K-Award Terms and Conditions Compliance Pitfalls

1. K-Award Terms and Conditions& Compliance Pitfalls Presented By: Mee Mee Lee-Choi, Associate Director of Grants & Contracts September 30, 2010 1

2. Institutional Responsibility When we accept an award, we�� �agree to adhere to all of the terms, conditions and guidelines. �have a fiduciary responsibility to spend the money in a reasonable and responsible manner. �have to demonstrate adherence to the key cost principle (Reasonable, Allowable, Allocable, Consistent) for treatment of all costs 2

3. K-Awards Terms and Conditions K-Award recipients must be full-time employees Acceptance of a K-award may require a redistribution of effort to reflect the required level of commitment to the award (usually 75%) No-cost extensions still require the same level of effort required by the award Salary supplementation may NOT be from Federal funds unless specifically authorized by the Federal program from which such funds are derived 3

4. K-Awards Terms and Conditions Any change in employee status or responsibilities requires notification to the funding agency Salary for mentors, secretarial and administrative assistance, etc. is NOT allowed Candidate may not simultaneously submit or have an application pending for any other career award Ineligible candidates include current or former principal investigators on NIH research project grants, or project leaders on sub-projects of program project or center grants, or other career development awards 4

5. Common Compliance Issues Level of effort requirement Full-time appointment requirement Salary limitation Use of non-salary support Others Prior approval requirement (special leave, no-cost extension, reduction in effort, changes in career development plan, changes in institution, etc) Citizenship requirement Degree requirement 5

6. Importance of Compliance & Risks Increased monitoring and oversight Repayment of funds Loss of current and/or future funding Compromise expanded authorities Compromise institution�s reputation Could be breaking the law 6

7. K-Award Recipient Responsibilities Review award terms and NIH Grant Policy Statement Be aware of NIH policy concerning concurrent support from career development award and research grant Allowable only in the final two years of K-award Effort required on K-award may be reduced to no less than 50% Complimented by an appropriate percentage of effort from the research award Maintain total level of research commitment at 75% or more 7

8. K-Award Recipient Responsibilities (cont.) PI must have ability to commit required % effort Department head must agree that the PI will be permitted to spend the prescribed % of time on K activities. And, the department will cover required cost sharing 8

9. K-Award Recipient Responsibilities (cont.) Expend and report effort accurately Example: K07 requires a minimum 75% effort by the PI and has a salary limit of $75,000 PI: 75% Effort and IBS = $115,385 Payroll Effort Distribution K07 Award $ 75,000 65.0% Cost Share to K $ 11,539 10.0% Other Sources $ 28,846 25.0% Total $115,385 100.0% Submit timely progress reports 9

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11. Don�t Overcommit Effort or Could Lose K Award and $�s 3. If applicable, determine areas of clinical/research overlap; K award overlap K award: apportion as communicated to sponsor Clinical research: reasonable basis (e.g. proportion of effort expended on patients enrolled in research study and proportion of time spent on tests, treatments and care related to study when handling these patents �the chargeable portion) 4. Ensure effort commitments can be reconciled within 100% If overcommitted, we will need to address (surface to ORS ASAP) Note: 25% reduction in effort on a grant must be communicated to sponsor 11

12. Learnings from K-Awards Investigation Faculty Activity Analysis (FAA) reports must reflect the required effort percentage of a K-award Effort Certification being reviewed and signed without proper understanding Over commitments on clinical activity and under commitments on research effort All changes must be documented and agreed to in writing by the sponsor. 12

13. In Summary Be mindful of minimum effort commitment requirement and salary cap Effort reporting is one of the areas of federal government focus Who ensures appropriate salary is charged? Who ensures level of commitment is reasonable? Who signs the effort reports? Compliance is not only for post-award administration 13

14. Who Is Responsible for Compliance? 14

15. Types of K Awards with Effort Requirements K01 Mentored Research Scientist Development Award Career development in a new area of research. 3-5 yrs; Salary determined by the sponsoring institute. K01 International Research Scientist Development K01 Award (IRSDA) Provides US scientists with the opportunity to embark/enhance research careers related to global health. K02 Independent Scientist Award Develop the career of the funded scientist. 5 yrs; 75% effort. K05 Senior Scientist Award For outstanding scientist with a sustained level of high productivity. 5 yrs; 75% effort; Funding determined by the sponsoring institute. 15

16. K07 Academic Career Award Developmental/Leadership in academic instruction, research, administration. 2-5 yrs, 25-75% effort; requires institutional sponsorship. K08 Mentored Clinical Scientist Development Award Development of the independent clinical research scientist. 3-5 yrs; 75% effort. K12 Mentored Clinical Scientist Development Program Award Support to an institution for the development of independent clinical scientists. 5 yrs; 75% effort; initiated by the educational institution. NCI NCRR NEI NIA NICHD NIDA NIDCR 16

17. K07 Academic Career Award Developmental/Leadership in academic instruction, research, administration. 2-5 yrs, 25-75% effort; requires institutional sponsorship. K08 Mentored Clinical Scientist Development Award Development of the independent clinical research scientist. 3-5 yrs; 75% effort. K12 Mentored Clinical Scientist Development Program Award Support to an institution for the development of independent clinical scientists. 5 yrs; 75% effort; initiated by the educational institution. NCI NCRR NEI NIA NICHD NIDA NIDCR 17

18. Types of K Awards with Effort Requirements K18 Career Enhancement Award for Stem Cell Research Supports full-time or part-time training in the use of human or animal embryonic, adult, or cord blood stem cells. Usually 6 months to 1 year (up to 2 years allowed) full or part-time. NIDDK, NIAAA, NIAID, NHLBI, and NINR participate. K22 Career Transition Award Support to an individual postdoctoral fellow in transition to a faculty position. NCI NIDCR NINR NHGRI NHLBI NIDDK NLM NIAID NIEHS NIAMS NIMH NIDA NINDS 18

19. Types of K Awards with Effort Requirements K23 Mentored Patient-Oriented Research Career Development Award Development of the independent research scientist in the clinical arena. 3-5 yrs, 75% commitment. K24 Midcareer Investigator Award In Patient-Oriented Research Development of clinical mentors conducting funded research. 3-5 yrs, 25 to 50% effort. K25 Mentored Quantitative Research Career Development Award To foster interdisciplinary collaboration in biomedical research by supporting career development experiences for scientists with quantitative and engineering backgrounds. 3-5 yrs; 75 % effort. K26 Midcareer Investigator Award In Mouse Pathobiology Research Provides support for established pathobiologists who wish to devote up to 50 percent of their effort to research and mentoring in the field of mouse pathobiology. 3 to 5 yrs, renewable 25 to 50% effort. 19

20. Types of K Awards with Effort Requirements K30 Clinical Research Curriculum Development Institutional Award for development of a clinical research curriculum. 5 yrs; up to $200,000 per year. 20

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