1)
June 12 (old date June 1)
October 12 (old date Oct. 1)
Research Grants - R03, R21, R33, R21/R33, R34, R36 new
February 16 (old date Feb. 1)
June 16 (old date June 1)
October 16 (old date Oct. 1)
Academic Research Enhancement Award (AREA) - R15 new, renewal, resubmission, revision*
February 25 (no change)
June 25 (no change)
October 25 (no change)
Research Grants - R01 renewal, resubmission, revision*
March 5 (old date March 1)
July 5 (old date July 1)
November 5 (old date Nov. 1)
Research Career Development – all K series renewal, resubmission, revision*
March 12 (Old date March 1)
July 12 (old date July 1)
November 12 (old date Nov. 1)
Research Grants - R03, R21, R33, R21/R33, R34, R36 renewal, resubmission, revision*
March 16 (old date March 1)
July 16 (old date July 1)
November 16 (Old date Nov. 1)
New Investigator – R01 resubmission* for those applications involved in pilot ONLY (http://grants.nih.gov/grants/guide/notice-files/NOT-OD-06-060.html)
March 20 (no change)
July 20 (no change)
November 20 (no change)
Small Business Innovation Research (SBIR), Small Business Technology Transfer (STTR) Grants - R43, R44, R41 and R42 new, renewal, resubmission, revision*
April 5 (old date April 1)
August 5 (old date Aug. 1)
December 5 (old date Dec. 1)
Individual Ruth L. Kirschstein National Research Service Awards (Standard) – all F series Fellowships. new, renewal, resubmission*
April 8 (old date April 5)
August 8 (old date Aug. 5)
December 8 (old date Dec. 5)
Conference Grants and Conference Cooperative Agreements - R13, U13 new, renewal, resubmission, revision*
April 12 (old date April 15)
August 12 (old date Aug. 15)
December 12 (old date Dec. 15)
AIDS and AIDS-Related Grants ALL of the mechanisms cited above new, renewal, resubmission, revision*
May 1 (no change)
September 1 (no change)
January 2 (no change)
Key Dates Release Date: October 5, 2006 Effective Date: January 1, 2007
Issued by National Institutes of Health (NIH) (http://www.nih.gov) Agency for Healthcare Research and Quality (AHRQ) http://www.ahrq.gov/) National Institute for Occupational Safety and Health, Centers for Disease Control and Prevention (NIOSH/CDC) http://www.cdc.gov/niosh/oep)
The purpose of this Notice is to inform the research community of a change in standard receipt dates for grant applications submitted to NIH, AHRQ and NIOSH. The new receipt dates will be effective as of January 2007 and will apply to both paper and electronic applications. The transition to electronic application submission has heightened our awareness of challenges posed by having very large numbers of incoming grant applications on any single day. We currently spread the workload involved with receiving incoming grant applications across three annual council rounds that include multiple submission dates for each round. However, some of our standing receipt dates allow for six to eight thousand applications to be submitted for a single date. This volume has the potential to cause bottlenecks in a number of critical places: the research administration offices at the applicant institution, which must now submit all applications; Grants.gov and eRA systems, where response time may slow under heavy volume; the Grants.gov and NIH help desks, which have to handle large spikes in call volume; and the CSR Division of Receipt and Referral, which is responsible for referral of incoming applications in a timely way. Spreading receipt dates to have a steady flow of applications rather than “boom and bust” cycles will allow many different groups to have a realistic approach to this complex process and maximize electronic system responsiveness.
The new receipt dates are based on many factors including:
• The heaviest receipt dates from all agencies on Grants.gov are the first of the month, the 15th of the month, the first Friday, and last day of the month. The proposed NIH receipt dates have been intentionally offset from these dates to improve Grants.gov response times for NIH applicants.
• An effort was made to use recurring days of the month for simplicity (i.e. new R01s would come in on February 5 and renewals on March 5). • The R01s, NIH’s most frequently used mechanism, were kept early in the receipt window to allow time for processing. The receipt date of the 5th of the month was chosen to
be sure the bolus of submissions that come in on the receipt date and the few days prior missed Grants.gov’s heaviest volume days. • The proposed dates provide additional time for proposal development for application mechanisms often used by new investigators - R03s, R21s, and Ks. • The AREA date was already changed in the fall of 2005 so it was not moved. • The New Investigator R01 date was not changed to avoid affecting the pilot. At present this involves only new investigator R01 applications reviewed in forty study sections in
CSR (http://grants.nih.gov/grants/guide/notice-files/NOT-OD-06-060.html
NIH has revised its standard receipt dates as follows. Applications for Request for Applications (RFAs) and Program Announcements (PAs, PARs, PASs) with special receipt dates continue to be due on the specified dates listed in the FOA. For an application to be considered on time it must be received by Grants.gov by 5 p.m. local time for the applicant institution (http://grants.nih.gov/grants/guide/notice-files/NOT-OD-06-050.html).
*The move to electronic applications also has brought a change in terminology. The new Grants.gov terminology (included in the table above) corresponds to traditional NIH terms as follows: · New = new · Resubmission = a revised or amended application · Renewal = Competing Continuation · Continuation = Noncompeting Progress Report · Revision = Competing Supplement ** Institutional Research Training Grants (T32) are accepted by many NIH Institutes and Centers (IC) for only one or two of the dates. Applicants should contact the relevant IC for specific dates.
At present NIH receives and processes applications for NIOSH and also for components of CDC that participate in the Omnibus Solicitation for Small Business Innovation Research grant applications.This notice applies only to these two groups of applications and not to other CDC submissions.
NIH GRANTS.GOV TRAINING SCHEDULE MERF PBB December 6, 2006 December 7, 2006 9 – 10:30 AM 9 – 10:30 AM 2117 MERF S401 PBB December 13, 2006 December 11, 2006 9 – 10:30 AM 9 – 10:30 AM 2117 MERF S401 PBB
NIH GRANTS.GOV TRAINING SCHEDULE MERF PBB December 6, 2006 December 7, 2006 9 – 10:30 AM 9 – 10:30 AM 2117 MERF S401 PBB December 13, 2006 December 11, 2006 9 – 10:30 AM 9 – 10:30 AM 2117 MERF S401 PBB
Guidelines for Sponsored Projects (Fund 500 & 510) in Deficit Status last updated: 08/20/2006 Overview: A grant or contract is considered to be in deficit when total expenditures exceed the authorized award. Although there are many possible reasons for deficits, some of which may be legitimate and acceptable, deficit balances should be monitored monthly and resolved timely. It is not acceptable for deficits to reside in grant/contract accounts for an extended period of time. A deficit balance on a grant/contract that has ended and will receive no additional funding should be resolved within 30 days of the close of the award, although within 90 days would still be acceptable. If it is determined that additional funding will be received, documentation should be provided to Grant Accounting by the department/PI. As a reminder, it is not appropriate to clear a deficit on a grant/contract by moving it to a different grant/contract. Roles and Responsibilities: Departments/PIs should monitor accounts for deficits on a monthly basis.
A deficit balance on a grant/contract that has ended and will receive no additional funding should be resolved within 30 days of the end of the award.
For accounts that will be receiving additional funding, yet are past the end date of
the award, documentation from the sponsor should be provided by the department/PI to Grant Accounting indicating that additional funding is forthcoming and when it will be expected. Deficits due to considerable delays in the funding will be reported to the University Controller.
Grant Accounting will monitor deficits on a monthly basis.
As soon as Grant Accounting determines that an account is in deficit, the department/PI will be notified by Grant Accounting to provide a status of the account.
If it is determined that an account has gone into deficit before the project end date
and there is no indication that there will be additional funding and/or there is no response to requests for information from Grant Accounting, the department/PI will be notified that the account will be closed to activity within 10 business days.
On a quarterly basis, a report will be distributed to the appropriate departmental administrator and collegiate administrator that will include all deficits related to grants where expenditures exceed the authorized amount.
Deficits should not reside in grant funds, particularly federal grants, for extended
periods of time. Expenditures related to the deficit should be moved to a non-grant fund as soon as possible. If a PI/Department is unable or unwilling to resolve a deficit at the request of Grant Accounting, the deficit will be reported to the University Controller who will notify the Dean and Collegiate Budget Officer.
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Motivation
Widespread and often unnecessary use of SSN increases institutional riskUI commitment to maintaining privacy and confidentiality of SSNFERPA, HIPAA, GLBA, …
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Objectives
Protect privacy and confidentiality of SSN
Eliminate SSN as a publicly visible identifierReduce reliance on SSN for identification
Increase the University’s efforts to manage its information responsibly
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Social Security Number Policy
Governs University use of SSN’sRecognizes use of University ID (Univ ID) as primary identification number for persons with a recurring business relationship (e.g., faculty, staff, students, applicants, affiliates)Eliminates requirement for individuals to provide SSN except where legally necessary or a business necessity
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Social Security Number Policy
Addresses the electronic use of SSN and its use on printed materials, distributed both internally and externally to the UniversityRestricts release of SSN by UIGrades, other student-related personal info cannot be publicly displayed
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Social Security Number Policy
Reasonable precautions must be taken to protect SSN
Employee access as required by job function and business necessitySigned confidentiality statement required; tracked by University Self-Service systemVendor access governed by contractual agreements
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Social Security Number Policy
Discovery of unauthorized release of SSN’s or related confidential information must be reported to
Your management Information Technology Security Office
[email protected] Important: preserve computers for forensic analysis
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SSN Policy – IT Focus
Electronic transfer via secure mechanismEliminate SSN as identifier (key) in database applications, servicesEliminate SSN when no longer needed
Convert SSN to Vendor ID for on-going Research Subject Payments
Confidential/hidden attribute if necessarySearch parameter, but not displayed
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SSN Policy – IT Focus
Logical ProtectionsManaged system – security updatesAccess controls, strong passwords, encryptionFirewall, anti-virus, system logging Separation of function (web, database, file, etc)
Physical ProtectionsSecure location, limited access, environmentals Off-site backups
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Registration of Use of SSN
Require notification to IT Security Officer describing business uses annually by Dec. 31 (2006)
Identifies systems/databases that need to be monitored
Committee to review all uses, evaluate compliance with policy, and determine if continued use is allowed
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Resources
SSN Policy: http://www.uiowa.edu/~our/opmanual/ii/36.htm
Registration of SSN Uses: https://survey.uiowa.edu/wsb.dll/149/ssnregistration.htm
Data Classifications and Handling Requirements (Version 2 draft under campus review): http://cio.uiowa.edu/policy/policy-InstitutionalDataAccess.shtml
Security Best Practices, Resources: http://cio.uiowa.edu/ITSecurity/bestprac/
University of Iowa
Division of Sponsored ProgramsReport Out on Contract Lean EventAugust, 2006
ParticipantsSponsors: Meredith Hay, VPR and David Wynes, Associate VPR Champion: Twila Reighley, Assistant VPR, Director of Sponsored ProgramsParticipants: David Wynes, Associate VPR Wendy Beaver, Sr. Associate Director, DSP Lisa Leff, Assistant Director, DSP Jim Leaven, Assistant Director, DSP Erin Brothers, Program Assistant, DSP Jennifer Lassner, Sr. Associate Director, DSP Charlotte Talman, Director, CTO Kathryn Cox, Licensing Associate, UIRF John Doershuk, Director, Contracts Program, Office of the State Archaeologist Paul Below, Contracts Administrator, IIHR – Hydroscience and Engineering Wendy Jackson, Administrative Specialist, Occupational and Environmental Health Richard Ahrens, M.D., Professor, Pediatrics Chris Manjoine, Application Development and Support, Research Info Systems Audra Haddy, Associate Controller, Grant Accounting Rod McElvain, Contracts Administrator, Grant Accounting Facilitators: Observers: Brooke Langlitz, UIRF Kathy Berry, Rockwell Collins Deb Matney, ISU rep. Laura Reed, UI Organizational Effectiveness Jamy Rentschler, ISU rep.
Case for Change
There have been a variety of complaints orconcerns raised by campus users of the serviceto VPR, Sponsored Program staff andsponsoring entities regarding: Length of time it takes for an initial contract review Length of time it takes for approval or notification of
award Nature of the negotiation and the variances that may
exist related to that part of the process Costing issues related to proposal review
Case for Change Annually, DSP processes 5,180 proposals, awards,
non-monetary agreements, and subcontracts out (funding to other institutions). The contracts come from a widely diverse group of sponsors and vary in complexity and regulatory requirements.
With this Review, we considered sponsored-related contracts directed to UI, about 2% of the grant applications and about 8% of the grant awards (estimated portion that are very complex and require a similar review to contracts), which means for this process, we focused on about 1,780 units.
Another event is scheduled to examine remaining grant process in the future.
Scope This review started at contract development in the unit
or department and ended with DSP post award administration Various steps within DSP and other consultation
and approval by DSP and sponsor to the actual issuance of an Award Activation Authorization Notice by DSP to GAO were included.
Objectives 1 Make recommendations for automation where
appropriate. Identify critical/unique skills or key persons in the
process. Historical knowledge/relationship related to a contract is critical to efficient and effective resolution.
Develop plan for reallocating work within DSP Contract Team related to future state map and determine staffing needed to meet acceptable turnaround times, considering queue and process time.
Develop a communication/training plan for future state to share with stakeholders and general campus as appropriate.
Objectives 2 Determine appropriate metrics and establish
benchmarks that will drive desired behaviors, including but not limited to the following: Decrease average cycle time baseline for current state for initial
contract review, approval and notification. Set significant improvement goal for future state.
Improve customer feedback to 90-95% satisfaction rate Determine acceptable and available processing times for individual
turnaround in order to complete negotiation and UI signature of 65% of contract agreements within two weeks and 85% within 75 days.
Boundaries Contract terms must comply with University policies
and procedures and federal and state regulations. Ensure future state process design is flexible enough
to: Meet changing federal compliance requirements
and expectations Accommodate unique industry and private
organization contract requirements
What the Customer Values
Sponsor Speed, compliance to their terms, low cost, quality
Principal Investigator Speed, ability to spend, protection of interests,
convenience, relationship with Sponsor, status of agreement
University Protection, compliance, funding, relationships,
academic values, consistency, cost and process efficiency, information/data
Public/Human Subject Safety, compensation, access, objectivity
The Academe/Collaborators Academic values, information, consistency, speed
Contracts by Sponsor Type
Business Corporations
20%
State and Local Government
27%
Federal Government
14%
Private, Non-Profit Organizations
11%
Educational Inst./Hospitals
28%
Based on Number of Executed Contracts FY2006 (DSP Only)
Current State Multiple steps Nearly as many waits/delays as there are
steps Significant backlog Excessive loopbacks Limited knowledge and tracking of contract
status within DSP Limited information provided to
PI/Department Very manual process – paper intensive DSP accommodating (to a level of
inefficiency)
Issues Contracts arrive in a variety of ways with
incomplete and inaccurate information Some preliminary negotiation is completed
without contacting DSP for appropriate terms Departmental process may be duplicative Limited education/understanding of routing form
information Non-monetary database limited/separate Routing form arrival varies Many approvals required for routing form Hard copies rather than electronic No deadline or trigger tracking system
Issues Inconsistent communication of contract edits to
departments Requests for status and updates are manual
and ad-hoc Budget errors can occur throughout process With urgent contracts and limited resources,
backlog is exacerbated Duplication of routing form on yellow sheet Coding of contracts can occur at different
stages Budget changes not always communicated to
Grant Accounting Current prioritization is not clearly defined
Issues Sponsor contact is not always known Matching files with contract is labor intensive Contracts are sent to various offices instead of DSP Information gathering from PI occurs at various stages Non-monetary agreements arrive in DSP with inadequate
information Appropriate F&A rate not consistently applied by
PI/department Deadline for regulatory approvals not clearly
communicated
Backlog not fully addressed
Ideal State Characterization Automated where appropriate Good requirements capture early in the process Visibility to all changes/status Roadmap of administrative services Manageable volume Triage potential Protect PI/UI interests Eliminates redundancy Right person at the right time doing the right job Minimized waits Advertises, educates and shows benefit
Future State
Future State
Accomplishments
ReductionHours/#s Weeks Hours/#s Weeks Hours/#s Weeks % Change
# of Steps 45 17 28 62%# of Waits 42 15 27 64%# of Loopbacks 21 10 11 52%
Processing Time in HoursSimple 3.7
Moderate 20 10.6 9.4 47%Complex 32 16 16 50%
Sponsor Wait in HoursSimple - Hours 240 6.0
Moderate 440 11.0Complex 1096 27.4 1040 26.0 56 1.4 5%
Internal Wait in HoursSimple - Hours 55.2 1.4
Moderate 155.2 3.9Complex 1513 37.8 255.2 6.4 1257.8 31.4 83%
Current State Future State Amt Change
What’s New or Changed? More accurate and complete information is available
sooner to DSP and throughout process More information and tools available to PI Electronic viewing and editing status Streamlined contract turnaround times with clear
metrics Work distribution is smarter, the right person is on the
right job Contracts will be triaged according to effort and
complexity up front in process; expedited process for simple agreements
What’s New or Changed?
Less manual paper processes More interactive and collaborative process with PI,
e.g., scheduled conference calls for complex cases prior to Sponsor contact
Potential to eliminate some negotiation steps Improved communication to all stakeholders Improved process metrics that system will deliver Process flow is smoother and more effective and
efficient
Future Metrics Date contract or initial information is received in DSP Date all required information to start contract review is
received Date contract is completed Volume Dollars per contract and total dollars Activity tracking log to identify bottlenecks within process,
inclusive of internal and external contacts Track: Current routing data and additional as required
Budget completion date IRB and IACUC approvals Export control compliance review/date Publication exceptions Conflict of Interest approval Shared credit
Critical Next Steps
Eliminate backlog through reallocation of effort and obtaining additional resources
Electronic team to begin design and incorporate Lean recommendations
Implementation plan in place with follow up meetings to be scheduled
Implementation tasks
August – September start Define categories for triage Define rules and triggers for contacting PI and Sponsors for
follow-up; then develop standard emails Decision RPI – DSP needs to notify staff to accept industry
sponsored CT terms when applicable conditions apply, e.g., CT sponsor initiated, protocol and drug
Communicate Lean Event and Implementation process Define Work Distribution (consider Creep) Determine/Reallocate Roles and Responsibilities across
entire process Finalize Fee For Service Exemption Review whether additional terminology is needed to
accommodate change in contract (e.g., termination clause) Determine how to eliminate backlog
Implementation tasks
September – October start Drop down box for reconciling budget Develop internal sponsored training Analyze need for relocation (examine space) Create DSP Contract email Investigate dual monitors Review building list optionsOctober – November start Education PI’s related to various items including F&A
Rate; faculty are not authorized to approve rate reductions
Implementation tasks
October – November start (continued) Define intake process and points of contact for campus
and sponsor PI Website
Budget tools/worksheet F&A calculator Model agreement
Roadmap to include checklists Sponsor website
Model agreement F&A Rates
Implementation tasks
November – December start Develop container (electronic) and routing
Contract log restarted Non-monetary routing project restarted Communication, tracking, ticklers, date
Convert yellow and pink sheets as electronic information
Develop method (dropdown) for capturing lessons learned at end of process
December – January start Budget Notification to PI
Changes to the Outgoing Subcontracts Process
Workflow will remain in DSP until amendment or subcontract is fully executed
PI and Dept. Contact will be notified by email with a UPS tracking number when the subcontract is sent for signatures
Flow chart and revised subcontract and amendment directions will be put on the web
Revised Sole Source Justification form
Changes to the Outgoing Subcontracts Process
Future revisions:
Workflow will be linked to DSP subcontracts database so PI and department administrators can track subcontracts
View status on the web-based subcontract log – Date sent and UPS tracking number– View draft subcontract– Date signed subcontract is received in DSP – View fully signed subcontract
Research Administrator Meeting
Tuesday, October 17, 2006
Audit Issues – Recent Internal Audit Findings
Sponsored Research Account Monitoring
Deficits Cost Share NIH Salary Cap
Misclassification of expenses Timely completion of PARs
Audit Issues – Recent Internal Audit Findings
Financial Management Monthly Reconciliation of Statement of
Accounts/Transaction Detail Statement Split purchases to get under threshold Verifying purchases against PO Timely submission of PCard vouchers Cash handling
Audit Issues – Recent Internal Audit Findings
General Lack of appropriate record retention
Audit Issues – Recent Federal Audit Findings
Yale University February 2006 DHHS OIG (Department of Health & Human
Services – Office of Inspector General) Audit of subaward from University of
Massachusetts Medical School Under a prime NIH grant – award $572,000 for
period 2/1/2001-8/31/2002
Audit Issues – Recent Federal Audit Findings
Findings: Cost transfers – salary and other costs – late transfers
were not authorized properly, could not be reconciled with acctg records, & lacked clear, specific, detailed explanations
Effort reporting – unsigned effort reports Level of effort – greater than 25 percent reduction of
PIs committed effort Cost allocation method – methodology not recognized
& documentation did not justify amounts allocated
Audit Issues – Recent Federal Audit Findings
Other issues: Subaward was made to Yale four months after
the project started Some of the costs incurred during four month
period were originally charged to other sponsored projects
In some instances, the sponsored project accounts that held the original charges were in overrun status at the time of the cost transfer
Audit Issues – Recent Federal Audit Findings
DHHS OIG recommended disallowances of approx. $194,000
Audit Issues – Recent Federal Audit Findings
At the end of June: NSF, NIH & DOD all requested, via subpoenas, documentation pertaining to 47 grants and contracts totaling approx. $47 million awarded to Yale during the last decade
Audit Issues – Recent Federal Audit Findings
What can we learn from this? Use Advance Accounts when appropriate Importance of good cost transfer policies, practices
that scrutinize cost transfers & thorough documentation
Cost transfers are a target of federal scrutiny, particularly when costs are being transferred from another project When the other project is in deficit status, it is even more
difficult to defend cost transfers
Cost Transfers
What are we doing? Internal subgroup has been established
Analysis: How many cost transfers are occurring? Who is submitting cost transfers? Why are they submitting cost transfers? Are we obtaining appropriate justification?
Expand subgroup to include staff from campus – will be seeking volunteers; let me know if you are interested Develop University policies to require adequate justification
and review Determine if we have appropriate controls in place – do we
need to modify our systems?
OMB A-21 Costing Issues – Direct Charging to Federal Grants
Effective July 1, 1997, the salary and benefits of administrative and clerical staff and certain general expenses, including office supplies, postage, local telephone costs and memberships in professional and scientific organizations, are not allowed as direct charges to federally sponsored agreements, except in special circumstances
http://research.uiowa.edu/dsp/main/index.php?get=adminsal&PassToURL="clerical“
OMB A-21 Costing Issues – Direct Charging to Federal Grants
What are we doing? Continue to make campus aware of issue Currently reviewing A-21 and UI expense
classifications In November – establish subgroup to review
findings and current classifications – include staff from GAO, DSP and possibly campus Determine if additional guidelines are necessary Establish/improve central monitoring
Next Meeting
Tuesday, March 20, 200710:00-12:00
Braley Auditorium - 1136 Pomerantz Family Pavilion