Sponsored Projects Administration (SPA) Training Program

Sponsored Projects Administration (SPA) Training Program

Sponsored Projects Administration (SPA) Training Program Topics: SPA Training Program A. Research Mission of the University B. Five University Initiatives C. Roles and Responsibilities D. The Life Cycle of a Sponsored Project E. What Every P.I./Administrator Should Know June 15, 2000 2 Five University Initiatives Management and Internal Controls

1. Personnel Policy Guidelines, Section U606.01: Compliance with University Policies and Procedures Communicate to employees their responsibility to adhere to University policies and procedures and report potential or actual violations Affirms commitment that individuals who come forward in good faith shall not be subject to reprisal or retaliation June 15, 2000 3 Five University Initiatives Management and Internal Controls (cont) 2. Financial Policy No. 2101: Principal Investigator Responsibilities for Financial Oversight of Grants and Contracts

Encourages delegation of day to day financial management activities to departmental or Local Business Center personnel Communicate P.I. responsibilities for oversight of financial management of grants and contracts June 15, 2000 4 Five University Initiatives Management and Internal Controls (cont) 3.Principal Investigator Certification: Project Proposals Proposal Transmittal Form (PTF) requires the P.I. to certify his/her: Compliance with University Conflict of Interest policies and

procedures Acceptance of financial oversight responsibilities for the sponsored project June 15, 2000 5 Five University Initiatives Management and Internal Controls (cont) 4. Increased Internal Audit Focus to Supplement Annual OMB Circular A-133 Audit Reinforce importance of compliance with federal regulations and University policy Enhance internal control by identifying problems or potential problems Summary of findings and corrective actions submitted to

University Officers Material adverse findings reported to Department of Health and Human Services June 15, 2000 6 Five University Initiatives Management and Internal Controls (cont) 5. Mandatory Training Program For all University administrative and clerical employees who work in any area of Sponsored Project Management June 15, 2000

7 Roles and Responsibilities Who are the Players? What are their Roles and Responsibilities? June 15, 2000 8 Roles and Responsibilities The Players

Principal Investigator Unit Administrator Department Chair Dean Central Offices Office of the Provost University Research Administration

Comptroller/Restricted Funds Others June 15, 2000 9 Roles and Responsibilities Principal Investigator The primary person in charge of a research grant, cooperative agreement, training or service project, clinical study, contract, other sponsored project or material transfer agreement. Usually a faculty member holding a regular appointment, although other employees may be approved to serve as P.I.s. In some sponsored projects, the P.I. may be referred to as the project or program director.

June 15, 2000 10 Roles and Responsibilities Principal Investigator (Cont) Responsible for the design and implementation of all aspects of the project

Prepares, seeks approval and responsible for Oversight Committee Approvals Develops Research Plan and Technical Proposal Seeks out funding opportunities Prepares technical reports, noncompeting continuations, interim and final reports June 15, 2000 11 Roles and Responsibilities Principal Investigator (Cont)

Determines the budgetary needs of the project Adheres to relevant agency, institutional, divisional and departmental guidelines Reviews and signs Proposal Transmittal Form (PTF) Discloses Inventions Manages all Project Personnel Reviews and adheres to all terms and conditions of award June 15, 2000 12

Roles and Responsibilities Principal Investigator (Cont) Oversees workscope and authorizes payments to consultants and subcontractors Authorizes all expenditures, cost transfers, rebudgeting Updates Assurance and prepares Disclosure Form if significant financial conflict of interest develops

Provides information on closing reports Retains project data and materials as required June 15, 2000 13 Roles and Responsibilities Unit Administrator An employee responsible for providing administrative support to one or more sponsored projects. This position may include a wide variety of roles and position titles including faculty service representative, account manager, grants & contracts administrator, administrative assistant, pre-award administrator, post-award administrator, account assistant, project assistant, secretary, etc.

June 15, 2000 14 Roles and Responsibilities Unit Administrator (Cont) Obtains and reviews proposal guidelines/forms Coordinates and communicates with P.I. to understand relationship between project goals and resources

Prepares (assists with) proposal budget & other administrative documents Prepares Proposal Transmittal Form (PTF) June 15, 2000 15 Roles and Responsibilities Unit Administrator (Cont)

Assures institutional review and approval of proposal Assures submission of proposal to sponsor Assists with regulatory compliance (human subjects, animals, biohazards, etc.) Assists with sponsor inquiries & negotiation of award June 15, 2000 16 Roles and Responsibilities Unit Administrator (Cont)

Assists in establishing account Assists with recruitment, appointment and effort assignment for personnel Reconciles monthly ledgers of expenditures Expedites documentation for purchases, subcontracts, consulting agreements June 15, 2000 17 Roles and Responsibilities Department Head A University official with managerial and fiscal

responsibilities for a designated area, such as department chair, center director, institute director. June 15, 2000 18 Roles and Responsibilities Department Head (Cont) Reviews and approves Proposal Transmittal Form

Reviews and endorses requests for P.I. eligibility Approves cost sharing and matching from departmental funds Expedites request for indirect cost waiver Approves pre-award arrangements and authorizes a guarantee account from which expenditures may be paid if award is not received June 15, 2000 19 Roles and Responsibilities Department Head (Cont) Provides local oversight for the following:

Compliance with regulatory research requirements, as necessary Rebudgeting, cost transfers, and carry forwards Compliance with effort reporting, reporting of program income, and all other award terms and conditions Records retention and data ownership Availability of administrative support, facilities and resources June 15, 2000 20

Roles and Responsibilities Dean A University official with managerial and fiscal responsibilities. Each school, division, or college is administered by a dean under the supervision of the Provost of the University. June 15, 2000 21 Roles and Responsibilities Dean (Cont)

Approves divisional commitments for cost sharing/matching Reviews and approves Proposal Transmittal Form Approves requests to Office of the Provost for P.I. Eligibility Provides divisional/unit oversight for compliance with regulatory research requirements, such as human & animal subjects, radiation safety, etc. June 15, 2000 22

Roles and Responsibilities Dean (Cont) Provides divisional/unit concurrence in negotiation and acceptance of awards Interacts with Comptrollers office and URA in all areas of compliance with proposal and award terms and conditions, as necessary Assists with compliance with technical and financial reporting, as necessary June 15, 2000

23 Roles and Responsibilities BSD/Office of Research Services (BSD/ORS) Office designated by the Dean of the Division of Biological Sciences to review and provide divisional approval for all proposals to Federal and other external sponsors (excluding gifts) assuring compliance with divisional policies. Office oversees regulatory compliance for institutional animal care and use committee, BSD-institutional review board, human use of radioisotopes and radioactive drug research committee, institutional biosafety committee. Director of ORS has been delegated signature authority for University approval of certain NIH and several nonfederal proposals. June 15, 2000

24 Roles and Responsibilities BSD/ORS (Cont) Five Sections: 1. Clinical Trial Office Encourages the growth of Clinical Trial Activity, Management and Conduct of Trials 2. Research Funding Distributes funding opportunity information to BSD faculty and researchers Manages Internal BSD Funding Opportunities Selects Candidates for Limited BSD Program Submissions June 15, 2000

25 Roles and Responsibilities BSD/ORS (Cont) 3. Regulatory Compliance Manages and oversees administrative support for four divisional regulatory research committees June 15, 2000 BSD/UCH Institutional Review Boards (IRB) Institutional Biosafety Committee (IBC) Institutional Animal Care and Use Committee (IACUC)

UC/UHC Combined committee for Use of Radioisotopes in Humans (RDRC) 26 Roles and Responsibilities BSD/ORS (Cont) 4. Grant and Contract Management Reviews all BSD proposals with special attention to oversight committee information and approvals, abstracts and lay summaries, budget and justification, divisional and institutional guidelines and policies Reviews for divisional approval material transfer agreements and clinical trials Approves requests for financial accounts and any postaward modifications for the BSD

June 15, 2000 27 Roles and Responsibilities BSD/ORS (Cont) 5. Director Facilitates Review and Recommendations regarding disclosed conflicts of interest by Dean Approves Cost sharing and matching Funds Commitments, and BSD PI status Designated Signatory Authority on Certain Applications. June 15, 2000 28

Roles and Responsibilities PROVOST The chief academic and administrative officer for all academic units, including the college, the divisions, schools and centers. The Provost oversees the Universitys compliance with all academic research policies. DEPUTY PROVOST The chief academic official designated by the Provost as the person responsible for the direction and guidance of the Universitys research mission. June 15, 2000 29 Roles and Responsibilities

Office of the Provost (Cont) Oversees the formulation and implementation of academic research policies governing all units of the University Approves indirect cost waivers and PI eligibility In cooperation with the Budget Office, authorizes and approves all University budget cost sharing/ matching commitments greater than $100,000 (except BSD) June 15, 2000

30 Roles and Responsibilities Office of the Provost (Cont) Provides institutional oversight for: handling of academic fraud allegations and compliance with other regulatory research policies resolution of potential conflict of interest situations interactions with ARCH regarding research and technology transfer June 15, 2000 31 Roles and Responsibilities

University Research Administration (URA) Office designated by the University with the responsibility to review and provide institutional endorsement for all proposals to Federal and other external sponsors (excluding gifts), assuring compliance with University policies and sponsor terms and conditions. URA is the institutional authority for the negotiation and acceptance of financial support or other contractually-binding obligations in the form of a contract, grant, or agreement, including material transfer agreements and clinical trials. URA is the authorized institutional official for post-award actions necessitating agency approvals: change in P.I., rebudgeting, no-cost extension, etc. June 15, 2000 32

Roles and Responsibilities URA (Cont) Approves and authorizes submission of proposals and award acceptance on behalf of institution Expedites processing and approval of subcontract and consulting agreements Reviews, negotiates and approves Material Transfer Agreements and Clinical Trials Disseminates notification of award and reviews terms

and conditions of award June 15, 2000 33 Roles and Responsibilities URA (Cont) Provides institutional oversight for cost sharing/matching commitments Maintains database of University-wide proposal and

award activity, including the development of TRACS, coming in Summer 2000 Informs Office of Special Projects and ARCH of sponsor intellectual property and invention reporting requirements June 15, 2000 34 Roles and Responsibilities URA (Cont) Coordinates Legal Counsel and Risk Management

reviews and approvals, as necessary Coordinates with ARCH on negotiation and acceptance of intellectual property provisions on sponsored research agreements and MTAs involving patents, licensing and commercialization of University-developed inventions June 15, 2000 35 Roles and Responsibilities URA (Cont)

Disseminates funding opportunity information to university community Provides leadership for electronic research administration planning and implementation June 15, 2000 36 Roles and Responsibilities URA (Cont) Confirms that proposals to sensitive foundations are cleared through development office for

submission Reviews proposals for compliance with university policies and sponsor proposal guidelines and potential award terms and conditions June 15, 2000 37 Roles and Responsibilities Comptroller/Restricted Funds OFFICE OF THE COMPTROLLER The Comptroller, at the direction of the Board of Trustees has supervision over the financial records and accounts of the University. The Comptroller is responsible for keeping proper books of accounts adequately setting forth the financial condition and transactions of the University and shall devise proper methods of accounting and internal

controls for all departments of the University. RESTRICTED FUNDS The unit of the Comptrollers Office that is responsible for the financial accounting, reporting and collecting of funds for federal and other sponsored project awards. Also, this unit is responsible for preparing the Indirect Cost Proposal and negotiating an Indirect Cost Rate Agreement with the Federal Government. June 15, 2000 38 Roles and Responsibilities Comptroller/Restricted Funds (Cont)

Establishes and maintains sponsored project accounts in FAS Enforces University financial policies and federal grant and contract financial regulations Coordinates the preparation and submission of financial reports to the sponsoring agency Manages project account receivables Monitors overdrafts to ensure their timely resolution Ensures that project accounts are closed in FAS

June 15, 2000 39 Roles and Responsibilities Comptroller/Restricted Funds (Cont) Establishes procedures to comply with the sponsors financial terms and conditions for: Allowable cost

Cost transfers Direct costs allocations Cost sharing expenses/matching funds Effort reporting Equipment management and reporting Subrecipient A-133 Audit monitoring June 15, 2000 40 Roles and Responsibilities Comptroller/Restricted Funds (Cont) Establishes procedures to comply with the sponsors financial terms and conditions for (Con't):

Time restrictions on award funds Program income Invoicing/letter-of-credit drawdowns Cash management Cash receipt/expenditure reporting June 15, 2000 41 Roles and Responsibilities Other Players

Office of the Comptroller Payroll Independent Contractor/Travel Reimbursement Property Management Central Procurement Services HRM June 15, 2000 42 Roles and Responsibilities

Other Players (Cont) Facilities Services Radiation Safety Safety and Environmental Affairs Renovations Development / Medical Center Development ARCH Dean of Student Offices (Training Awards, Research

Assistant Appts.) University News Office June 15, 2000 43 Roles and Responsibilities Other Players (Cont) Legal Counsel / Medical Legal Risk Management Hospital Safety

Medical Legal June 15, 2000 44 The Life Cycle of a Sponsored Project Part I. Part II. Part III. Part IV. Part V. Part VI. Part VII. Part VIII. Part IX.

June 15, 2000 Proposal preparation Budgeting Project Costs Compliance Issues Routing and Review Process Updating Submissions and Award Negotiations Award Evaluation and Acceptance Administration Information Award Accounts Managing Programmatic Aspects 45 The Life Cycle of a Sponsored Project (Cont) Part X. Part XI.

Part XII. Part XIII. Part XIV. June 15, 2000 Managing Award Funding Audits Financial Reports Intellectual Property Project Termination 46 Part I. Proposal Preparation Current Forms and Guidelines Web-based information

Campus resources Diskettes Direct to PI June 15, 2000 47 I. Proposal Preparation Deadlines/target dates Target deadline Rolling deadlines Deadline No deadline Receipt date Mailing date Internal deadlines

June 15, 2000 48 I. Proposal Preparation Limited opportunities Coordination of selection process Deputy Provost/Foundation Relations Divisional Departmental Nomination letters Assistance in proposal development

Coordination with Foundation Relations Limited opportunities Sensitive foundations June 15, 2000 49 I. Proposal Preparation Funding Instruments Procurement vehicles Contracts Assistance vehicles Grants Cooperative agreements

June 15, 2000 50 I. Proposal Preparation Major Federal Regulations Office of Management and Budget Circulars (OMB) Federal Acquisition Regulations (FAR) Code of Federal Regulations (CFR) Boilerplate Federal Demonstration Partnership (FDP)Terms and Conditions General Agency Specific June 15, 2000

51 I. Proposal Preparation Funding Instruments (cont) Grant Federal, state and local government, foundations, voluntary associations, corporations Oversight, but not direction P.I. initiated Federal grants subjects to OMB Circular A-110 and agency implementation, may be awarded under Federal Demonstration Partnership (FDP). June 15, 2000 52 I. Proposal Preparation

Funding Instruments (cont) Cooperative agreement (federal) Agency initiated Financial assistance Oversight and some direction; partnership Federal cooperative agreements subject to OMB Circular A-110 Generally not awarded under Federal Demonstration Partnership June 15, 2000 53

I. Proposal Preparation Funding Instruments (cont) Federal contract Federal, state or local government, corporations Procurement of services (research) Sponsor initiated - targeted project Oversight Federal contracts subject to Federal Acquisitions Regulations (FARs) June 15, 2000 54 I. Proposal Preparation Funding Instruments (cont)

Material transfer agreement Incoming/outgoing Incoming - MTA provided by provider Outgoing University of Chicago types: UBMTA UC MTA Sponsored research agreement Clinical trial agreement June 15, 2000 55 I. Proposal Preparation Solicitation Types

Broad agency announcements Request for proposals (contracts/cooperative agreements) Request for applications (grants) Program announcements (grants/cooperative agreements) June 15, 2000 56 I. Proposal Preparation Types of Proposals

Letters of intent Pre-proposals Unsolicited proposals Solicited proposals June 15, 2000 57 I. Proposal Preparation Project Description READ THE GUIDELINES!!! Agency/program specific Sequence/sections specified Use review criteria June 15, 2000

58 I. Proposal Preparation PI Eligibility Two parameters: sponsoring agency/university policy Eligible Faculty tracks Academic non-faculty (ANF) Senior Scientists, Senior Research Associate and RA track (Asst. Professor, Assoc. Professor, Professor) New Hires, not yet in PI eligible positions June 15, 2000 59

I. Proposal Preparation PI Eligibility (cont) Ineligible Research scientist Fellows Lecturer Part-Time (PT) Students BSD Specific Clinical Associate (CA)

RA (Instructor) June 15, 2000 60 I. Proposal Preparation PI Eligibility (cont) Requesting special permission June 15, 2000

Sectional, departmental support and oversight Written request with detailed justification Curriculum Vitae Approval by Dean or designee Approval of URA Final approval by Provost Office 61 I. Proposal Preparation PI Eligibility (cont) Appropriate Reasons Fellowship but agency requires fellow to serve as PI In advance of final approval of appointment Exceptional circumstances on a case by case basis

June 15, 2000 62 I. Proposal Preparation Freedom of Information Act (FOIA) When to mark proposal Proposal subject to FOIA when awarded Protection of proprietary/confidential information To be protected, each proposal page must be marked Post award access to data now required by law

in certain circumstances June 15, 2000 63 Part II. Budgeting Project Costs Budgets Reflect the scope of work of the proposal Compliant with sponsor guidelines Necessary to perform the proposed work and are not precluded by specific program guidelines or applicable cost principles Compliant with departmental, divisional, and University policies and guidelines Narrative justification June 15, 2000

64 II. Budgeting Project Costs Direct Costs Personnel confidentiality of salary data Graduate students Type A; Type B Equipment Consultants Lab supplies Sensitive categories: office supplies, telephone costs June 15, 2000 65 II. Budgeting Project Costs

Direct costs (cont) Subcontracts Graduate student tuition Travel foreign; domestic Publication costs June 15, 2000 66 II. Budgeting Project Costs Verification of current rates Graduate research assistant division dependent Graduate tuition recovery division dependent Fringe benefits choice of rate depends on

nature of employment and source of funding Recharge centers June 15, 2000 67 II. Budgeting Project Costs Verification of current rates (cont) Confirm current rate through Guidelines for Grant & Contract Management Specialized service centers excluded from MTDC overhead Animal Facilities Charge PSD Central Shop Use resource web sites http://www.uchicago.edu/adm/ura/

http://ors.bsd.uchicago.edu June 15, 2000 68 II. Budgeting Project Costs Cost sharing/matching commitments Definitions .Required cost sharing or matching is a programmatic requirement often expressed as a percent of budget request or by requirement of faculty effort without compensation. Required cost sharing should generally not exceed amount required June 15, 2000

69 II. Budgeting Project Costs Cost sharing/matching commitments Definitions (cont) .Voluntary cost sharing is not required, but is sometimes offered to enhance a proposals competitiveness. Voluntary cost sharing, including effort without salary recovery, must be prudently allocated. .Implicit cost sharing occurs when an agency places a cap or limit on budget items; e.g. NIH salary cap June 15, 2000 70

II. Budgeting Project Costs Cost sharing/matching commitments University policy Only when required by sponsor Avoid commitments requiring detailed supporting documentation Designation of source of cost sharing/matching $100,000 threshold requires additional approvals June 15, 2000 71 II. Budgeting Project Costs Consultants Individual expert in the field of the technical

project Use Sponsored Research Consultant Agreement Meet IRS test for independent contractor (should person be a casual employee? Should a subcontract be utilized?) Scope of services June 15, 2000 72 II. Budgeting Project Costs Consultants (cont) Rate of compensation test for reasonableness Rate may be capped by sponsor (e.g. NSF) Former UC employee is special case

Use SRC Invoice PI confirmation of satisfactory performance of service - OK for payment June 15, 2000 73 II. Budgeting Project Costs Subcontracts Organization to organization agreement Use of personnel and facilities Approval from subcontracting institution at the time of proposal submission Scope of work Budget, including subcontractors indirect costs June 15, 2000

74 II. Budgeting Project Costs NIH training Grants Special budget restrictions Stipends are set by NIH Limited post-award flexibility Health benefits Tuition: budget full amount/awarded by NIH formula June 15, 2000 75 II. Budgeting Project Costs NIH modular grants budgets

Designed to focus efforts of investigators and reviewers on science and away from detailed budget No detailed categorical budgets Direct cost budgets in modules of $25K up to ceiling of $250K/year Request the same # of modules for each budget period of project (exceptions permitted) June 15, 2000 76 II. Budgeting Project Costs NIH modular grants budgets (cont) No detailed or summary budget pages in application No annual escalation PLAN AHEAD when

estimating modules Modular budget evaluated on basis of general, expert estimate of total effort and resources required to carry out the proposed research June 15, 2000 77 II. Budgeting Project Costs NIH modular grants budgets (cont) Additional budget information will be requested only under special circumstances Departmental/divisional guidelines may require supporting budget detail Modular awards are issued without direct cost categorical breakdowns significant rebudgeting

provision does not apply. Allocate and account for costs related to award by category within FAS system June 15, 2000 78 Break and Budget Exercise June 15, 2000 79 Part III. Compliance Issues Regulatory compliance Subject Safety, public trust, public perception and scientific responsibility

Emergence of regulations Consequences of non-compliance Historical perspective Tuskegee experiments Nazi human experimentation June 15, 2000 80 III. Compliance Issues Protection of human subjects (cont) Development of ethical principles Nuremberg code

June 15, 2000 Voluntary consent to participate Capacity to consent Freedom from coercion Appropriate research design Minimization of risks Appropriate risk/benefit ratio Freedom to withdraw at any time 81 III. Compliance Issues Protection of human subjects (cont) Development of ethical principles (cont)

Declaration of Helsinki Policies for the Protection of Human Subjects (NIH) Belmont Report June 15, 2000 Respect for persons Beneficence Justice Boundaries between practice and research 82 III. Compliance Issues

Protection of human subjects (cont) Federal regulations DHHS: 45 CFR 46 Federal Common Rule: 1991 - 16 federal agencies FDA: 21 CFR 50 and 56 International Harmonization of Good Clinical Practice Recent HHS Announcement Emerging Requirements for Investigator Training June 15, 2000 83 III. Compliance Issue Protection of human subjects (cont) Applies to:

Any research with human subjects or their information, whether linked or not linked by identifiers to individuals and therefore, must be reviewed and approved by a recognized Institutional Review Board or determined to be exempt Includes: Clinical trials Behavioral research Epidemiological and survey research Outcomes research June 15, 2000 84 III. Compliance Issues Protection of human subjects (cont)

Includes (cont): June 15, 2000 Anthropological research Educational research Field research Oral history 85 III. Compliance Issues Protection of human subjects (cont)

Institutional Official: Associate Vice President for Research Multiple Project Assurance (MPA): M1264 Three IRBs Social Science Division and Social Service Administration, Combined in Summer 2000 Biological Sciences Division/University of Chicago Hospitals (01A and 01B) June 15, 2000 86 III. Compliance Issues Protection of human subjects (cont) Types of review: Exempt from committee review Expedited review

Review by committee June 15, 2000 87 III. Compliance Issues Protection of human subjects (cont) Points to remember: Protocols must be approved by the IRB in full prior to the initiation of any research The informed consent process must be completed before any subject can be enrolled in a study Use of patient charts or radiological films or discarded and unidentified tissues, blood etc, is research and must have IRB approval IRBS are not allowed to circumvent these rules

June 15, 2000 88 III. Compliance Issues Protection of human subjects (cont) Institutions are subject to review Office for the Protection from Research Risks (OPRR): MPA process Query letters On-site reviews Food & Drug Administration (FDA): periodic on-site audits June 15, 2000 89

III. Compliance Issues Protection of human subjects (cont) Resources ORS Web-site: http://ors.bsd.uchicago.edu/HS/ OPRR: http://www.nih.gov/grants/oprr/library_human.htm BSD/UCH IRB Policy and Procedure Manual BSD/UCH IRB Members Handbook FDA: http://www.fda.gov FDA Information Sheets http://www.fda.gov/oc/oha/IRB/toc.htm June 15, 2000 90 III. Compliance Issues

Use of animals Ethical principles: US Government Principles for the Utilization and Care of Vertebrate Animals Used in Testing, Research and Teaching: Transportation, care and use of animals should be in accordance with the Animal Welfare Act Investigators and other personnel shall be appropriately qualified and experienced for conducting the specified procedures on animals The living conditions of animals should be appropriate for their species and contribute to their health and comfort June 15, 2000 91 III. Compliance Issues Use of animals (cont)

US Government Principles for the Utilization and Care of Vertebrate Animals Used in Testing, Research and Teaching (cont): Animals selected for a procedure should be of an appropriate species and quality and the minimum number required to obtain valid results Alternatives to use of animals models, such as mathematical models, computer simulation, and in vitro biological systems should be considered. Procedures that cause more than momentary or slight pain or distress should be performed with appropriate sedation, analgesia, or anesthesia. June 15, 2000 92 III. Compliance Issues

Use of animals (cont) Principles Guide for the Care and Use of Laboratory AnimalsNational Research Council Federal regulations Public Health Service Policy on Humane Care and Use of Laboratory Animals Animal Welfare Act of 1966 (1970, 1976, 1985, 1990) - USDA Endangered Species Act June 15, 2000 93 III. Compliance Issues Use of animals (cont) Institutional Animal Care and Use Committee

(IACUC) Responsibilities Approve all use of animals for research, teaching or testing purposes Review protocols on an on-going basis Provide oversight of the Animal Resources Center Semi-annual program review, includes ARC and inspection of all labs where animals are housed more than 12 hours June 15, 2000 94 III. Compliance Issues Use of animals (cont) Institutional Official: Dean of the Biological Sciences Assurance: (A3523-01)

New: OLAW-Office of the Laboratory of Animal Welfare Single institutional animal care and use committee Animal Resources Center June 15, 2000 95 III. Compliance Issues Use of animals (cont) IACUC Reviews Use of live animals Use of tissue, including tissue from slaughterhouse and/or routine tissue harvest Production of antibodies in live animals, whether on-campus or from vendor

Use of animal parts from dead animals Breeding of colonies June 15, 2000 96 III. Compliance Issues Use of animals (cont) Special considerations Partnership between Institutional Official (Dean Steele), IACUC, ARC and users Occupational health and safety Coordination with other committees Periodic review Good Laboratory Practice AAALAC Accreditation June 15, 2000

97 III. Compliance Issues Use of animals (cont) Resources ORS Web-site: http://ors.bsd.uchicago.edu/ OPRR: http://www.nih.gov/grants/oprr/library_animal.htm USDA: http://www.aphis.usda.gov/ac/ AAALAS: http://www.aalas.org ARC Web-site: http://arc.bsd.uchicago.edu/ ARENA June 15, 2000 98

III. Compliance Issues Use of animals (cont) Training Introduction Monthly Required for all with access to ARC facilities Monthly seminars Mandatory training for biohazards, primates Printed materials June 15, 2000 99 III. Compliance Issues Use of animals (cont)

Special grant related issues June 15, 2000 Who can be PI on a protocol Verifying protocol numbers and date Agency notification NIH requirements: research plan, Section F FAS accounts/regulatory compliance Peer review 100

III. Compliance Issues Use of biohazardous materials Infectious agents Risk to laboratory personnel Risk to general public Recombinant DNA Perceived risk to general public Institutional official: Dean of the Biological Sciences Division Single institutional biosafety committee June 15, 2000 101 III. Compliance Issues

Use of biohazardous materials (cont) Federal oversight and regulations Centers for Disease Control - Biosafety in Microbiological and Biomedical Laboratories (BMBL) NIH Guidelines for Research Involving Recombinant DNA Classification of Etiologic Agents on the Basis of Hazards OSHA Blood Borne Pathogen Standard June 15, 2000 102 III. Compliance Issues Use of biohazardous materials (cont) Principles in biosafety

Biosafety in the laboratory: Prudent practices for the handling and disposal of infectious materials (National Research Council) Four biosafety levels Containment Laboratory practice and technique Safety equipment (primary barriers) Facility design (secondary barriers) June 15, 2000 103 III. Compliance Issues Use of biohazardous materials (cont) Principles in biosafety (cont) Importation and interstate shipment of certain biomedical materials

USDA Department of Transportation Public Health Service Foreign Quarantine Regulations June 15, 2000 104 III. Compliance Issues Use of biohazardous materials (cont) Biosafety Levels I-IV Biosafety Level 1: well characterized agents not known to cause disease in healthy adults and of minimal potential hazard to lab personnel and the environment Recombinant DNA Vectors from viruses

Biosafety Level 2: agents of moderate potential hazard E. Coli, anthrax, chlamydia, most mycobactierim, adenoviruses, hepatitis, retrovirus June 15, 2000 105 III. Compliance Issues Use of biohazardous materials (cont) Biosafety Levels I-IV (cont) Biosafety Level 3: applicable to clinical, diagnostic, teaching, research or production facilities in which work is done with indigenous or exotic agents which may cause serious or potentially lethal infections Mycobacterium tuberculosus, encephalitis

Biosafety Level 4: dangerous exotic agents Hanta virus, hemorrhagic fever, ebola June 15, 2000 106 III. Compliance Issues Use of biohazardous materials (cont) Resources ORS Website: http://ors.uchicago.edu/IBC/index.html CDC: http://www.cdc.gov/od/ohs/biosfty/ bmbl/bmbl-1.htm NIH: http://www.nih.gov/od/orda/ June 15, 2000

107 III. Compliance Issues Use of biohazardous materials (cont) Occupational Health and Safety Human Resources Health Services IBC Coordination with other regulatory committees June 15, 2000 108 III. Compliance Issues Use of radiation Federal/state oversight

FDA Nuclear Energy Commission Illinois Department of Nuclear Safety Oversight Committee on Radiation Hazards Radioactive Drugs and Radioactivity Committee (RDRC) Office of Radiation Safety June 15, 2000 109 III. Compliance Issues Use of radiation (cont) Regulatory requirements Purchasing restrictions

Emission limits No eating IDNS regulatory licenses University - laboratory research Hospital - clinical care and clinical research Annual or more frequent inspections Reports - citations June 15, 2000 110 III. Compliance Issues Use of radiation (cont) Resources ORS Website: http://ors.bsd.uchicago.edu

Radiation Safety Website http://adminet.uchicago.edu/adminfac/frameset/ facframe.html Training Mandatory training with periodic updates Newsletter Office of Radiation Safety June 15, 2000 111 III. Compliance Issues Conflict of interest Federal regulations University policy Assurance Form

Disclosure Form Process of review Approval of management plan by Office the Provost June 15, 2000 112 Part IV. Routing and Review Process Proposal review and clearance Forms and agency guidelines Project personnel Evaluation of scope and nature of work to be performed Representations and certifications University audit and financial reports

June 15, 2000 113 IV. Routing and Review Process Proposal review and clearance Taking exception to binding terms and conditions UC Policy does not accept Approval of publications Indemnification Assignment of intellectual property Recipient organization: The University of Chicago (not Medical Center; not Hospital; not department) June 15, 2000

114 IV. Routing and Review Process Proposal Transmittal Form (PTF) Internal control document (http://www2.uchicago.edu/adm-ura/ura/PTF.pdf) Purpose Instructions Purpose Summarizes Information Mechanism to obtain PI Certification Ensures endorsement of Department and Division June 15, 2000 115

IV. Routing and Review Process PTF (cont) Trouble spots Incomplete data PTF data does not match proposal data Salary and effort of PI and senior investigators does not match up Cost sharing/.matching information incomplete Illegible handwriting Sign offs June 15, 2000 116 IV. Routing and Review Process

Electronic Research Administration (ERA) National Science Foundation FASTLANE URA FASTLANE proposal policies updated February 1999 NIH Commons coming to your proposal soon Many Non Federal Awards and Proposals (AHA, Cystic Fibrosis Foundation, ACS) with more to come June 15, 2000 117 IV. Routing and Review Process Traditional proposal and award procedures URA completes and authorizes Reps and Certs Comment and sign off by URA

Changes required by URA: * requirements versus suggestions Submission to agency dy department Final proposal to URA, BSD/ORS, Division, LBC, department or local unit for files June 15, 2000 118 Part V. Updating Submissions and Award Negotiations Special considerations Changes in Scope or budget Regulatory Approvals Just in Time updates based on priority score assigned by NIH

Updating Current and Pending Support Just in Time updates based on priority score assigned by NIH Best and Final Offers June 15, 2000 119 V. Updating Submissions and Award Negotiations Special considerations (cont) Site visits

June 15, 2000 Inform departmental/divisional/URA offices Office of Special Projects expertise Critical importance of run-through Involve senior academic administrators Assure administrative and financial systems support 120 V. Updating Submissions and Award Negotiations Negotiation of award terms and conditions PI key point of contact for technical

negotiations URA point of contact for business and budget negotiations Review and approval of negotiated technical and budget changes June 15, 2000 121 V. Updating Submissions and Award Negotiations Preaward costs and advance accounts Account create Limitations on advance accounts Postaward considerations Authorities

June 15, 2000 Preaward Costs Rebudgeting Project period No-cost extension Carry-forward authority 122 V. Updating Submissions and Award Negotiations Postaward considerations (cont)

Equipment issues Ownership Reporting Financial reporting requirements Invoicing requirements June 15, 2000 123 V. Updating Submissions and Award Negotiations Receipt of award Email notifications NSF, NIH Award letters unilateral or bilateral Distribution of award information

Acceptance by institutional or authorized official this means URA! Exceptional agreements PI leaving or left University June 15, 2000 124 V. Updating Submissions and Award Negotiations Special cases Clinical studies routing of protocols and proposed agreements Visiting scientists corporate scientific visitors Corporate-sponsored research Gifts and grants and contracts and which is

which is which June 15, 2000 125 Part VI. Award Evaluation & Acceptance Notification of award For most Federal grants: Expenditure of funds constitutes acceptance of award, e.g. NIH, NSF Formal acceptance by Authorized Institutional Official - NOT the PI June 15, 2000 126

VI. Award Evaluation & Acceptance Trouble spots to look for Cost Sharing requirements NSF budget line M Unanticipated budget reductions that could impact scope of work Never assume year-to-year boilerplate is same changes do appear June 15, 2000 127 VI. Award Evaluation & Acceptance

Legal Office Review-URA point of contact Indemnification requirements Unusual certifications and compliance clauses National Laboratory User Agreements June 15, 2000 128 VI. Award Evaluation & Acceptance

ARCH participation in sponsored research & MTA agreements Unusual intellectual property rights & requirements Pre-agreed upon licensing royalty rates for research outcomes Risk Management--URA point of contact Unusual insurance requirements Off campus site conditions June 15, 2000 129 VI. Award Evaluation & Acceptance Notification to URA of PI/departmental/

divisional approval to accept: File Documentation PI Approval (not administrator signing for PI) Acceptance of unusual terms and conditions by department/division Distribution of signed agreement June 15, 2000 130 Part VII. Administrative Information Program and Budget Revisions Federal agency prior approval

requirements Located in For grants: General terms & conditions Agency publications Agency administrative regulations that implement Section 25 of A-110 For contracts The Schedule June 15, 2000 131 VII. Administrative Information Program and Budget Revisions

Federal agency prior approval is mandatory for: Change in scope Change in key personnel Program director/principal investigators: absence for more than 3 months 25% reduction in effort Need for additional funding June 15, 2000 132 VII. Administrative Information Program and Budget Revisions

Federal agency prior approval is mandatory for (cont) Transfer of training allowance funds to other categories Subcontracting project scope Award specific restrictions June 15, 2000 133 VII. Administrative Information Program and Budget Revisions Federal agency prior approvals required

unless waived: Transfers between direct and indirect cost categories FDP awards: All agencies have waived Other awards NIH has waived NSF has waived June 15, 2000 134 VII. Administrative Information Program and Budget Revisions

Federal agency prior approvals required unless waived (cont): Transfers between direct and indirect cost categories (cont) Other awards (cont) NASA reserves the right not to waive DOE has waived unless prohibited by program regulations Others: Check agency publications & regulations that implement A-110 __.25(c)(5) June 15, 2000 135 VII. Administrative Information Program and Budget Revisions

Federal agency prior approvals required unless waived (cont): Costs that require prior approval because of A-21 Include: June 15, 2000 Intra-University Consulting compensation Insurance on federally-owned equipment Equipment

Pre-agreement (pre-award) costs Special arrangement and alteration costs 136 VII. Administrative Information Program and Budget Revisions Federal agency prior approvals required unless waived (cont): Costs that require prior approval because of A-21 (cont) Intra-University consulting compensation Assume no waivers Insurance on federal owned equipment Assume no waivers

June 15, 2000 137 VII. Administrative Information Program and Budget Revisions Federal agency prior approvals required unless waived (cont): Costs that require prior approval because of A-21 (cont) Equipment FDP awards All agencies have waived Other awards NIH has waived for < $25k

NSF has waived Other agencies: Assume no waivers June 15, 2000 138 VII. Administrative Information Program and Budget Revisions Federal agency prior approvals required unless waived (cont): Costs that require prior approval because of A-21 (cont) Pre-agreement (pre-award) costs FDP awards

All agencies have waived prior approval for costs incurred within 90 days of the award Other awards Assume no waivers June 15, 2000 139 VII. Administrative Information Program and Budget Revisions Federal agency prior approvals required unless waived (cont): Costs that require prior approval because of A-21 (cont)

Special arrangement and alteration costs FDP awards NSF has waived only for arrangement and alteration cost < $10k Other agencies have waived Other awards Assume no waivers June 15, 2000 140 VII. Administrative Information Program and Budget Revisions Federal agency prior approvals required

unless waived (cont): One-time no cost extensions FDP awards All agencies have waived Agency notifications required Other awards Research awards Waiver is likely Non-research awards Assume no waivers June 15, 2000 141 VII. Administrative Information Program and Budget Revisions

Federal agency prior approvals required unless waived (cont): Carry forward unobligated balances to subsequent funding periods FDP awards All agencies have waived Agency notifications required June 15, 2000 142 VII. Administrative Information Program and Budget Revisions

Federal agency prior approvals required unless waived (cont): Carry forward unobligated balances to subsequent funding periods (cont) Other awards Research awards Waiver is likely Non-research awards Assume no waivers June 15, 2000 143 VII. Administrative Information Cost Principles

Allowability of costs is determined in accordance with the provisions of A-21, Cost Principles for Educational Institutions A-21 states that specific provisions of the award take precedence Effectively allows awarding agencies to write additional cost principles NIH Grants Policy Statement and NSF Grant Policy Manual address some costs in more detail than A-21 June 15, 2000 144 VII. Administrative Information Cost Principles A-21 reference

For grants: General terms & conditions Agency publications Agency administrative regulations that implement Section 27 of A-110 For contracts The Schedule Contract Clause 52.216-7 June 15, 2000 145 VII. Administrative Information Period of Availability of Funds

Grants Period of availability is governed by by Section 28 of A-110. Section 28 states that where funding period is specified, only allowable costs resulting from obligations incurred during the funding period are allowable. Section 25 of A-110, however, allows awarding agency to give grantee authority to carry-forward unobligated balances to subsequent periods. June 15, 2000 146 VII. Administrative Information

Period of Availability of Funds Contracts Unlike grants, contracts that are incrementally funded do not have those funds restricted to that incremental period. However, The Schedule may specifically restrict funds to a period Funds may be used only for costs incurred within the contracts period of performance June 15, 2000 147

VII. Administrative Information Technical Reporting Requirements Grants Awarding agencies technical reporting requirements must comply with Section 52 of A-110 Section 51 provides among other things that: Reports shall not be more frequently than quarterly, or less frequently than annually Annual reports (Technical and Financial Contracts Reporting requirements will be detailed in the Schedule

June 15, 2000 148 VII. Administrative Information Financial Reporting Requirements Grants Awarding agencies financial reporting requirements must comply with Section 52 of A-110 Section 52 provides: Use of standard forms SF269, 269A, 270 or 272 Reports shall not be more frequently than quarterly, or less frequently than annually

Annual reports (Technical and Financial) shall be due no later than 90 days after the grant year June 15, 2000 149 VII. Administrative Information Financial Reporting Requirements Contracts Reporting requirements will be detailed in the Schedule June 15, 2000

150 VII. Administrative Information Record Retention Requirements Requirement Retain records for a period of 3 years from the date of submission of the annual or final financial report June 15, 2000 151 Part VIII. Award Accounts How many accounts are needed?

Every award needs at least one master account Are new accounts needed for each budget year? Only if carry forward needs agency approval Are additional accounts need to show compliance with T&Cs Are funds restricted by multiple purposes? June 15, 2000 152 VIII. Award Accounts How many accounts are needed? (cont) Additional accounts are needed if both on- and offcampus indirect cost rates are used Additional accounts are needed if cost sharing is

required Additional accounts needed for University management purposes Research may be subdivided into multiple subprojects with their own budgets University requires multiple accounts when award is for student aid that crosses divisional/school lines June 15, 2000 153 VIII. Award Accounts Regulatory compliance Approvals required before account can be created/opened

June 15, 2000 Human subjects Animals Recombinant DNA Biosafety 154 VIII. Award Accounts How are Regular Accounts Created?

LBC-Account Create Process Non-LBC Account Create Process (Awards other than NIH and NSF) Department completes Form 70, Request for Restricted Funds Account - Ledgers 5 and 6 Divisional office reviews and approves URA reviews and approves Restricted Funds creates the account June 15, 2000 155 VIII. Award Accounts Non-LBC Account Create Process (cont) NIH and NSF, AHA and some DOD awards URA e-mails the awards to

P.I. Department Divisional office Restricted funds Restricted funds creates the account Based upon Form 70 template completed by department June 15, 2000 156

VIII. Award Accounts Advance accounts Restricted Funds receives the award from URA Changes the status from Advance to Regular Enters the budget based upon the award agreement June 15, 2000 157 Part IX. Managing Programmatic Aspects Compliance with terms and conditions

of award Publication review Publication citations Sharing research resources June 15, 2000 158 IX. Managing Programmatic Aspects Compliance with terms and conditions of award (cont) Confidential materials--marking and storage Intellectual property--disclosure, informing sponsor

Record retention and storage June 15, 2000 159 IX. Managing Programmatic Aspects Approval of changes to award terms Expanded authority/FDP OMB A-110, plus agency implementation No cost extensions Carry-forward Requiring agency approvals--grants Significant change in PI effort Change in PI

Change in institution June 15, 2000 160 IX. Managing Programmatic Aspects Approval of changes to award terms (cont) Requiring agency approvals--grants (cont)

Significant changes of effort Significant change in scope of work Subcontacting Requests for additional funding Foreign travel Use of non-USA airline June 15, 2000 161 Part X. Managing Award Funding A-21 Cost Principles Requirements Reasonable Reflects action of a prudent person

Generally recognized as necessary Arms-length bargaining Circumstances at the transaction time Institutional policies and practices Allocable Cost can be assigned to a sponsored agreement on the basis of the relative benefits received or some other equitable basis June 15, 2000 162

Part X. Managing Award Funding A-21 Cost Principles Requirements (cont) Treated consistently Costs incurred for Same purpose In like circumstances Are either direct costs only or indirect costs only Cost must Benefit the project and be charged consistently as direct cost Be included in the award budget or list of allowable costs June 15, 2000 163

X. Managing Award Funding Allowable Cost Determinates Costs normally treated as indirect costs Administrative, secretary, & clerical compensation Telecommunications, memberships, postage, office supplies University guidelines for charging appear in Section 307B of URAs Guidelines for Grant and Contract Management June 15, 2000 164 X. Managing Award Funding Other costs that warrant attention Alterations & renovations

May require prior approval Alcoholic beverages Generally unallowable Animals Excluded from indirect cost MTDC base Books and periodicals Normally treated as indirect cost Dependency allowances Generally unallowable June 15, 2000 165

X. Managing Award Funding Other costs that warrant attention (cont) Consultants May require prior approval if substantive work is involved Compensation caps may exist Sponsored Consulting Agreement required Drugs Entertainment costs-Unallowable Property insurance Prior approval needed for government owned property University provided insurance generally allowable June 15, 2000 166 X. Managing Award Funding

Other costs that warrant attention (cont) Medical insurance for sponsored fellows and trainees Allowable because University requires proof of coverage Participant support costs--NSF awards Rebudgeting prior approval required Patient care costs Routine and ancillary medical services Publications Acknowledgements, disclaimers required June 15, 2000 167

X. Managing Award Funding Other costs that warrant attention (cont) Student aid (tuition, fees and stipends) Unallowable charge to federal research awards Salaries and wages % salaries charged must be <= % of effort Unallowable if Annual Certification Statement is not completed Travel Must comply with University travel policies Use of foreign flag-carriers generally prohibited Foreign travel may require prior approval June 15, 2000 168 X. Managing Award Funding

Allocating Costs Guidelines A-21, Section C.4.d & University Financial Policy No. 2109 If a cost benefits one project or activity, the cost should be charged to that project or activity. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost should be allocated to the projects based on the proportional benefit. June 15, 2000 169 X. Managing Award Funding Allocating Costs (cont) A-21, Section C.4.d & University Financial

Policy No. 2109 (Cont) If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the cost may be allocated to benefited projects on any reasonable basis. June 15, 2000 170 X. Managing Award Funding Official Accounting Reports FAS reports Monthly Reports

AM090: Account Statement in Whole Dollars AM091: Report of Transactions Payroll reports Reports generated for each monthly and biweekly payroll Expense Summary Report Expense Detail Report June 15, 2000 171 X. Managing Award Funding Official Accounting Reports Reconcile to shadow reports

Act to correct errors Update cost projections Consider commitments not shown on FAS Reports cease when Acct Admin names are removed June 15, 2000 172 X. Managing Award Funding Cost Sharing Procedures

Accounting documents cost sharing compliance Recorded in separate associate account Funding account is designated FAS cost sharing entry moves expense to funding account See Financial Policy No. 2110 June 15, 2000 173

X. Managing Award Funding Cost Transfers A-21 Costs allocable to an award may not be transferred to another award: To meet deficiencies caused by overruns To avoid restrictions imposed by the terms of an agreement Or for other reasons of convenience Must comply with any agency specific policies June 15, 2000 174 X. Managing Award Funding Cost Transfers

NIH and PHS Grants Policy Statement Requires Timeliness Within 90 days of original transaction Full explanation To correct error is insufficient explanation June 15, 2000 175 X. Managing Award Funding Cost Transfers University policy & procedures Ensure conformance with regulations Policy

Financial Policy No. 2111 Procedures http://adminet.uchicago.edu/admincompt/ costtran/contents.html June 15, 2000 176 X. Managing Award Funding Effort System Required by A-21 Non-compliance results in disallowance of salaries, wages and benefit expense

System characteristics Work plan Monitoring & reporting Significant changes Certification June 15, 2000 177

Part XI. Audits Test for compliance Federal regulations Award specific Non-award specific Not to be feared if UC policies and procedures were followed Award specific restrictions were met June 15, 2000 178

XI. Audits Types of Audit A-133 Award closeout Special subjects Proposal June 15, 2000 179 XI. Audits A-133 Performed by KPMG Federal programs divided into 3 categories Research

Student financial assistance Other Emphasis on UC systems Allowable costs: Salary caps, student aid, etc. Effort reporting Cost transfers June 15, 2000 180 XI. Audits A-133 (cont) Emphasis on UC systems (cont)

June 15, 2000 Period of funding availability Financial reporting Procurement Recharge center pricing Billing Equipment inventory Subrecipient monitoring 181 XI. Audits

A-133 (cont) Tests compliance with award specific restrictions June 15, 2000 Prior approval requirement Cost sharing Student assistance awards unique regulations Training program eligibility Etc.

182 XI. Audits Award interim and closeouts Performed by DHHS Prime contractor Non-federal awarding agency Usually federal direct contracts or subcontract Desk audit vs.. on-site audit Tests for allowable costs

Tests for compliance with award specific restrictions June 15, 2000 183 Part XII. Financial Reports Deadlines A-110 requires agencies to impose filing date deadlines Most are due 90 days after end of reporting period

Non-compliance is reported as an audit finding Types Request for Advance or Reimbursement (SF 270) Report of Federal Cash Transactions (SF 272) Financial Status Report (SF 269, 269A) June 15, 2000 184 XII. Financial Reports Closing Memo

The Closing Memo is a workpaper used to complete FSR (i.e., Financial Status Report SF 269 or 269A) Closing Memo is issued to Account Administrator #1 one month prior to budget or award end date Closing Memo is returned to Comptrollers Office no later than 15 days prior to the FSR due date June 15, 2000 185 XII. Financial Reports When are Closing Memos required? Required for all final FSRs Interim FSRs Required only if prior approval required for carry forward of unobligated balance

June 15, 2000 186 XII. Financial Reports Closing Memo (Cont) Steps to complete: 1. Post the Budget Balance from AM090 2. Add encumbrance balance from AM090 3. Add trailing credit transactions 4. Subtract trailing charge transactions 5. Equal unobligated balance to report 6. Certify the charges are appropriate (allowable) to the award. June 15, 2000

187 XII. Financial Reports Financial Status Report (SF 269, 269A) Steps to complete Step 1: Closing Memo issued to Account Administrator Step 2: Closing Memo returned to Comptrollers Office Step 3: Closing Memo audited by Comptrollers Office Step 4: FSR completed and submitted by Comptrollers Office June 15, 2000 188

XII. Financial Reports Other Financial Reports Request for Advance or Reimbursement (SF 270) Completed for awards not funded by a letter of credit agreement May require Closing Memo Completed by Comptrollers Office Report of Federal Cash Transactions (SF 272) Shows both expenditures and cash receipts Completed by Comptrollers Office

Non-federal reports Similar to federal reports June 15, 2000 189 Part XIII. Intellectual Property University policies Patent Policy Board of Trustees Statute 18 http://ap-www.uchicago.edu/UCPOL/ UCPOLidx.html New Information Technologies Rights to Intellectual Property Determination of who has rights to discoveries in the course of sponsored research/projects?

June 15, 2000 190 XIII. Intellectual Property Data Rights Who has access rights? What are PI responsibilities for retention of data? Do employees who have worked in a sponsored project have the right to remove data, materials from The University when they leave? FOIA public right to federally-sponsored research data OMB issued prescribed implementing regulation Each agency has agency-specific implementation191191 June 15, 2000

191 XIII. Intellectual Property PI responsibility to disclose discoveries Office of Special Projects http://www.uchicago.edu/ adm/spec-proj/ Guidance on Disclosure Process and forms Review of Disclosure to confirm sponsored research and relevant MTAs University turns over disclosure to ARCH

ARCH assesses commercial potential of discovery ARCH has brief period to elect title to disclosure If elected, ARCH seeks appropriate protection for IP June 15, 2000 192 XIII. Intellectual Property Governing regulations for IP derived from sponsored projects Bayh-Dole spells out extensive compliance and reporting requirements for IP elected by ARCH Terms and Conditions of awards for other sponsored projects Compliance obligations Royalty sharing

Release of IP if unelected or ARCH abandons commercialization effort Rights of Sponsors take precedence over rights of PI June 15, 2000 193 XIV. Project Termination Final technical report Sponsor may withhold funding for University if ANY Final Report is overdue Agencies that do this include NEH, Air Force Confirm submission of report to URA URA follows up on late technical reports Administrator, PI, Department Chair, Dean, Provost

June 15, 2000 194 XIV. Project Termination Integration of close out of records with restricted funds Confirmation of Compliance with Technical Reporting requirements Confirmation that Restricted Funds has closed financial report All URA Terminated Project Files archived for at least 3 years after closing of project A-110 records retention requirement Obligations to keep local records June 15, 2000

195 XIV. Project Termination Delete project accounts from FAS Before accounts can be delete Budget balance must be reduced to zero Voucher payable balance and other balance sheet account controls must be zero AM090 and 91 reports stop only after accounts have been deleted Accounting is not completed until accounts are deleted June 15, 2000 196

What Every PI and Administrator Should Know Indicators of problems Unauthorized or inappropriate charges Unallowable costs Improper cost allocations Overdrafts Assignments of costs based on fund availability or project expiration

Frequent delinquent cost transfers Equipment purchases near end of project June 15, 2000 197 What Every PI and Administrator Should Know (Cont) See handout for information on the following topics:

General rules Major federal regulations Performance periods Unallowable costs Cost sharing/matching Salary/effort commitments and reporting Travel and business expenses Equipment purchases Indirect costs June 15, 2000 198

What Every PI and Administrator Should Know (Cont) Budgeting/rebudgeting Cost transfers Program income Monthly account/financial reviews Agency reporting Invoicing

recharge centers June 15, 2000 199 What Every PI and Administrator Should Know (Cont) Regulatory compliance Other research related policies Knowing your resources Consultants/subcontractors

June 15, 2000 200 Acknowledgements

Judith K. Argon, Director of Research Services, BSD Arnold Aronoff, Director of Training, HRM Sandra Bateman, Director of Employee Relations, HRM William J. Hogan, Jr., Comptroller Thomas P. Jurczak, Manager, PSD Local Business Center Lauren McGrath, Grants and Contracts Manager, URA Casey J. Murray, Associate Comptroller for Restricted Funds Mary Ellen Sheridan, Associate Vice President for Research, URA Robert Smentek, Associate Comptroller for Disbursements Lynda Wolter, Associate Director of Research Services, BSD Robert Zimmer, Deputy Provost for Research June 15, 2000 201

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