Research Administration Forum February 3, 2009

1. Research Administration Forum February 3, 2009

2. What is new in Research Administration? Dick Seligman • new Research Administration Website • Yale University Settlement • Audit update • new Export Compliance policy • Restricted Party Screening • Agency updates • Future Training Sessions • Answering questions

3. http://researchadministration.caltech.edu

4. Yale University$7.6 Million Settlement • Multi-year investigation by Federal agencies • DHHS OIG • NSF OIG • DOE OIG • DOD DCAA • NASA OIG • FBI

5. Yale University$7.6 Million Settlement • Period covered: January 2000 – December 2006 • $3 Billion in Federal grants • Basis of the settlement: • $3.8 Million “actual damages” • $3.8 Million “penalties”

6. Yale University$7.6 Million Settlement • Issues • Improper Cost Transfers • Salary charges to grants must reflect actual time and effort spent • So what? • Wake-up call for the rest of us • Heightened scrutiny

7. Project Accounting Audit Update Estella Venegas

8. Audit Update • FY2008 A-133 Audit conducted by PricewaterhouseCoopers (PwC) • Cost sharing • Financial reporting • Payroll distribution confirmation reports • DCAA FY2007 Incurred Cost Proposal (ICP) Audit • Financial reports submitted by Project Accounting • Award summaries and sponsor invoicing • DCAA FY2008 Interdivisional Cost Transfer Audit • Caltech expenditures and invoicing of JPL awards

9. Audit Update • DCAA FY2008 MAAR 5 (Mandatory Annual Audit Requirement) • Refunds and credits due to JPL/NASA • Lawrence Livermore National Laboratories (LLNL) Agency Award Audit • Caltech expenditures and invoicing of LLNL contract • Other Audit Requests • Reference: http://www.whitehouse.gov/omb/circulars/a133/a133.html

10. What is new in Export Compliance? Adilia Koch

11. Institute Policy Announcement To: The Caltech Community From: Jean-Lou Chameau Subject: Compliance with Export Laws and Regulations Federal laws and regulations concerning export, import and financial transactions involving sanctioned or embargoed countries have existed for many years. The events of September 11, 2001, and subsequent events around the world have pushed national security concerns to the forefront. The government has responded by tightening the export control regulations that govern the transfer of strategic technology for national security and foreign policy reasons. Export control laws are intended to control the transfer of sensitive information or goods to individuals, entities, or countries of concern and, under certain conditions, to foreign persons. The regulations contain a fundamental research exclusion and specific university exemptions that allow most of the research activities being performed at Caltech and at other U.S. universities to be carried out without the need for government licenses or other restrictions. There are certain activities and information that are not covered by the fundamental research exclusion, however, and remain subject to the export control laws and regulations. It is essential for all members of the Caltech Community to be aware of them. Toward that end, we have adopted a new policy, "Compliance with Export Laws and Regulations." While the policy applies to all members of the Caltech community, there are many who will not be directly affected by the requirements of this policy. The Caltech Export Compliance Office will continue to offer export compliance awareness classes for faculty and staff on these requirements. The schedule of training programs for 2009 will be announced in January. However, if you need immediate assistance or have any questions regarding this policy, please contact Caltech's Director of Export Compliance, Adilia F. Koch, at extension 4469 or email: adilia.koch@caltech.edu. • The policy can be accessed at: http://cit.hr.caltech.edu/policies/Policies/CITPolicy_ExportLaw.pdf

12. http://cit.hr.caltech.edu/policies/Policies/CITPolicy_ExportLaw.pdfhttp://cit.hr.caltech.edu/policies/Policies/CITPolicy_ExportLaw.pdf

13. What is this new Institute Policy? • A clear statement of commitment by Caltech’s senior officers • Communicated to the Caltech community • To comply with US export laws and regulations

14. Why do we need this policy? • Recommended Best Practices • It will mitigate risk should something go wrong • It serves as the foundation of the larger Export Compliance Management Program

15. What are the effects of this policy? • Export Compliance Education Program for campus • Faculty & Researchers • Administrative Staff • International Shipments reviewed to ensure: • Compliance with export/import regulations and to • determine whether an export license is required. • Creation of new processes and procedures for some organizations

16. What else is new? • MK Denial Restricted Party Screening Tool • A campus wide web-based tool vs. limited # • Will ensure we are not involved with unauthorized entities or individuals • Current Users: • OSR • Mail Services • Shipping & Receiving • Procurement • Export Compliance, Other • Tool is very simple to use

17. MK Denial RPS Search

18. MK Denial RPS Search Results

19. When should we perform RPS? • When engaging in a financial or export transaction involving unknown individuals or entities • When a transaction raises a “red flag” • MK Denial • Acquire a user name and password from the Export Compliance Office if you have a concern about a transaction.

20. Contact Us Export Compliance Office (626) 395-2641 (626) 395-3144 (fax) • Web: http://researchadministration.caltech.edu/ec • Email: exportcompliance@caltech.edu

21. Sponsored Research Agency Updates David Mayo

22. Agency Updates NSF • Postdoc Mentoring Activities description: • Required: • As a separate section • In any proposal that includes funding for postdocs • Within 15 page limit of Project Description • Proposals will be returned by NSF if there is no section addressing this topic (Grant Proposal Guide Chapter II, Section C.2d(i))

23. Agency Updates NIH • 2009 NIH Salary Cap • $196,700 (up from $191,300 for 2008) • Effective January 1, 2009 http://grants.nih.gov/grants/guide/notice-files/NOT-OD-09-037.html • Career Development (K) applications • Electronic submission goes electronic on February 12 (e.g., via Grants.gov) • Reference letters will be submitted directly to NIH Commons after submission of proposal

24. Agency Updates DoD • Cap on F&A has been carried into 2009 • Limits F&A recovery to 35% of TC • Applies to: • New/Renewal awards issued in FY2008 & FY2009 • Year 2 funding of awards issued in FY2008 • Standard burden schedule will apply • Will not impact direct costs available to PI

25. Agency Updates F&A in Proposals • Caltech F&A Rate Agreement • Negotiated with the federal government • Used on all federal and non-federal proposals • On-campus rate (60.5%) applies by default • Off-campus rate (26.0%) - proposal must clearly demonstrate that the off-campus rate is applicable • Use of on- and off-campus rates in the same proposal requires prior discussion with OSR

26. Agency Updates F&A in Proposals (cont.) • Exceptions to Caltech’s F&A Rate Agreement: • Reduced or zero F&A based on sponsor policy does not require special approval, however… • Must be a federal or non-profit sponsor • Must be a published policy • Must be a requirement for submission • Sponsor’s reduced F&A must be assessed on all budget categories, unless a category is specifically exempted by the sponsor’s policy • All other exceptions require prior approval of the Vice Provost for Research; Research Administration does not have the authority to approve waivers

27. Agency Updates F&A in Proposals (cont.) • Remember, F&A recovery lower than Caltech’s negotiated on- or off-campus rates • will negatively impact Faculty Research Pools • requires use of the higher tuition remission rate (85%) in non-federal proposals

28. Future Training Sessions Fundamentals of Research Administration February 27, 2009 9:00-11:30am 202 Guggenheim Annual Export Compliance Update March 24, 2009 10:00-11:30am 151 Sloan please RSVP to mika.walton@caltech.edu

29. Questions & Suggestions • Any future Forum topic suggestions can be dropped off in the suggestion box at the sign-in table. • Questions can also be placed in the box.