OSP News

Ohio State implemented the procurement sections of the Uniform Guidance on July 1, 2018.  These regulations are more prescriptive than the guidance we had used before that date.  We believe that the Uniform Guidance regulations increase administrative burden, particularly the $10,000 Micro-Purchase Threshold for soliciting multiple price quotes. In an effort to reduce the impact and keep administrative burden for researchers as low as possible, we requested and received approval from the University’s federal oversight agency to reinstate the $25,000 threshold.

This means that the Micro-Purchase Threshold for Ohio State is revised to $25,000; purchases lower than the Micro-Purchase Threshold do not require multiple quotes or sole source justification.

Additionally, per OMB memo M-18-18, the simplified acquisition threshold is raised to $250,000 from $150,000.  Purchases of $250,000 or higher require competitive bidding or sole source justification.

For detailed information, review the 5 methods of procurement with the new thresholds.

The university has completed negotiations with DHHS for FY19 fringe benefit rates for sponsored programs. These rates will apply through June 30th, 2019.

View the FY19 rates

Effective July 1, 2018, The Ohio State University Office of Sponsored Programs (OSP) will be implementing new purchasing policies and procedures in order to comply with the procurement requirements (2 CFR 200.318 – 326) of the Office of Management and Budget’s “Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards,” commonly known as “Uniform Guidance.” Uniform Guidance changes focus on ensuring full and open competition and increased transparency in the procurement process. In general, the new Uniform Guidance procurement regulations are more prescriptive than the previous guidance (OBM Circular A-110).

We recommend that you read the full text of the procurement sections of Uniform Guidance.  Additional information is posted on the OSP website:

• Procurement
• Uniform Guidance

OSP Procurement staff are available to assist you with the new regulations and answer any questions you may have. Call 614-292-6871 for assistance.

Per NIH notice NOT-OD-18-137 (as finalized in legislative mandates notice NOT-OD-18-181), the salary cap for grant, cooperative agreement and contract awards remains tied to Federal Executive Level II. Effective January 7, 2018, Executive Level II increased to $189,600, up from $187,000.

Investigators may use the 2018 cap of $189,600 in preparing proposal budgets. However, in keeping with the practice we have used in the past, Ohio State will start utilizing the new cap limit for salary cap processing on eligible projects effective July 1, 2018. The reason for this practice is to mitigate to some extent the impact on current awards where funds will have to be re-budgeted to cover the increased salary costs.

For additional information, contact your Sponsored Programs Officer.

The ePA-005 was recently updated to better meet the requirements of today’s regulatory environment and to help guide whether grant congruency review is needed. Grant congruency review is an evaluation of a grant proposal awarded compared to the associated research protocol to ensure consistency in the research activities that will be conducted and the protection of human and animal subjects. Congruency review may be required by federal sponsors according to applicable regulations.

As soon as the investigator learns that he or she has a score that is likely in the fundable range, the principal investigator should contact the Office of Responsible Research Practices (ORRP) and their Sponsored Program Officer (SPO).

To obtain guidance on the congruency review process please contact the following:

• Human Subjects Research: hscongruencyreview@osu.edu
• Animal Research: IACUCinfo@osu.edu
• Office of Sponsored Programs: Sponsored Program Officers

Waiting for the Notice of Award from the sponsor prior to initiating the congruence review process may increase the possibility for a delay in the release of funds.

Additional investigator guidance on grant congruency can be found here:

• Human Subjects Research FAQs
• Animal Research FAQs

MESSAGE FROM RANDY MOSES, INTERIM SENIOR VICE PRESIDENT FOR RESEARCH

Congress ended the three-day federal government shutdown on Monday, January 22, 2018,  by passing a stopgap bill that keeps federal funds flowing through February 8. However, there remains the possibility that we could face another shutdown.

We do not expect that another brief shutdown will have a major impact on the direct conduct of research projects at Ohio State. The impact could be significant in the event of a longer shutdown.

During a shutdown, here is what you can expect, based on our recent experience:

• Work on federally funded projects can go forward as usual unless the funding agency issues a stop work order. In such cases, the Office of Sponsored Programs would receive a project specific notification. A stop work order is more likely to happen for contracts than grants.
• Many federal websites and business applications including NIH.gov, NSF.gov, nifa.usda.gov, FastLane, and Research.gov will likely either be unavailable or have disabled features. Grants.gov and some other federal systems would continue to operate, but have little or no support for problem resolution. Other systems, e.g., FastLane, would not be available.
• Federal agency program officers and grants management staff would not be available to answer questions, approve requests, etc.
• Much of the administration relative to federal funding would be on hold. New funding opportunities would not be issued, panel reviews would be postponed, and no new grants or no-cost extensions would be awarded. Federal agencies have filed shutdown contingency plans that provide information about what might happen during a future shutdown.

We recommend that investigators continue proposal preparation and internal submission. If a shutdown occurs, our Office of Sponsored Programs will hold proposals centrally until federal systems are functioning again.

Additional information is available in an Office of Management and Budget memorandum outlining issues related to the federal government’s Planning for Agency Operations during a Potential Lapse in Appropriations.

Should a shutdown occur, the Office of Research and Office of Sponsored Programs websites will be updated with information that is critical to the conduct of your research.

Office of Research staff will provide an overview of the new, redesigned PI Portal, demonstrate its enhanced features and address questions related to its use. This session is intended for faculty as well as department and college staff who use the PI Portal to access project financial information.

Sessions are filling up, new dates will be added to meet the demand. Click here to view the scheduled training.

Contact Kari Uhl for additional information.