The new Uniform Administrative Requirements for Federal Awards (commonly referred to as Uniform Guidance) mandates that recipients of Federal funds document their process of classifying third parties included in grant proposals as either subrecipients or contractors. In order to meet this requirement, OARS and Grants & Contracts have developed an online form that must be completed, saved as a PDF, and attached to your eSPA proposal record for all proposals that include funds going to a third party.
A separate form is required for each entity to be included in your proposal budget. Although this requirement is for funds from Federal sources, consistency principles dictate that we apply this same scrutiny to all proposals, whether the sponsor is Federal or non-Federal. Nothing is new in the criteria for determining whether a third party is classified as a subrecipient or a contractor — the only thing new is the requirement to document our process for making the determination.
A link to the online form can be found in the Proposal Preparation Resources section of the OARS website, as well as on the Budget and Subcontract pages in eSPA. If you have any questions about this new form, please contact your OARS representative. Use of this form will begin immediately.
Photo of contractor by Amanda Bicknell, from the FEMA Photo Library, via Wikimedia Commons, used under public domain.
Last week at the 9th Annual Meeting for Pre-Award Research Administrators (PRA), sponsored by the National Council of University Research Administrators (NCURA), Jean Feldman, head of NSF’s Policy Office within the Office of Budget, Finance & Award Management, offered a concurrent session in which she updated attendees on happenings at the NSF. A summary of this information is provided below:
NSF issued a new proposal guide on November 20, 2104. Most of the changes in the new document are related to NSF’s implementation of the new UG, as summarized below.
Administrative and clerical salaries and wages can be charged as direct costs as long as: 1) they are explicitly identified in the approved budget or have written approval from NSF and 2) they are integral to accomplishing the goals and objectives of the project and 3) they are not included in the facilities and administrative (F&A) costs base. You must be able to answer “Yes” to the question, “Are these costs necessary to complete the project as proposed?” to charge these salaries and wages as direct costs.
Compensation for care for children, older adults, and other qualifying dependents is allowable for those traveling to attend a Federally-funded conference if those costs are 1) over and above the costs of regular care (e.g., overnight or weekend care) and 2) consistent with regular benefits of the home institution. If the home institution does not normally cover these costs, the Federal government cannot be asked to cover them.
Participant support costs are to be excluded from all Federally-sponsored awards. Any participant support costs listed under “Other” in the participant support category in the NSF budget must be heavily justified.
General operating computing devices that are essential to the project and allocable — even if they are not 100% dedicated — can now be requested under materials and supplies.
NSF will pay an institution’s Federally-negotiated F&A rate unless the NSF Director gives approval to use a reduced rate (as in the case of the MRI program, for example). For domestic sub-recipients, NSF will pay the negotiated rate unless the sub-recipient does not have such a rate, in which case NSF will pay 10% or negotiate an award-based rate with the sub-recipient, at the sub-recipient’s discretion. Foreign sub-recipient will be paid F&A at a 10% rate, unless they already have an existing negotiated rate.
Look for new NSF award terms and conditions to be published by NSF. Once published, ensure our award documents (and subaward documents) are not referencing old documents.
Three new notifications and requests now require prior NSF approval:
Moving funds into the participant support OTHER category
Moving funds into administrative support
Long-term travel by PI
If an NSF deadline falls on a day when the government is shut down by inclement weather, the deadline is postponed to the next day on which the government is open for business.
Each individual prime and sub-recipient budget justification can now run up to three pages.
Ideas Lab is a new merit review strategy/funding mechanism being used at the National Science Foundation to address grand challenges. While Feldman offered no specific information about this program, a “Dear Colleague” letter from January 2014 indicates that the “Ideas Lab process is modeled on the ‘IDEAS Factory’ program developed by the Engineering and Physical Sciences Research Council (EPSRC) of the United Kingdom. The Ideas Lab process starts with submission of a brief application to participate in the Ideas Lab, indicating a Principal Investigator’s interest in and preliminary ideas regarding the specific Ideas Lab topic. A diverse sub-set of participants from a range of disciplines and backgrounds will be selected from the submitted applications by NSF and will be brought together in an intensive, interactive and free-thinking environment, where participants immerse themselves in a collaborative dialog in order to construct bold and innovative approaches. In the IDEAS Factory model, the five-day Ideas Lab culminates with the development of multidisciplinary collaborative concepts by teams of participants; a sub-set of these teams are then invited to submit full proposals.”
Clarification was given on the “2-month salary rule,” which states that a PI may have only two months’ NSF salary across all NSF grants. However, a PI may be able to justify more than two months and re-budget as long as the change does not impact the scope of the project. Such re-budgeting might be justified, for example, in the event that a postdoctoral researcher could not be hired and the PI is therefore required to take over the activities that were intended to be the responsibility of the postdoc.
Technical reports are overdue on the 91st day after a proposal end date.
Final financial reporting must be done in the Award Cash Management system, no later than 120 days after a proposal end date.
All new rules apply to new awards or amended existing awards made on or after December 26, 2014. Therefore, if a new increment is awarded, then the new rules apply to all available funds.
Written by Tricia Callahan, Director of Proposal Development, Office for the Advancement of Research & Scholarship, Miami University.