Grants and Subcontracts Information about navigating grant and subcontract processes. Introduction Getting Started Who can help me apply for grants and subcontracts? Your department administrator and Sponsored Programs Administration (SPAdmin) grant specialists understand UNMC’s research administration infrastructure and can guide you. You should notify both as soon as you identify a funding opportunity you plan to pursue. Identify your SPAdmin grant specialist. SPAdmin contact information:Web: unmc.edu/spa/Phone: 402-559-7456Email: spadmin@unmc.edu Does UNMC offer grant writing assistance? Yes, researchers can request grant and manuscript editing assistance through the Research Editorial Office. Web: unmc.edu/vcr/cores/research-editorial/Phone: 402-559-4132Email: grantseditor@unmc.edu Roles and Responsibilities for Grants and Subcontracts Effective sponsored project management Effective sponsored project management is a collaboration among Principal Investigator(s); Departmental Administrators and other research staff; Sponsored Programs Administration (SPAdmin); and Sponsored Programs Accounting (SPAccount). Principal Investigator Leads and directs the project, intellectually, logistically, and administratively Oversees proposal and budget preparation Identifies project personnel and collaborators Secures appropriate research resources Follows departmental policies for pre-review of application for scientific merit Ensures integrity and timeliness of financial, administrative and technical information provided to SPAdmin Signs internal research routing forms and verifies that Conflict of Interest disclosures in COI-Smart are current Obtains regulatory approvals of research prior to initiating the research Department Administrators and other research staff Assists PIs with completion of the application and budget preparation Manages UNMC’s financial systems, maintaining the integrity of the financial transactions in those systems in keeping with Policy #8012 Generates internal forms for signature Submits published manuscripts or clinical trial updates to the appropriate databases Sponsored Programs Administration (SPAdmin) staff Provides expertise and guidance to investigators and department personnel regarding grant and contract submissions and management Protects the UNMC by monitoring compliance with federal, institutional, and sponsor requirements Reviews and submits applications, agreements, and modifications in accordance with sponsor terms, conditions and program guidelines Negotiates final terms for government and non-profit grants, contracts, and subcontracts Reviews Conflict of Interest disclosures for project personnel Approves internal forms and applications prior to institutional signature Prepares awards for set-up by Sponsored Programs Accounting Web: unmc.edu/spa/ Phone: 402-559-7456 Email: spadmin@unmc.edu Sponsored Programs Accounting (SPAccting) staff Oversees post-award financial compliance in accordance with the Federal Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards or “Uniform Guidance”. (Uniform Guidance rolls OMB Circular A-21, OMB Circular A-110, OMB Circular A-133 into one document) Sets up awards Manages effort reporting certifications Monitors program revenue, cost-share, and cost allowability Invoices sponsors Prepares and submits financial reports to sponsors Web: info.unmc.edu/management/finance/spaccounting/ Phone: 402-559-5822 Who can sign grant proposals prior to submission? The Director of SPAdmin or a designee are the only personnel who can officially sign grant proposals, subcontracts, and internal forms as the institutional official for sponsored projects at UNMC. A SPAdmin grant specialist reviews the application first to be sure it is compliant with UNMC and sponsor policy and then will obtain the institutional signature for the applicant. Preparing a Federal Grant Application Read the instructions early, carefully, and often. Early in the process, investigators should review submission timelines and requirements of the Funding Opportunity Announcement (FOA) and the programmatic guidelines. The applicant should communicate the information as soon as possible to anyone helping them with their grant application, including their department administrator and designated SPAdmin grant specialist. How are federal grant applications submitted at UNMC? Federal grant applications are prepared by investigators and departmental personnel, and submitted using Cayuse424, a system-to-system interface that: Populates applications with institutional information Allows multiple users to work on an application Validates applications before submission Link to Cayuse424 (log in with UNMC net ID and password): unmc.cayuse424.com Contact your SPAmin grants specialist for questions about using Cayuse424. Preparing Non-federal Grant Applications Investigators need to be aware of submission deadlines and requirements of the Request for Applications and programmatic guidelines. Communicating this information to your department administrator and SPAdmin grant specialist as soon as possible is critical for establishing timelines and generating project support. How are non-federal grant applications prepared at UNMC? Investigators and departmental personnel prepare non-federal grant applications in accordance with sponsor guidelines. Many non-federal sponsors have their own submission website and forms. Submitting Federal and Non-federal Applications Are there prerequisites to submitting a grant application? NIH submissions require an eRA Commons ID and password. This eRA Commons ID is also required on every NIH Biosketch submitted. To request an ID and password for the Principal Investigator and an ID for other key personnel, including graduate students, contact SPAdmin at 402-559-7456. Required internal budget and other forms must be routed through the appropriate Department and College units and signed by UNMC’s institutional official prior to grant submission. For more information, see Research Administration for Grants and Subcontracts. Are there minimum time requirements for Sponsored Programs review prior to grant application? Draft applications should be sent to SPAdmin for review at least three business days (ideally five business days) before the submission date. SPAdmin carefully reviews all forms, including the budget and program requirements, to correct errors or inconsistencies that would disqualify the grant from review. NIH and other sponsors can and will disqualify grant applications that do not comply with instructions. Who submits the final grant application? After SPAdmin review and signature by UNMC’s institutional official, SPAdmin submits the application to the sponsor. Federal applications are submitted to www.grants.gov directly from Cayuse424, and non-federal applications are submitted electronically or shipped per sponsor guidelines. Departments may transmit or ship applications themselves if they wish, but only after receiving SPAdmin approval and by making arrangements in advance with SPAdmin. Sponsor guidelines specify how to submit applications. Guidelines generally include an identifier (e.g. Funding Opportunity Announcement number), due date and time, paper or electronic submission instructions, required contact and format, award amount (including F&A), period of performance, and eligibility requirements. Guidelines may be program-specific or generally applicable to the sponsor. Be sure that you are working from the current version of the guidelines. Additional Resources for Preparing and Submitting Applications UNMC Institutional Information required by sponsors (Federal tax ID, etc.) Link to Cayuse424 (log in with UNMC net ID and password) Request eRA Commons Account SPAdmin Grant Guidelines Workshops on Grant Writing, Formatting Applications, and More External Collaboration Subcontracting OUT to a Sub-Investigator at Another Organization What is a subcontract OUT? A subcontract OUT is generated when a UNMC investigator applies for a grant and collaborates with an investigator from another organization. UNMC is thus the prime recipient, and the other organization is the sub-recipient. UNMC delegates appropriate prime award terms and funds, and the sub-recipient organization commits to performance, program, and compliance responsibilities. UNMC remains fully responsible for the entire award when subcontracting out part of an award to another organization. What does SPAdmin require to generate a subcontract OUT? Prior to submitting a grant application, Sponsored Programs Administration (SPAdmin) requires: Intent to Form a Consortium signed by an authorized official of the sub-recipient organization Subrecipient's format PHS 398 face page, or UNMC's format Statement (or scope) of work Detailed budget with F&A cost calculation Budget justification Contact information (FDP Attachment 3) For details on Subcontracts OUT and links to required forms, see unmc.edu/spa/subcontracts/subcontracts-out. How is a subcontract OUT different from a vendor contract? Vendors supply goods and services needed to complete the project but do not have programmatic responsibilities and so are not subject to the compliance requirements of the award terms and conditions. Finance and Business Services negotiate vendor agreements. For additional information on sub-recipients, see Policy #6108 or contact SPAdmin at 402-559-7456. For more information regarding vendor agreements, see Policy #6063 or contact the Chief Compliance Officer at 402-559-6767 or Business Services Director at 402-559-5840. Subcontracting IN from a Primary Investigator at Another Organization What is a subcontract IN? A subcontract IN is generated when a primary investigator from another organization applies for a grant and collaborates with a UNMC investigator. UNMC is thus the sub-recipient, and the other organization is the “sponsor.” The other organization passes on the prime award terms and funds, and UNMC commits to performance, programmatic, and compliance responsibilities. What is required to initiate a subcontract IN? Prior to grant submission by the other organization, SPAdmin must receive and process forms required by the prime recipient to document UNMC’s intent to participate, the scope of work, qualifications, and budgetary needs. Forms may include: An Intent to Form a Consortium, which must be signed by one of UNMC’s institutional officials to signify understanding of our obligations and that we authorize the other organization to submit a proposal containing commitments Sponsor's format, or UNMC's format Statement (or scope) of work Budget justification (including F&A) Additional documentation required by the other organization (e.g. detail budget) Biographical sketch Resources page Internal forms (For more information see the section Research Administration for Grants and Subcontracts). Identify and communicate timelines to SPAdmin early. Remember that other institutions may require more time than UNMC to process subcontracts prior to grant submission. For details on Subcontracts IN, go to unmc.edu/spa/subcontracts/sub-in Collaborating with Small Businesses How do federal grants that fund collaborations between small businesses and UNMC work? Small Business Innovation Research (SBIR) or Small Business Technology Transfer (STTR) programs allow federal agencies to fund Small Business Concerns (SBC) to work with Research Institutions on innovative research and technology transfer. The SBC is the applicant/recipient, and the Research Institution (i.e. UNMC) is the sub-recipient. University funds in this case are managed as a subcontract IN. If I am UNMC faculty but also developing a new business, can I submit a SBIR or STTR grant or collaborate with a small business using SBIR or STTR funds? Yes. If you are the CEO of the business you would be the Principal Investigator, and you can lease space or subcontract for other UNMC services with an SBIR or STTR grant. Contact UNeMed for more information on the requirements for and help with developing and submitting a SBIR or STTR grant. You will also need to consider some of the policies and will work with the entities below. Similarly, if a small business owner would like to collaborate with you, you should contact UNeMed to help with the process. See UNMC Policy #3002 for the entities you might need to help you, depending on your role. UNeMed Ownership of Intellectual Property (Board of Regents Policy 4.4.2) Preliminary business plan models and advice License Template Sponsored Programs Administration SBIR/STTR subcontract template Letter of commitment regarding expected time and effort commitments Academic Affairs Compliance and COI Officers Outside Employment Form (UNMC Policy #1049) Conflict of Interest management (as needed) Assistant Vice Chancellor Business & Finance Contract for Use of Space and Equipment Administration About this Section The information in this section applies to the research administration of any grant or subcontract from federal, state, and local governments and non-profit entities, whether categorized as research, instruction, public service, or other activities. Internal Forms Internal forms document institutional support for the project and provide information about decision-making and approvals. They are signed by the Sponsored Programs Administration (SPAdmin) grant specialist, appropriate Deans/Directors and Chairs (or designees), and UNMC’s official signatory. What internal forms are required for grant submissions? Sponsored programs require two internal forms prior to grant submission: The Routing Form provides basic information about the project. The Internal Budget describes the proposed budget for approval by all participating units. Personnel costs include the committed effort (as a percentage) of each participant as well as the Institutional Base Salary (IBS), which includes one or more of the following elements as well as benefits based on UNMC’s federally negotiated fringe benefits rate agreement: UNMC base salary Specified UNMC stipends UNMC Physicians base salary or Nebraska Pediatric Practice base salary If the project does not pay for the entire salary proposed by the effort required, as can occur with training grants or NIH salary caps, UNMC may have to commit to cost sharing. Cost sharing must be justified and approved by the unit director. View UNMC’s Institutional Base Salary and Cost Share Policies. Other considerations: Waiver of Facilities & Administrative Rate (F&A). If you believe there is a rationale for accepting a lower F&A rate than UNMC has negotiated, you must complete an F&A waiver request when you are completing the ADIS Internal Forms. International projects or partners. All projects that include an international partner or are performed outside the country must submit an International Projects Questionnaire. This should be submitted to SPAdmin before the grant is completed to be sure that all elements have been considered so grant submission is not delayed. Administrative charges to sponsored projects. If you believe there is a rationale for charging administrative costs—which are normally treated as indirect costs—directly to a grant, you must complete an Administrative Costs Checklist when you are completing your ADIS Internal Forms. Consortium grant. If a UNMC investigator applies for a grant collaborating with an investigator from another organization, an Intent Document is required. See Intent to Form a Subcontract. How are internal forms submitted? Your department administrator will initiate the submission of these forms using internal processes through ADIS. SPAdmin assigns user rights upon request by the Department Administrator. UNMC personnel can log in to ADIS using a UNMC Net ID and password. How can I obtain other Sponsored Programs forms? Some forms are available as MS Word or Adobe PDF documents at unmc.edu/spa/forms/forms-templates. For questions, call SPAdmin at 402-559-7456. Direct Costs What are direct costs? Direct costs are those that can be specifically identified with a particular sponsored project or activity and can be assigned to that project or activity with a high degree of accuracy. Examples include lab supplies, travel expenses, animal purchases, and animal housing expenses. What are fringe benefits? All salaries are accompanied by a fringe benefit rate that varies with the specific group, such as faculty, post docs, and staff. Each year, UNMC negotiates the Fringe Benefit Rate with the federal government. UNMC’s current fringe benefit rates are availale in the rate agreement document. Indirect Costs What are indirect costs? Indirect costs, also known as overhead or the Facilities and Administrative (F&A) Rate, are provided to the institution proportional to the project total to cover research administrative costs such as research compliance and building upkeep. What is UNMC’s indirect cost rate? UNMC has negotiated an F&A Rate Agreement with the federal government that varies with the type of project or sponsor. Use the F&A rate agreement document to find the indirect cost rate appropriate for the project's specific activity and sponsor. On what budget items is the indirect cost rage charged? Most federal grants use a Modified Total Direct Cost (MTDC) base, which excludes the value of each subcontract over $25,000, equipment, participant stipends, and patient care. For industry sponsors, we apply the indirect cost rate to Total Direct Costs (TDC) with the exception of IRB fees. Can I reduce or waive F&A costs? UNMC will accept the published F&A rate of a sponsor. Only in special cases can UNMC accept a lower rate. The waiver process is discussed at unmc.edu/spa/forms/forms-templates. Computers and NIH What are the regulations regarding computers and NIH budgets? Office equipment (copiers, laptops, desktop computers, personal handheld computers, fax machines, scanners, etc.) used for general office purposes (rather than justified as a specific research purpose) are not allowable as direct costs; they are allowable as an F&A cost. Conflict of Interest How do my Conflict of Interest disclosures affect my grant submissions? All sponsored project proposals are reviewed prior to grant submission to identify any real or perceived conflict of interest. If a potential conflict is identified, it can be eliminated or managed. The Conflict of Interest Committee establishes the COI management plans.Pre-award Activities Required Regulatory Review Processes Do I need to complete regulatory review processes prior to grant submission? NIH and most other sponsors allow applicants to submit grants prior to obtaining final approval of required regulatory processes. This process is called “Just in Time (JIT).” After the application is submitted and approved, but prior to final determination of funding, NIH or other sponsors will request submission of regulatory approval documents. The request will be designated in eCommons using JIT next to the submitted application. However, a JIT request does not guarantee that an award is forthcoming. When should I complete and submit regulatory documents? If regulatory approvals are required by the grant, and they are not completed and approved prior to grant application, it is best to begin the application as soon after the grant submission as possible to prevent any delays in grant award once those documents are needed. These may include human studies review (IRB), animal welfare review (IACUC), and safety review (IBC). Human studies projects involving administration of any medication or therapeutic agent also require pharmacy and therapeutics (P&T) review, and any cancer-related project will require Scientific Review Committee (SRC) review and approval. For human studies projects, all personnel on the study budget who will also interact directly with patients or human subjects’ data should complete human subjects training on the CITI Web site. For more about CITI training, see unmc.edu/irb/citi. Before I receive the Notice of Award, can I hire personnel and order equipment on the grant Budget? If you have received indication that funding will be awarded you can request an Advance Account from SPAdmin. However, if an Advance Account is set up and the award is not made, the department covers the cost of any expenses incurred. Access the Advance Account Request form in ADIS Internal forms. A guide is available at unmc.edu/spa/forms/forms-templates You must have processed your proposal through SPAdmin prior to requesting an Advance Account. Finalizing Grant Awards As soon as you receive a Notice of Award, please notify and forward to Sponsored Programs Administration (SPAdmin) to set up your grant. If the internal forms on file are complete and match the award, SPAdmin will prepare the award and send it to Sponsored Programs Accounting (SPAccting) for set-up within one week. If the total award or budget has been changed since the grant application was submitted, the internal forms will need to be revised to match the award. SPAdmin will contact you if changes to internal paperwork are required. After the award is set up in UNMC’s accounting system, the PI and department administrator are notified by email that the account is ready and that the project “bundle” may be accessed in ADIS. The bundle includes: Checklist, which lists the account number (known as the WBS), personnel, effort, budget, regulatory requirements, and budget and award periods Internal budget Award document Routing form signed by the PI For more, see Award Set-up Finalizing Subcontracts OUT What is required to finalize a subcontract OUT? After UNMC’s grant award is finalized, SPAdmin generates a subcontract OUT to any sub-recipient organizations based on the statement of work and budget collected from the PI and department prior to submission. The subcontract budget may need to be revised if there is a significant variance between the budget request and budget award. Finalizing Subcontracts IN What is required to finalize a subcontract IN? Once the prime recipient organization receives a notice of grant award, SPAdmin works with the organization to execute a subcontract IN based on the statement of work and budget provided by the UNMC investigator and department. The subcontract from the prime recipient should contain: Statement of work Detailed budget Catalog of Federal Domestic Assistance (CFDA) number (if federally funded) Documentation of terms and conditions Copy of prime award The budget and scope of work may need revisions if a significant variance exists between the budget requested and the budget awarded to the prime recipient.Managing Awards Sub-site Monitoring UNMC is obligated to the sponsor to act as a good steward of the entire award and must therefore monitor the activities of any sub-sites. For more information on Sub-recipient Monitoring obligations, see UNMC Policy #6108. Progress Reports to the Sponsor (Non-competitive Renewals) What is a progress report? Most sponsors require a progress report at specified intervals, which may be monthly, quarterly, or annually. Progress report requirements are described in the notice of award. These progress reports are sometimes used to adjust the next year's budget. For grants, although the sponsor may commit in the initial award to several years of funding, the grant award is contingent on satisfactory progress. NIH and NIH-style awards are usually funded in one-year budget periods as part of a five- (or less) year “cycle.” A “non-competitive” continuation of the project is triggered by the submission of a satisfactory progress report. Contracts can be revoked entirely if desired outcomes or performance milestones are not reached. It is very important to communicate to the sponsor in advance of the progress report if there are any circumstances that have adversely affected progress. The NIH uses an electronic Research Performance Progress Report (RPPR) system for most progress reports (NOT-OD-13-035). The RPPR provides a uniform format for interim performance reporting on federally-funded research and research-related activities. Who submits the progress report? The PI prepares the technical report and submits to SPAdmin for review and submission. SPAdmin’s review determines whether the report contains the required elements and is in the proper format. Internal forms are required prior to progress report submission for projects funded in one-year budget periods as part of a five (or less) year cycle. For more information see Research Administration for Grants and Subcontracts. Sponsored Programs Accounting prepares and submits the financial report based on the information in SAP, UNMC’s accounting system. Financial reporting and invoicing often occur simultaneously. Changes Requiring Formal Approval by the Sponsor Most grants and sponsors allow the investigator some flexibility to change budget and project implementation from that originally proposed. However, many contracts and sponsors require formal approval by the sponsor via an amendment or revised notice of award. SPAdmin will submit the change request to the sponsor. Some of the changes that typically require formal approval include: Change in PI or Key Personnel. UNMC must seek prior sponsor approval if the PI or other key personnel withdraw from the project or are replaced. Rebudgeting. Significant variance may occur between budget and actual costs in a funding year; and actual expenditures may be reported for grants to the sponsor via financial reports. If actual costs differ significantly from what was anticipated, it is wise to inform the sponsor. Significance varies with the sponsor, but NIH will require a justification of any change of 25% or more. Leave of Absence. Generally, UNMC must seek prior approval from the sponsor if the PI or other key personnel will be absent from the project during a continuous period of 3 months or more, whether for illness or other cause. Change in Effort. When a certain level of effort is stated in a proposal, UNMC commits to the sponsor that the named person will spend that time on the project, either paid for by the award or cost-shared by UNMC. Though month-to-month time may fluctuate, the individual must spend the stated average over the project period unless percentage of effort has been changed. It is also important to inform the sponsor if the principal investigator or other key personnel effort is significantly changed. For federal sponsors, approval is generally required if the PI or other key personnel will reduce time devoted to the project by 25 percent or more from the approved level. Change in Direction or Project Scope. It is also wise to contact the sponsor if the project moves in a new or unexpected direction. Indicators of a change in scope include: Change in specific aims approved at time of award Change from approved use of live vertebrate animals (including change of species) or involvement of human subjects Shift of research emphasis from one disease area to another Application of a new technology Adding a new subcontract or an international component Your SPAdmin grant specialist should be contacted if a significant change has occurred that requires sponsor approval. No-cost Extensions If additional work is required to complete a project, an award may be extended in one of two ways, depending on sponsor requirements: Under “expanded authorities,” SPAdmin can extend the end date and notify the sponsor of the change.` If “prior approval” is required, SPAdmin will request a revised Notice of Award or amendment from the sponsor. In either case, the investigator will be required to submit an explanation (e.g., slow patient accrual, delay in completing last experiments or data analysis). UNMC cannot extend a project solely for the purpose of spending remaining funds. Competitive Renewals When your funded grant is completed, if there are ongoing research questions that the sponsor is interested in, the investigator can often submit the project as a competitive renewal. A competitive renewal requires a new application submitted for peer review, much like the original application. UNMC’s internal process for competitive renewal submission and approval mirrors that of new applications. Effort Reporting SPAdmin verifies effort availability at the time of award, but after the award, the Office of Management and Budget's Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires the investigator certify the salary charged to a sponsored project is reasonable in relation to the effort expended on that project. Per UNMC’s Effort Reporting Procedure, “effort” is the proportion of time spent on any activity, expressed as a percentage of total time. Total effort for an employee must equal 100% of the employee’s appointment. Investigators are responsible for assigning effort to all personnel on sponsored project budgets and for monitoring effort for all budgeted personnel, including tracking effort changes. If changes in effort occur, investigators are responsible for informing the sponsor. For more information, see UNMC’s Effort Certification Policy #6105 Effort Tracking Sponsored Programs Accounting (SPAccting) initiates and administers Effort Certification reporting. Investigators or delegated staff with first-hand knowledge are responsible for completing the Effort Certification Reports in Research Support System (RSS) on the UNMC intranet.