OSP News

Per the Federal Register notice dated 05/17/2017, The Ohio State University is delaying implementation of the new procurement requirements in OMB 2.CFR.200.320 until July 1, 2018.  The university will continue to comply with the procurement standards in the OMB guidance at 2 CFR §200.110(a) until that time.

Per NIH notice NOT-OD-17-049, the salary cap for grant, cooperative agreement and contract awards remains tied to Federal Executive Level II.  Effective January 8, 2017, Executive Level II increased to $187,000, up from $185,100.

Investigators may use the 2017 cap of $187,000 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, 2017.  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 Final Research Performance Progress Report (F-RPPR) will replace the Final Progress Report (FPR) for grants closeout, effective January 1, 2017.  The F-RPPR will be available for use in eRA Commons on January 1, 2017.

What This Means for You

If you have a final progress report due, and you wish to use the old FPR format of an uploaded document, you must submit the FPR before January 1, 2017. NIH will no longer accept any of the old format FPRs on or after January 1, 2017.

The Format

The format of the Final RPPR is very similar to that of the annual RPPR, the notable differences being the F-RPPR does not have sections F (Changes) and H (Budget).

Also, please note that just as with annual RPPRs, once completed, you will need to route the F-RPPR to your SPO so they can submit it.

The Changes

The F-RPPR does have a new section: Section I (Outcomes).  Project Outcomes (Section I) will be made publicly available, allowing recipients the opportunity to provide the general public with a concise summary of the public significance of the research

A significant change with implementation of the F-RPPR, is that in order to maximize public transparency, NIH will not maintain the current Type 2 policy which in accordance with NIHGPS Chapter 8.6.2 states that “whether funded or not” the progress report contained in the Type 2 application may serve in lieu of a separate final progress report. As a standard policy, NIH will request that organizations submit an “Interim-RPPR” while their renewal application (Type 2) is under consideration. In the event that the Type 2 is funded, NIH will treat the Interim-RPPR as the annual performance report for the final year of the previous competitive segment. If the Type 2 is not funded, the Interim-RPPR will be treated by NIH staff as the institution’s Final-RPPR

Deadline Remains Unchanged

The deadlines for submitting a Final RPPR remain the same – no later than 120 days from the project end date.

The NIH says that FAQs and additional information pertaining to NIH’s implementation of the F-RPPR, including instructions, will be available on the NIH RPPR website in the near future.

The university has just completed negotiations with DHHS on a 4 year F&A rate agreement. The agreement, dated September 23, 2016 establishes the rates shown below. These rates will apply through the end of FY20 and will continue to be used after that date until a new rate agreement is established.

MTDC (Modified Total Direct Costs) means all costs except equipment (stand-alone items with a useful life of a least 1 year and a unit cost of at least $5,000); capital expenditures (alterations and renovations); patient care costs; tuition; scholarships and fellowships; rental of off-site facilities; participant support costs; and subaward costs in excess of $25,000.

Please see the rate agreement for additional information about on-campus/off- campus designations and the components of the F&A rate.

Implementation

New proposals

Investigators should begin using the new rates in proposals immediately. For example, if proposing work that runs 7/1/17 – 6/30/20, use 55% for the first budget year (7/1/17 – 6/30/18) and 56% for the second and third budget years (7/1/18-6/30/20).

For awards that begin mid fiscal year, and therefore two different F&A rates would apply, it may be reasonable to assume a constant burn rate throughout the year, and therefore costs may be prorated in the proposal budget, e.g., in the first year of an award with a start date of Jan 1, 2018 F&A would be charged at 55% for the first 6 month and at 56% for the second 6 months. Or, you may use average rate of 55.5% for the 12 months.

New or competing continuation proposals submitted but not yet funded

OSP will work with sponsors to obtain the new F&A rate whenever possible. However, if we cannot obtain additional funds, direct costs will be protected and will not be reduced to cover the increase in F&A rate.

Currently active projects

These projects will continue to be charged their current rate, as proposed and awarded, until the next competitive segment or other natural break point.

If you have questions, please contact your department’s sponsored program officer.

When do the changes go into effect?
NASA issued the RESEARCH OPPORTUNITIES IN SPACE AND EARTH SCIENCES – 2016 (ROSES-2016) on February 19, 2016. The changes in this document are effective for applications and proposals that are submitted on or after April 22, 2016.

The two major changes of note are:

• NASA no longer wants salary, fringe benefit or indirect costs (F&A) to appear in any section that a reviewer may see, as they do not want this information to influence reviewers’ judgement of the proposal.
  • As a result, this information should be left off of the budget justification and anywhere else in the body of the proposal.
  • The entire budget (including the personnel and F&A amounts excluded everywhere else in the proposal) should be entered accurately into the budget section on NSPIRES, and uploaded to the Proposal Attachments section using the new “Total Budget” option.
• Current and pending support is only required for funded Co-Is who are proposing to work at or above 10% of that person’s total effort (0.1FTE) on the project. A current and pending support form is still required for the PI regardless of their effort amount.

See Section I(c) of the ROSES-2016 Summary of Solicitation for a complete list of the changes to ROSES this year.

Additional changes and details can also be viewed on NASA’s FAQ website.

A new training requirement will go into effect on October 1, 2016, that will impact your continued access to information in the PI Portal.

The Office of the CIO recently revised the Institutional Data Policy that classifies all university records and data as public, internal, private or restricted. Some data related to research grants falls into the restricted category—specifically voucher/invoice images displayed in the PI Portal and in the Subaward Invoice Approval (SIA) application. Additional controls will be required for access to restricted data, including completion of the university’s Institutional Data Policy Training.

What does this mean for you?

• As of October 1, 2016, in accordance with university data security policy, access to voucher/invoice images will be removed in the PI Portal and SIA for all users pending completion of the required Institutional Data Policy Training.
• In order to retain access to this information, all principal investigators must complete the online training by September 30, 2016. Instructions for enrolling in the training are available on the CIO’s website. The course and assessment will take about 40 minutes to complete.

It is important for you to retain access so that you can continue to review subaward invoices for payment approval (as required by the federal Uniform Guidance governing grants) and monitor expenditures on your awards.

Why is this necessary?

Cyber security is of increasing concern for universities. NBC reported last fall that from 2013 to 2015, 550 universities reported some kind of data breach, and in 2014, only the health care and retail sectors reported more security breaches than the education sector. These breaches result in violations of individual privacy, reputational damages and high financial cost, often in the multi-million dollar range. Universities may also face regulatory non-compliance penalties and civil litigation as the result of a breach.

If you have questions, please contact Christine Hamble at hamble.3@osu.edu or 614-688-8734.

We very much appreciate your willingness to work with us and the Office of the CIO to ensure the safety and integrity of all data at Ohio State.

The university plans to stop doing business with Santa Cruz Biotechnology when their dealer license is terminated on December 31, 2016.

For Questions or concerns regarding purchases from Santa Cruz Biotechnology or finding alternative suppliers contact The Office of Sponsored Programs Purchasing at 614- 292-6871.

For more information download the message from Jan Weisenberger and Christine Hamble.