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May 21, 2013 Research Administrators Workgroup

May 21, 2013 Research Administrators Workgroup . Agenda. Introductions Announcements / Updates NIH Public Access Policy ( Pam Hastings ) FY12 PHS Consolidated A-133 Report (Raquel Espinosa ) Billing Agreements / Partners Internal Direct Charging Unilateral Agreements Q & A – All .

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May 21, 2013 Research Administrators Workgroup

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  1. May 21, 2013Research Administrators Workgroup

  2. Agenda Introductions Announcements / Updates NIH Public Access Policy (Pam Hastings) FY12 PHS Consolidated A-133 Report (Raquel Espinosa) Billing Agreements / Partners Internal Direct Charging Unilateral Agreements Q & A – All

  3. Pre-award Announcements

  4. Pre-award Announcements Due to the  very high volume of grant proposals anticipated over the next couple of months, please be reminded of the internal deadlines: 10 and 5 business days before the Sponsor deadline dateof draft and final proposals

  5. Temporary” contact for SF424 Application and Progress Reports SF424    #5 Person to be contacted on matters involving this application                 #19 Authorized Representative Mrs. Raquel Espinosa Tel 617-855-2922 Fax 617-855-3745 email : Research_Admin@mclean.harvard.edu Title: Director, Research Administration NIH progress reports, the “Research Performance Progress Reports” (RPPR) should reference Raquel as the Institutional Official

  6. Statement of Intent SOICooperating Institutional Business Contact Information John Cavanaugh Tel 855-2285 Fax 617-855-3745 email: McLSubContracts@partners.org

  7. McLean PeopleSoft Payroll Fix

  8. McLean PeopleSoft Payroll Fix It was noted that there are problems processing research funding changes in PeopleSoft before the monthly payroll run. Workaround: Effective immediately McLean stops approving all research funding changes four days prior to the McLean monthly payroll run. Example: if monthly payroll falls on a Thursday of the month, all changes submitted from Monday – Thursday will not be processed.

  9. Salary Issues Salary issues should be directed to: PHSSalaryIssueAdj@partners.org

  10. PeopleSoft- Research Post Only Transactions

  11. Reminder: Research Post-Only (RPO) Transaction 11 • Effective 6/1/13, Departments will be required to utilize the RPO transaction when submitting post-only transactions • Initial roll-out took place 4/1/13 and Research Management will continue to accept the previous method through 5/31/13 • RPO transaction replaces the previous method of entering a Post Only EDC, which required the DA to add ‘Post-Only’ comments • Many new features were added to the RPO, including: • Ability for a single entry for multiple consecutive changes • Ability for side-by-side comparison of “effective” and “new” distribution • Webinar training available at the following site: • https://phsragconnect.partners.org/rpowebinar • Look for revised Employee Data Change SOP in June

  12. New PCRO Helpline and Hotline information

  13. New PCRO Helpline and Hotline information 13 The Partners Clinical Research Office (PCRO) has established a dedicated PCRO Help Line 617-954-9392 and Mailbox PCRO@partners.org for the PHS research community for information, assistance and answers to questions related to industry-sponsored clinical research contract and budget negotiation and approval, fund activation, Medicare Coverage Analysis and Medicare device petition issues.    The PCRO Help Line 617-954-9392 and PCRO Mailbox PCRO@partners.org are listed on the PCRO website at: http://www.partners.org/Medical-Research/Resources/Research-Support/PCRO/Default.aspx Experienced PCRO staff with knowledge of industry-sponsored clinical research contract and budget negotiations and approval, fund activation, Medicare Coverage Analysis, Medicare device petition and, institutional policies and procedures will respond to calls and emails within one business day.

  14. FY12 Pd 2 Effort Certification – ECFs Past Due

  15. FY12 Pd 2 Effort Certification – ECFs Past Due Effort Reports were due on May 8, 2013. Currently there are still 14 incomplete forms left at McLean. Thank you to all administrators and investigators that have already completed their Effort Certification Forms! Please contact the Effort Reporting Team with any questions or concerns at phseffort@partners.org McL Effort Forms by Status As of 5/20/13 • DEADLINE • May 8 – Deadline for effort reports return (marked as completed in Insight) • ESCALATION • May 23 – Chief, Dept Admin, Institutional Research Administrator, and Entity Compliance Officer • June 7 – Entity VP Research, PHS Vice President of RM and RF, PHS Compliance Officer + everyone above • June 21 – PHS VP Finance + everyone above

  16. FY12 Pd 2 Effort Certification Deadlines & Escalation • DEADLINE • May 8 – Deadline for effort reports return (marked as completed in Insight) • ESCALATION • May 23 – Chief, Dept Admin, Institutional Research Administrator, and Entity Compliance Officer • June 7 – Entity VP Research, PHS Vice President of RM and RF, PHS Compliance Officer + everyone above • June 21 – PHS VP Finance + everyone above • Please contact the Effort Team via their mailbox at phseffort@partners.org if you need help or have any of the following issues: • Investigator left the institution during the reporting period and cannot sign • Investigator is on a leave of absence and cannot sign • Investigator assigned to me belongs in another department • We are ready to assist you now. Don’t wait until escalation to get help!

  17. Harvard Stem Cell Institute

  18. Harvard Stem Cell Institute (HSCI) recently instituted more strict rebudgeting requirements for their awards to Partners hospitals. These requirements will make the proposal submission and award management significantly more onerous. HSCI will reject any invoice that has an expense in a budget category for which there was no budget included in the proposal Due to the way the PeopleSoft general ledger reports expense activity, freight expenses associated with a supply purchase report in the “Other Expenses” category instead of “Supplies.” HSCI will reject any invoice that reports an amount in Other Expenses if there wasn’t a budget for Other Expenses in the proposal Rebudgeting for more than 20% of any budget line requires HSCI’s prior approval. After-the-fact-approval, meaning requesting a rebudget after we have overspent a budget category, is not allowable Carry forward of unspent funds is not automatic and must be justified Budgeting for Harvard Stem Cell Institute (HSCI) Awards 18

  19. Budgeting for Harvard Stem Cell Institute (HSCI) Awards (cont.) 19 As a result of these more strict requirements, Pre-Award will now ask you to include the following budget categories in your new applications for HSCI awards: Other Direct Costs - $50-$100 to cover freight and other ancillary charges if the budget also includes supplies or equipment Travel - $50 to cover local and other travel not anticipated at the time of proposal submission

  20. NIH Access Policy

  21. The NIH Public Access Policy Applies to Any Final Manuscript That… • Is peer-reviewed • And, is accepted for publication in a journal on or after April 7, 2008; • And, arises from: • Any direct funding from an NIH grant or cooperative agreement active in Fiscal Year 2008 or beyond, or; • Any direct funding from an NIH contract signed on or after April 7, 2008, or; • Any direct funding from the NIH Intramural Program, or; • An NIH employee.

  22. Differences Accomplishments Products Participants Impact Special Reporting Resources/Tools RPPR: Research Performance Progress Reports

  23. C.1 Publications Products C.2 Website(s) or other internet site(s) C.3 Technologies or techniques C.4 Inventions, patent applications and/or licenses C.5 Other products and resources RPPR: Research Performance Progress Reports RPPR: Section C – Products (Publications/Public Access)

  24. Products RPPR: Research Performance Progress Reports

  25. MyNCBIDashboard for the Principal Investigator

  26. MyNCBI – My Bibliography with “AWARD VIEW”

  27. “AWARD VIEW” – NIH Public Access Compliance color codes

  28. Resolving Non-Compliant NIH Public Access Citations Is there an NIHMSID# ? Yes – Then the submission process has already begun. Check that submission was approved. No - Contact Pam Hastings, for assistance. x2460 chastings@partners.org

  29. Questions? Contact Pam Hastings, Manager Library Resources 617-855-2460 chastings@partners.org

  30. FY12 Audit UpdatePHS Consolidated A-133

  31. FY12 Audit Testing • Award testing included 34 research grants, 27 PI interviews based on Compliance Controls Questionnaires and 260 direct cost selections. • Service Center testing included 7 Cores and 40 direct cost selections. • Compliance Controls testing included Activities Allowed & Unallowed Asset Inventory Cash Management Cost Sharing Davis-Bacon FFATA & FSR Reporting Effort Reporting Eligibility Period of Availability Procurement Program Income Special Tests & Provisions Sub-recipient Monitoring Unallowable Costs

  32. Audit Results - Four Findings • 2012-1 Equipment • 2012-2 Davis-Bacon • 2013-3 Period of Availability • 2012-4 Federal Funding Accountability and Transparency Act (FFATA)

  33. 2012-1 Equipment • OMB Circular A-110 Section 34(f)(3) requires organizations which receive federal funding and which purchase equipment to perform a physical inventory of the federally funded equipment at least once every two years and reconcile the results to equipment records. • Of the 34 inventory items selected, PwC noted one item at McLean Hospital whose serial and tag number was not appropriately reflected within Partners HealthCare’s equipment records. Cause • This item had malfunctioned and was returned to the supplier for a replacement. However, equipment records were not updated to reflect the replacement item’s equipment tag and serial number within the inventory management system.

  34. 2012-2 Davis-Bacon • Non-federal entities shall include in their construction contracts subject to the Davis-Bacon Act a requirement that the contractor or subcontractor comply with the requirements of the Davis-Bacon Act and the Department of Labor regulations (29 CFR part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29CFR sections 5.5 and 5.6). • PwC tested purchase orders greater than $100K, a $4.6M selection was made related to a construction contract which was subject to Davis-Bacon requirements as outlined within the Notice of Award. The Davis-Bacon requirements were not communicated to the contractor as part of the construction contract and there was no evidence of certified weekly payroll submissions to demonstrate compliance with Davis-Bacon. • .

  35. 2012-3 Period of Availability • OMB Circular A-110 (2 CFR section 215.28) “a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period.” • PwC noted one instance of a grant which had $33,986 in salary expenses incurred subsequent to the grant end date. Charges were not redirected prior to the end date of the award or removed after the grant ended.

  36. 2012-4 Federal Funding Accountability and Transparency Act (FFATA) • Beginning October 1, 2010, the FFATA reporting requirement was effective for Partners HealthCare. This law requires that Grant, Cooperative Agreement, and Contract recipients report information related to subawards issued which have an obligation of $25,000 or greater by the end of the month following the month in which the subaward agreement or modification was fully executed. These reports are required to be submitted once each time a subagreement or modification is fully executed for all applicable awards. • Six of the 14 reports selected for testing were late.

  37. Corrective Action Plan 2012-1 Equipment • Partners HealthCare agrees with the finding and the auditors recommendations. The McLean biennial inventory was completed in October 2012 with the Near Infrared Video Fear Conditioning System properly tagged and recorded in the Hospital’s asset inventory. Management has emphasized the importance of accurate inventory records and provided training to the McLean Research Community in January 2013. Additionally, Partners HealthCare will upgrade existing research asset inventory systems in FY13. • 2013-3 Period of Availability • 2012-4 FFATA

  38. Corrective Action 2012-2 Davis-Bacon • Partners HealthCare agrees with the finding and the auditors recommendations. Management has reviewed the current award portfolio for all Partners HealthCare hospitals and confirmed that this is the only grant subject to the Davis-Bacon Act. The existing contract with the construction vendor has been amended to incorporate Davis-Bacon terms and conditions. Payroll records, retroactive to the start of construction in January 2012, have also been reviewed for proper certification as required under the Act. Hospital Real Estate Offices and Partners Research Management will follow standard operating procedures to ensure that federally funded construction contracts incorporate all terms and conditions included in the prime award. Partners HealthCare has documented internal procedures to ensure that all applicable terms and conditions are incorporated into construction contracts.

  39. Corrective Action 2012-3 Period of Availability • Partners HealthCare agrees with the finding and the auditors recommendations. Costs charged after the award end date have been removed from the grant as of November 2012. Management views this as an isolated circumstance. During FY13, Management will increase the focus on salaries charged to grants that are ending through monthly notification of upcoming end dates and routine fund monitoring procedures. Management will direct future payroll allocations to discretionary sources if a new salary distribution is not identified prior to the end date of the award.

  40. Corrective Action 2012-4 FFATA • Partners HealthCare agrees with the finding and the auditors recommendations. Management has emphasized the importance of FFATA compliance and identified key control points to strengthen existing standard operating procedures for FFATA reporting requirements. Internal procedures were updated in February 2013 with system enhancements to be completed by May 2013.

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