Sponsored Programs: Fundamentals & Lifecycle Tutorial

1. Navigating the Basics ofSponsored ProgramsA Training Tutorial for Faculty and Staff Office of Sponsored Programs Web Tutorial as of 11/18/09

2. This Tutorial Will Cover: • Sponsored Program Lifecycle • Sponsors, Proposals & Funding Mechanisms • Typical Proposal Components • Cost Types • Regulatory Environment • Roles • Compliance • Red Flags • Key WPI Contacts Office of Sponsored Programs

3. The Sponsored Program Lifecycle Office of Sponsored Programs

4. Who Are Our Sponsors? Examples include… • Federal • National Institutes of Health • National Science Foundation • National Endowments for the Arts/Humanities • Department of Defense (Air Force, Army, Navy) • State • MA Board of Library Commissioners • MA Technology Collaborative • Industry • Intel Corporation • The MathWorks • Raytheon Corporation • Foundations, Associations, Foreign Organizations • Alfred P. Sloan Foundation • EADS Company Foundation Office of Sponsored Programs

5. Proposal Types Letter of Inquiry - Used by foundations for screening to second stage Concept Paper - Generally, an internal working document used to solicit informal feedback White Paper - A concept paper (either unsolicited or required in advance of a full proposal) sent to a sponsor Preliminary Proposal - Often, the first stage of a two-stage submission process that can be either requested or required by a sponsor Formal (Full) Proposal - the submission used by a sponsor to determine whether a program should be funded or rejected. Full proposals are submitted as new, non-competitive continuation, competitive continuation (also called competing renewal), and supplement Office of Sponsored Programs

6. Funding Mechanisms • Sponsors use formal agreements and these agreements represent exchange transactions (i.e., the sponsor receives something of value in exchange for having provided funding) • Funding mechanisms • Grant (financial assistance) • Cooperative Agreement (financial assistance) • Contract (procurement or “purchase of services”) • The mechanism (e.g., financial assistance vs. procurement) is determined by sponsor according to the performance requirements, sponsor involvement, and activity type of the project Office of Sponsored Programs

7. Funding Mechanisms • Grant • project conceived by investigator • investigator defines details and retains scientific freedom • used to transfer money, property, services, or anything of value to recipient to accomplish a specific purpose • considered to be financial assistance or "support" • no substantial involvement between sponsor and recipient during project performance • Cooperative Agreement • much like a grant...used to transfer money to recipient to accomplish a specific purpose • also considered to be financial assistance, but... • substantial involvement in the project by both sponsor and recipient Office of Sponsored Programs

8. Funding Mechanisms • Contract • project conceived by sponsor • used to acquire product or services for the direct benefit or use of sponsor • generally requires strict adherence to budget • sponsor exercises direction or control • most contentious award instrument on issues such as ownership, indemnification, etc. Office of Sponsored Programs

9. Typical Proposal Components Most formal (full) proposals submitted to the federal government and/or in response to a formal sponsor announcement will contain many of the proposal components listed on the following slides Formatting varies widely by sponsor and type of proposal (hard copy vs. electronically submitted) Less formal proposals minimally include a cover page, scope of work, budget, and budget justification Office of Sponsored Programs

10. Typical Proposal Components Title/Cover Page with appropriate signatures  Table of Contents  Abstract/Project Summary (normally no more than a single page) Statement of Work/Project Description Bibliography Personnel Vitae (normally, for key persons only) Current and Pending Support Budget for submitting organization and any collaborators Budget Justification Facilities/Resources Statement Representations, Certifications, and Assurances Appendices (as needed and judiciously selected) Office of Sponsored Programs

11. Cost Types • Direct Costs - Direct costs are defined by the federal government as "costs that can be identified specifically with a particular sponsored project, an instructional activity, or any other institutional activity, or that can be directly assigned to such activities relatively easy with a high degree of accuracy." • Examples include: • Personnel • Equipment • Travel • Professional Services/Consortium/Contractual Costs • Materials & Supplies • Other Direct Costs (e.g., tuition, publications, service center costs) Office of Sponsored Programs

12. Cost Types • Indirect costs (a.k.a., overhead), which are now officially called Facilities and Administrative (F&A) costs by the federal government, are defined as "costs that are incurred for common or joint objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project, instructional activity, or any other institutional activity." • Indirect costs are charged as a rate and include expenses that cannot be charged directly to grants and contracts, such as: • lights and heat • snow removal • office supplies • building maintenance • the services of administrative offices (e.g., OSP, Accounting) Office of Sponsored Programs

13. Sample Budget Office of Sponsored Programs

14. The Regulatory Environment Office of Sponsored Programs

15. The Regulatory Environment Office of Sponsored Programs

16. Federal Regulations As a Principal Investigator, some of what you need to know about Tier I (Regulations) is summarized on the next few slides. This generalizable knowledge will help you to determine where to look and which questions to ask in order to avoid any unnecessary involvement in “red flag” transactions. Office of Sponsored Programs

17. Federal Regulations (Tier 1) • Cost Principles for Educational Institutions (OMB Circular A-21) • Guide to determining direct and indirect costs on federal awards • Defines what is normally allowed and not allowed on Federal grants – exceptions for “major programs” • Allowable • Direct expenses, such as salary, travel, project-related supplies, research assistants, publications, etc. • Also, an expense may be allowable, but not as a direct expense because it is included as part of the indirect cost calculation (e.g., general supplies) • Unallowable • Entertainment, air travel on a foreign carrier (under most circumstances), lobbying costs, alcoholic beverages, subscriptions, memberships, etc. Office of Sponsored Programs

18. Federal Regulations (Tier 1) • Cost Principles for Educational Institutions (OMB Circular A-21) • You should become familiar with the following two sections of Circular A-21: • Section F.6.b describes departmental administration expenses and why certain costs may not be charged directly to awards • Section J of this circular explains the allowable and unallowable cost categories • Visit: http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html Office of Sponsored Programs

19. Federal Regulations (Tier 1) • General Administrative Requirements (OMB Circular A-110) • Prescribes standards for consistency and management of federal funds • Primary concerns for PIs are in: • Subpart C Post-award requirements • Subpart D After-the award requirements • To learn more, please visit: http://www.whitehouse.gov/omb/circulars/a110/a110.html Office of Sponsored Programs

20. Federal Regulations (Tier 1) • General Administrative Requirements (OMB Circular A-110) • Subpart C Post-award requirements • Relates payment to performance • Defines qualifying cost sharing or matching • Prescribes methods for calculating program income • Specifies requirements for re-budgeting actions, no-cost extensions, absence of PI, etc. • Covers audits and allowable costs (Circular A-21) • Defines requirements for property standards • Establishes procurement standards • Reports and records (how long and types) • Prescribes conditions for termination and enforcement Office of Sponsored Programs

21. Federal Regulations (Tier 1) • General Administrative Requirements (OMB Circular A-110) • Subpart D After-the award requirements • Sets forth closeout procedures (e.g., timing, property, accountability) • Prescribes subsequent adjustments and continuing responsibilities of awardees (e.g., disallowed costs, refunds of Federal cash, code of conduct, property requirements, record retention) Office of Sponsored Programs

22. Federal Regulations (Tier 1) In addition to OMB Circulars A-21 and A-110, you should understand that the mechanism for determining whether the University has successfully complied with these regulations is contained in another circular – OMB Circular A-133 (Audits of States, Local Governments, and Non-Profit Organizations). Each year, WPI is audited on 14 separate compliance points to determine that it has complied with OMB Circulars A-21 and A-110, and other applicable award requirements. Office of Sponsored Programs

23. Federal Regulations (Tier 1) • Audits (OMB Circular A-133) • Defines auditee (WPI) responsibilities • Prescribes subrecipient monitoring requirements • Sets forth 14 separate audit tests to determine compliance (e.g., allowability, allocability, records management, and timeliness, accuracy and completeness of reporting) • To learn more, please visit:http://www.whitehouse.gov/omb/circulars/a133/a133.html Office of Sponsored Programs

24. Federal Regulations (Tier 1) • Federal Acquisition Regulations (FAR) • Regulations that apply to contracts (codified at Title 48 of the Code of Federal Regulations) • Each agency uses its own version for procurement actions (e.g., NASAFAR, DFARS, etc.) • Incorporates OMB Circular A-21, Cost Principles for educational Institutions • To learn more, please visit: http://www.arnet.gov/far/ Office of Sponsored Programs

25. Other Federal Regulations • Depending on the scope of your program and the terms and conditions of your awards, other federal regulations will often apply, including: • Fly America Act – requires use of a U.S. flag carrier for foreign travel • Export Control Regulations (with prior approval of WPI senior administration) • E-Verify – requires verification of eligibility to work on qualifying federal contracts Office of Sponsored Programs

26. Sponsor Guidelines (Tier 2) The purpose of these guidelines is to implement the Tier 1 federal regulations and supplement them with agency-specific requirements. Links may be found at: http://www.wpi.edu/Admin/Research/Sponsored/guidelines.html Examples include : • NSF Proposal and Award Policies and Procedures Guide (PAPPG) • NIH Grants Policy Statement • NASA Grant and Cooperative Agreement Handbook Office of Sponsored Programs

27. Award Terms & Conditions (Tier 3) • On Federal Awards • Additional terms and conditions may be added beyond the previously described sponsor guidelines (e.g., NSF conference grant guidelines, NIH training grant guidelines) • On Non-Federal Awards • Corporations and foundations often impose conditions that are more strict than federal regulations Office of Sponsored Programs

28. Roles Office of Sponsored Programs

29. Areas of Responsibility • Principal Investigator • Completion of the project scope of work • Managing, processing, and justifying project expenses • Monitoring the activities of subrecipients • Submission of required technical or narrative reports • Completion of reports for compliance (e.g. IRB, IACUC, etc.) • Disclosure of inventions during the project • Technology Transfer Office • Determining the potential of inventions disclosed • Filing patent applications • Reporting to sponsors on inventions or patents • Negotiating terms of licensing agreements • Assignment of rights to inventions Office of Sponsored Programs

30. Areas of Responsibility • Property Administration • Tag, inventory, manage and determine disposition for all equipment purchased with sponsor funds • Screen for same, like or substitutable items • Report on status of equipment purchased • Research Accounting • Award set-up and creation of budgets • Monitoring and approval of expenditures • Submission of invoices and other cash management activities (e.g., reconciliations, drawdowns, etc.) • Completion of financial reports • Distribution of and follow-ups on effort certification reports • Coordinate financial closeout of awards Office of Sponsored Programs

31. OSP Responsibility • Negotiating, accepting and transmitting awards • Acting as principal liaison with sponsor for approvals and award modifications • Monitoring non-financial compliance with sponsor terms and conditions • Coordinating non-financial close out activities between WPI and sponsor • Contacting PI for technical report • Contacting Research Accounting for financial report • Contacting Property Administration for property report • Contacting Technology Transfer Office for patent report • Collecting report documentation for files • Responding to auditor inquiries regarding compliance Office of Sponsored Programs

32. Compliance Office of Sponsored Programs

33. Why Should You Care About Compliance? University of MinnesotaMisuse of federal funds $32 million University of Alabama BirminghamEffort Certification & Clinical Research Billing $3.4 million Northwestern University Committed Time and Effort $5 million Yale University Cost Transfers/Salary Charges $7.6 million New York University Medical CenterInflated Research Grant Costs$15.5 million Duke University Administrative and Clerical Expenses on Awards $1.7 million Florida International UniversityEffort Certification & Direct Cost Disallowances$11.5 million Harvard/BIDMC Costing Issues $3.25 million Non-Compliance Results at Other Institutions Johns Hopkins University Effort Certifications$15.5 million East Carolina University Questioned Costs HHS/OIG Audit $2.4 million Office of Sponsored Programs

34. Sponsor Reporting Requirements • Technical, Progress, and/or Narrative Reports • Project Deliverables • Property Reports • Expenditure and Other Financial Reports • Cash Management Reports • Invention or Patent Reports • Time and Effort Reports (Internal only, but reviewed by auditors to verify reported effort is reasonable in relation to salary charges) • ARRA Reports, as applicable Office of Sponsored Programs

35. Institutional Review Board • Human Subject use in Research (IRB) • PI is responsible for compliance with DHHS protection of human subjects regulations-45 CFR Part 46 • PI is responsible for compliance with FDA’s regulations for investigational new drugs and medical devices-21 CFR Part 50 • The IRB supports efforts of Investigators to conduct research which protects the rights and promotes the welfare of human subjects Office of Sponsored Programs

36. Institutional Review Board • WPI IRB reviews non-federally and federally sponsored human subject research • Online human subjects training and certificate of completion required • Annual reviews of protocols and adverse event reporting • Chairperson, Kent Rissmiller x5019 and Secretary, Ruth McKeogh, x6699 • http://www.wpi.edu/Admin/Research/IRB/ Office of Sponsored Programs

37. Animal Care and Use Committee • Institutional Animal Care and Use in Research (IACUC) • PI is responsible for compliance with Public Health Service Policy (PHS) on humane care and use of laboratory animals-review every 3 years • PI is responsible for compliance with USDA established standards for overseeing the humane care and treatment of animals and compliance with the Animal Welfare Act-annual reviews • IACUC oversees and evaluates programs, procedures and facilities for the proper care, use and humane treatment of animals • Chairperson and contact, Glenn Gaudette, x6086 • http://www.wpi.edu/Admin/Research/IACUC/ Office of Sponsored Programs

38. Export Controls • PI is responsible for compliance with the Federal Export Control laws • ITAR – Department of State • U.S. Munitions List • EAR – Department of Commerce • Dual Use Technology and Articles • OFAC – Department of Treasury • Economic Trade Sanctions • Compliance may include securing lab facilities, restrictions on researcher and/or student participation, restrictions on transmittal of information, and prepublication review/approval • http://www.wpi.edu/Admin/Research/ExportControls/ Office of Sponsored Programs

39. Safety • Biological, Radiation, Occupational and Laboratory Safety • PI is responsible for complying with a variety of federal regulations and WPI policies associated with each type of safety issue • Online lab safety training requirement for lab safety • Reports to Safety Office, Dave Messier, x5216 • http://www.wpi.edu/Admin/Safety/ Office of Sponsored Programs

40. Red Flags Office of Sponsored Programs

41. Be Prepared for Anything… Office of Sponsored Programs

42. Risk Areas • Some of the most common and highest risk areas that create “red flags” are: • Cost transfers that are not properly justified, are not timely, and/or attempt to move a deficit from one award to another • Inaccurate effort reporting and failure to match pay for performance • Failure to perform subrecipient monitoring activities to ensure performance • Erratic spending patterns, especially just prior to expiration to use available funds Office of Sponsored Programs

43. WPI Contacts • Controller • Rich Rogan, x5850, rrogan@wpi.edu • Research Accounting Manager • Heather Bilotta, x5422, hbilotta@wpi.edu • Technology Transfer Director • Mike Manning, x5834, mmanning@wpi.edu • Property Administrator • Clarence Plant, x5137, cplant@wpi.edu • University Compliance Officer • Mike Curley, x6919, mjcurley@wpi.edu Office of Sponsored Programs

44. OSP Contacts • Director • Franc Lemire, x5811, flemire@wpi.edu • Associate Director, Pre-Award • Ted Russo, x5583, trusso@wpi.edu • Associate Director, Post Award • Tina DeVries, x6716, cdevries@wpi.edu • Assistant Director • Tammy Houle, x5489, thoule@wpi.edu • Sponsored Programs Coordinator • Karen Rossow, x5359, krossow@wpi.edu Office of Sponsored Programs

45. Please Contact OSP with Questions about This Tutorial Office of Sponsored Programs