December 17, 2008

Revised NSF Agency-Specific Requirements Include Airline “Open Skies” Agreements

The National Science Foundation has posted a revision to the NSF Agency Specific Requirements to the Research Terms and Conditions on the Research Terms and Conditions web page.

The updated Requirements will go into effect on January 5, 2009, and will be applied to all new NSF grants and funding increments on existing NSF grants to organizations subject to 2 CFR Part 215. The Research Terms and Conditions will not be applied to NSF cooperative agreements and NSF fellowship awards made to individuals. NSF has posted a summary of significant changes to accompany the revised Requirements.

One significant change will provide investigators some flexibility (in certain circumstances) for use of non-US flag air carriers. NSF has updated Article 13, Travel, to incorporate revised circumstances under which use of a foreign-flag air carrier is permissible. Article 13 now addresses Airline “Open Skies” Agreements between the US and a foreign government, which the Department of Transportation has determined meets the requirements of the Fly America Act. Article 13 provides information on the Open Skies Agreement with the European Union, and includes a link to the General Services Administration web site for additional information on other Open Skies Agreements.

February 2013 Update:

December 11, 2008

NSF Postdoc Mentoring Plan Required for Proposals Received On or After January 5

The revised National Science Foundation NSF Proposal and Award Policies and Procedures Guide (PAPPG) (NSF 09-1) is effective for proposals received on or after January 5, 2009.

One significant change is that NSF has added a new requirement to the Proposal Preparation Instructions regarding mentoring for postdoctoral fellows. Proposals that request funding to support postdoctoral researchers that do not include a separate section on mentoring activities will be returned without review.

The revised NSF instructions state that: “Each proposal that requests funding to support postdoctoral researchers must include, as a separate section within the 15-page Project Description, a description of the mentoring activities that will be provided for such individuals. Examples of mentoring activities include, but are not limited to: career counseling; training in preparation of grant proposals, publications and presentations; guidance on ways to improve teaching and mentoring skills; guidance on how to effectively collaborate with researchers from diverse backgrounds and disciplinary areas; and training in responsible professional practices. The proposed mentoring activities will be evaluated as part of the merit review process under the Foundation's broader impacts merit review criterion. Proposals that do not include a separate section on mentoring activities within the Project Description will be returned without review.”

The revised PAPPG includes some other notable changes; NSF included a Summary of Significant Changes with the Grant Proposal Guide.

October 2008 Research Advocate: Significant Changes in New NSF Policies and Procedures Guide

December 05, 2008

Keeping Current with NIH: December News Highlights

NIH Announces the Availability of Adobe-Based Grant Application Forms

Adobe-based application forms are now available in Grants.gov for most National Institutes of Health funding opportunities; others will have the new forms added by early next week (December 8-12, 2008). NIH is making the transition to Adobe-based grant application forms from PureEdge-based forms.

Applicants should return to the NIH Funding Opportunity Announcement for which they are applying and download the new forms. Applicants can confirm that they are downloading the new Adobe forms by verifying that the Competition ID on the Download Application page of the Grants.gov website is “ADOBE-FORMS-A.”

NIH reminds investigators that a Grants.gov compatible version of Adobe Reader is required to prepare and submit an Adobe-based application. Grants.gov currently recommends Adobe Reader versions 8.1.3 or higher; compatible versions are listed on the Grants.gov Download Software page. The Grants.gov compatible version of Adobe Reader must be installed before downloading the new application forms.

NIH provides more information on the Resources for Adobe Transition page of the Electronic Submission web site.


Enhancing Peer Review at NIH:
Updated Implementation Timeline
New Scoring Procedures for Evaluation of Research Applications Received for Potential FY2010 Funding
Enhanced Review Criteria for Evaluation of Research Applications Received for Potential FY2010 Funding

In June 2007, the NIH initiated a formal, agency-wide effort to review the NIH peer review system (http://enhancing-peer-review.nih.gov/). After careful deliberation and consideration of the recommendations resulting from the year-long effort, NIH is making a number of changes to the peer review system.

On December 2, 2008, NIH issued three NIH Guide notices related to enhancing peer review: an updated timeline for implementing key actions, a new scoring system for reviewers, and enhanced review criteria.

The first standing due date for fiscal year 2010 is January 25, 2009; the new scoring system and enhanced criteria will be used for applications submitted in response to NIH Parent Announcements and Program Announcements, including PARs and PASs published before or after these notices. Some RFAs and PARs for funding consideration in FY 2010 have due dates before January 25, 2009, and responses to those will be evaluated using the new scoring system and enhanced criteria. Likewise some RFAs and PARs for FY 2009 have due dates after January 25, 2009, and responses to those will be evaluated using the present scoring system and criteria.

November 12, 2008

New AVC for Research Administration and Compliance

The Vice Chancellor for Research Office issued the following news through CALmessages on November 12, 2008.


From: Beth Burnside, Vice Chancellor for Research (Campus-wide)
To: Deans, Directors, Department Chairs, Senior Administrative Officers
Subject: New AVC for Research Administration and Compliance


Deans, Directors, Department Chairs, Senior Administrator Officers:

As many of you may have already heard, Marcia Smith, our AVC for Research Administration and Compliance, has accepted an offer to serve in a broadened role as Associate Vice Chancellor for Research Administration at UCLA. She will be leaving Berkeley early in the new year. During the two and one-half years that she has served at Berkeley, Marcia has provided leadership for contract and grant administration and for compliance in areas of research with animal and human subjects and financial conflict of interest. Although we are sad to see her leave Berkeley, we thank her for all she has accomplished here and wish her the best of luck in her broadened role and responsibilities at UCLA.

I am, at the same time, happy to announce that Pat Schlesinger will be replacing Marcia as the Berkeley campus Assistant Vice Chancellor for Research Administration and Compliance. Pat will take up his new position on December 8, 2008, allowing a short overlap in our AVC appointments so as to ensure a smooth transition.

Pat Schlesinger comes to Berkeley from UCOP, where he has worked for twelve years; first in the Office of General Counsel as Group Leader of the Environmental Law Group, and, more recently, as Director of Research Compliance. Pat brings to the Berkeley campus and our research office an extraordinary depth and breadth of knowledge in the area of Federal and State regulations that impact research institutions and research activities. I have worked with Pat over the last few years on various things and relied on him many times for advice in negotiating the complex world of research regulations. I know he will be a valuable asset to the Berkeley administration and a terrific colleague. I can not be more pleased that he will be joining our team.

Robert M. Price
Associate Vice Chancellor for Research

October 29, 2008

RAC Offices to Close During the Annual Campus Winter Break

The Office for the Protection of Human Subjects, the Sponsored Projects Office, and the Research Administration and Compliance Office will be closed during the campus energy curtailment beginning Thursday, December 25, 2008 through Friday, January 2, 2009. The Animal Care and Use Committee Office will be closed beginning Wednesday, December 24, 2008 through Friday, January 2, 2009. Offices will reopen on Monday, January 5, 2009.

SPO Proposal Submission
  • Proposals with deadlines during the campus shutdown should arrive at SPO by Friday, December 12, 2008.
  • Proposals due at agencies in early January should be at SPO by Monday, December 15, 2008.
  • No deliveries will be accepted after noon on December 24, 2008; any documents left in the drop box over the break will not be retrieved and logged until January 5, 2009.
ACUC Protocol Submission
  • The deadline for protocol submission for the January 21, 2009 meeting is Monday, December 8, 2008.
  • The deadline for protocol submission for the February 18, 2009 meeting is January 12, 2009.
  • ACUC will be closed on December 24, 2008.
CPHS Protocol Submission
  • The deadline for protocol submission for the December 5, 2008 CPHS-I meeting is Monday, November 10, 2008.
  • The deadline for protocol submission for the December 19, 2008 CPHS-II meeting is Monday, November 24, 2008.
  • There is no CPHS-I meeting in January 2009; the deadline for protocol submission for the February 6, 2009 CPHS-I meeting is Monday, January 12, 2009.
  • The deadline for protocol submission for the January 16, 2009 CPHS-II meeting is Monday, December 22, 2008.
  • Important: if your study was given full board review last January and approval will expire before January 16, 2009, you must submit your renewal application in time for review at a December 2008 CPHS meeting.
  • No deliveries will be accepted after noon on December 24, 2008; any documents left in the drop box over the break will not be retrieved and logged until January 5, 2009.

October 24, 2008

New NIH NRSA Fellowship Certification Form

Beginning December 1, 2008, a new certification form will need to be submitted to SPO with Ruth L. Kirschstein National Research Service Award (NRSA) PHS 416-1 grant applications, PHS 416-9 progress reports, and post-award prior approval requests for individual fellowships.

On October 14, 2008, NIH announced a change regarding the signatures of the applicant (individual fellow) and sponsor(s) as a part of PHS 416-1 grant applications, certain post-submission information, PHS 416-9 progress reports, and post-award prior approval requests. The change requires each institution to secure and retain the individual fellow and sponsor(s) signatures as part of the institutional review/approval process. This change in business process for individual fellowships now brings them in line with the similar business process change for principal investigators instituted in 2006.

This business process change applies to all competing applications prepared using the PHS 416-1 application for submission/receipt dates in December 2008 and thereafter. The change will apply to all progress reports for continuation support submitted for submission/receipt dates of December 1, 2008 and thereafter.

To meet the requirement, the Sponsored Projects Office has developed a new form, the “NIH NSRA Fellowship Assurance Certification Form.” The form must be submitted to SPO with NIH PHS 416 fellowship applications, progress reports, and prior approval requests beginning December 1, 2008. The form is available at http://www.spo.berkeley.edu/Forms/UCForms.html.

The NIH Guide announcement of this change and other changes to PHS 416 are available at http://grants.nih.gov/grants/guide/WeeklyIndex.cfm/10-17-2008/.

Please contact the SPO research administrator assigned to your department with any questions.

October 22, 2008

VCR Policy on Late Proposal Submissions to SPO

On October 22, 2008, Vice Chancellor for Research Burnside issued a new VCR Policy on Late Proposal Submissions to SPO through CALmessages. The text of the new policy is included below.


From: Beth Burnside, Vice Chancellor for Research
To: Deans, Directors, Department Chairs
Re: VCR Policy on Late Proposal Submissions to SPO


I am writing to alert you to a new policy that I am putting into practice for contract and grant proposals that are submitted after the SPO deadline. As you know, UC Berkeley policy is that complete proposals must be submitted to the Sponsored Projects Office five working days in advance of the sponsor's deadline. In consideration of the volume of proposals and the growing complexity of the proposal submission process, it is essential that principal investigators observe the SPO deadline to allow adequate time for staff members in the Departments and in SPO to work through the many issues that arise before a proposal can be submitted for the sponsor's deadline. Very often a high number of proposals are received by SPO at one time, and because there are difficulties with grants.gov and other on-line submission systems, late proposals create great stress for all staff members and jeopardize timely submission. Further, late proposals often delay the proposals of principal investigators who have submitted their proposals to SPO on time.

Late proposal submissions are a significant problem for the campus. In the last 12 months SPO received 2,909 proposals with a stated sponsor deadline. Of those, about 27% (782) were received by SPO less than 2 days before the sponsor deadline, and nearly 14% (401) were received on the same day they were due to the sponsor. This ongoing problem with late proposal submissions creates a “log-jam” that jeopardizes SPO's ability to transmit to funding agencies those applications that have been submitted on time. Hence, the PIs that have been ignoring the SPO five-day deadline are placing in jeopardy the more numerous PIs who are submitting in a timely fashion. I have on several occasions urged the campus faculty to observe the SPO submission schedule. That has not had a noticeable effect on the volume of late submissions. As a continuation of the current situation is simply untenable, a new policy is required. The following policy will become effective Monday, November 3, 2008.

• Any proposal that is to be submitted to SPO less than five working days before the sponsor deadline will require the prior approval of both the Department Head or Director of the submitting unit and the Vice Chancellor for Research before it will be processed by SPO.

• I have asked SPO management not to approve proposals received after the SPO deadline unless this policy has been followed.

• SPO will no longer have authority to grant extensions on its own to principal investigators to submit proposals after the five-day deadline. All extensions must be approved by the VCR to be processed. This policy applies to paper and electronic submissions of new, competing renewal, continuation and re-submission proposals regardless of sponsor, if the sponsor specifies a deadline. If no deadline is specified, SPO will expect to have five working days to process the proposal from the time of receipt.

• Sponsor requests for annual progress reports, revised budgets and other requests such as this are not subject to this policy.

• To obtain approval to submit a proposal after the SPO deadline, the Principal Investigator must send a request via email to the appropriate Department or Lab Head and lead administrative officer, with a copy to Marcia Smith, AVC-RAC. The request must explain why the proposal is late and describe the reasons why it could not or cannot be submitted on time. The justification will need to be very compelling for it to be considered for exception to this policy.

• If the Department or Lab Head or designee approves the late submission, he/she must notify Marcia Smith and forward the proposal to my office for consideration and approval. Once we receive the Department approval, we will try to respond to the Department, the Principal Investigator and SPO within one day. Please note that if I approve the proposal for submission, it will be processed by SPO in the order it was received.

I ask that you inform all principal investigators in your unit of this policy. Please reinforce to principal investigators the importance of this policy so that they are aware that as a result they may be prevented from submitting a late proposal. I also want to note that although every effort will be made to submit approved late proposals by the sponsor's deadline, there are no guarantees that they will make it through the system in time.

My staff and I appreciate your cooperation as we work through the implementation of this new policy. If you have questions or would like to discuss the policy, do not hesitate to call Marcia Smith or myself.

Sincerely yours,
Beth Burnside
Vice Chancellor for Research

October 06, 2008

Keeping Current with NIH: Recent News Highlights

The National Institutes of Health Office of Extramural Research (OER) provides several sources for current news related to grants policy, funding programs, compliance, and electronic research administration.
Some recent important NIH announcements are linked and summarized below.


New NIH Policy on Resubmission (Amended) Applications (October 10 NIH Guide)

Beginning with original new applications and competing renewal applications submitted for the January 25, 2009 due dates and beyond, NIH will accept only a single amendment to the original application. Applicants who fail to receive funding after two submissions (i.e., the original and the single amendment) may resubmit but only if the application is fundamentally revised to qualify as new. A new application is expected to be substantially different in content and scope with more significant differences than are normally encountered in an amended application.

Original new and competing renewal applications that were submitted prior to January 25, 2009 will be permitted two amendments. For these “grandfathered” applications, NIH expects that any second amendment will be submitted no later than January 7, 2011.


Non-Competing Grant Awards under the Current Continuing Resolution

The Department of Health and Human Services continues to operate on a continuing resolution (CR) that currently extends through March 6, 2009. The CR applies the terms of the FY 2008 appropriations for the period covered by the CR. Until the final FY 2009 appropriation is enacted, NIH will issue non-competing research grant awards at a level below that indicated on the most recent Notice of Award (generally up to 90 percent of the previously committed level). This is consistent with NIH practice during the CRs of FY 2006-2008. NIH will consider upward adjustments to these levels after the final appropriation is enacted, but expects institutions to monitor their expenditures carefully during this period. NIH plans to publish additional details at http://grants.nih.gov/grants/financial/index.htm.

UC Berkeley questions regarding adjustments applied to individual grant awards amay be directed to the Grants Management Specialist identified on the Notice of Award.


Encouraging Early Transition to Research Independence: Modifying the NIH New Investigator Policy to Identify Early Stage Investigators

The NIH New Investigator policy been changed to encourage early transition to independence. Under the revised policy, New Investigators within ten years of completing their terminal research degree or within ten years of completing their medical residency will be designated Early Stage Investigators (ESIs). Beginning with traditional R01 applications received for the February 2009 receipt dates, NIH will identify applications from ESIs and New Investigators, and the career stage of the PD/PI will be considered at the time of review and award. NIH will be developing and issuing more complete information, instructions, and Frequently Asked Questions before the February R01 receipt dates.


Reminder Concerning Grantee Compliance with Public Access Policy and Related NIH Monitoring Activities

NIH principal investigators are subject to the terms of the NIH Public Access Policy. The policy, issued in January, requires scientists to submit final peer-reviewed journal manuscripts that arise from NIH funds to the digital archive PubMed Central upon acceptance for publication and requires that these papers are accessible to the public on PubMed Central no later than 12 months after publication.

NIH published a notice in the September 25 NIH Guide describing NIH Public Access Policy compliance monitoring efforts for fiscal year 2009, along with a reminder about grantee compliance with the policy and the location of citations for papers in applications, proposals and progress reports.

1/18/2008 Research Advocate article: NIH Public Access Policy Now Required


Announcing Transition Schedule for NIH/AHRQ/CDC/NIOSH/FDA to Adobe-based forms for SF424 Research and Related (R&R) Electronic Submissions through Grants.gov

Most electronic submissions to NIH on or after January 1, 2009, must use Grants.gov Adobe application forms. NIH has issued a schedule for the transition to Adobe forms.

Investigators planning to apply to NIH should be aware of that new Funding Opportunity Announcements released after September 1, 2008, will not have Adobe application forms for downloading until December 2008. Applicants will need to check the FOA in December to download the new Adobe application forms. Also, applicants should be aware that Grants.gov requires the use of very specific versions of Adobe Reader, currently 8.1.1, 8.1.2, or 9.0. The Grants.gov web site has a list of compatible versions that is updated when Adobe releases new editions.

For additional information, see the NIH Resources for Adobe Transition web page and the September 29 eRA Commons Items of Interest.


Elias A. Zerhouni to End Tenure as NIH Director

Dr. Elias Zerhouni announced his plans to step down as the director of NIH at the end of October 2008. He plans to pursue writing projects and explore other professional opportunities. Dr. Zerhouni has served as NIH director since May 2002.

October 02, 2008

Significant Changes in New NSF Policies and Procedures Guide

The National Science Foundation has published a revision to the NSF Proposal and Award Policies and Procedures Guide (PAPPG) (NSF 09-1), that will be effective for proposals received on or after January 5, 2009. The revision includes some notable changes; NSF has included a Summary of Significant Changes with the Grant Proposal Guide.

The revised PAPPG (NSF 09-1) becomes effective on January 5. Until then, the current PAPPG (NSF 08-01) will continue to apply. NSF plans to revise existing funding opportunities with due dates between January 5 and March 31 to alert proposers to the revisions in the proposal preparation guidelines.

Some of the more significant changes are described below. For information on additional changes, see the Summary of Significant Changes.

Mentoring Requirement for Postdoctoral Research Fellows

One major change is that NSF has added new guidance to the Proposal Preparation Instructions regarding mentoring for postdoctoral fellows, done to address and implement the mentoring requirement of the America COMPETES Act. The revised instructions state that: “Each proposal that requests funding to support postdoctoral researchers must include, as a separate section within the 15-page Project Description, a description of the mentoring activities that will be provided for such individuals. Examples of mentoring activities include, but are not limited to: career counseling; training in preparation of grant proposals, publications and presentations; guidance on ways to improve teaching and mentoring skills; guidance on how to effectively collaborate with researchers from diverse backgrounds and disciplinary areas; and training in responsible professional practices. The proposed mentoring activities will be evaluated as part of the merit review process under the Foundation's broader impacts merit review criterion. Proposals that do not include a separate section on mentoring activities within the Project Description will be returned without review.”

Senior Project Personnel Salary

The revised Proposal Preparation Instructions also include a major revision of NSF’s faculty salary reimbursement policy. NSF will “limit salary compensation for senior project personnel to no more than two months of their regular salary in any one year. This limit includes salary compensation received from all NSF-funded grants. This change moves away from the concept of summer salary and allows for reimbursement of two months of salary per year whenever appropriate during the year.” NSF also states that any anticipated compensation “in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice.”

RAPID and EAGER Replace SGER

The revision also introduces two new award mechanisms, Grants for Rapid Response Research (RAPID) and EArly-concept Grants for Exploratory Research (EAGER), that will replace the Small Grants for Exploratory Research (SGER) program. RAPID will support quick-response research on natural or anthropogenic disasters and similar unanticipated events with grants of up to $200,000 for one year. EAGER will support high-risk, exploratory, and potentially transformative research with grants of up to $300,000 for up to two years.

PI/Co-PI Definition

Another change in the revised PAPPG is that NSF has clarified the co-Principal Investigator definition to state that NSF does not infer any distinction in scientific stature among multiple PIs, whether referred to as PI or co-PI. NSF will hold all of the senior personnel equally responsible for the conduct of the project and submission of the requisite project reports. The change is found in Exhibit II-7 – Definitions of Categories of Personnel. NSF made this revision for greater consistency with guidance issued by the Office of Science and Technology Policy.

October 01, 2008

New Guidelines on Activities that Require CPHS/OPHS Review

The campus Committee for Protection of Human Subjects and Office for the Protection of Human Subjects have developed new CPHS Guidelines on Activities that Require CPHS/OPHS Review in response to investigator requests for additional guidance about when to submit an application for CPHS/OPHS review.

Please consult with OPHS if you have any questions in this regard. CPHS welcomes any comments from the research community about this new guidance.

RAC Forum Schedule for the Coming Year

Another year of Research Administration and Compliance Forum meetings is underway after a summer break. The monthly RAC Forum is primarily intended for campus administrative staff, but all are welcome. The first meeting was held in September and featured updates from RAC leadership, presentations on subaward business process analysis and the Subrecipient Commitment Form pilot, and an open forum to discuss ideas for topics for future meetings.

Upcoming RAC Forum meetings are scheduled from 10:30 a.m. until noon on the following dates:
  • October 8, 2008
  • November 12, 2008
  • December 10, 2008
  • January 14, 2009
  • February 11, 2009
  • March 11, 2009
  • April 8, 2009
  • May 13, 2009
  • June 10, 2009
Meetings will be held in the Tilden Room, 5th floor, ASUC Martin Luther King Jr. Student Union building. Contact Shelley Sprandel (2-8122, spore@berkeley.edu) to be added to the RAC Forum e-mail list.

AAAS Update on R&D in FY 2009 Federal Budget

The American Association for the Advancement of Science (AAAS) R&D Budget and Policy Program has issued a report, Federal Research Funding Flat in 2009 as Federal Budget Stalls, analyzing the current status of research and development funding in the fiscal year 2009 federal budget as of September 30.

The 2009 federal fiscal year began on October 1, but Congress is preparing to break without finishing the budget. To allow federal agencies without 2009 budget appropriations to continue spending, Congress passed a continuing resolution that would allow spending at or below 2008 funding levels through March 6, 2009. The continuing resolution included appropriations for only three agencies: the Departments of Defense, Homeland Security, and Veterans Affairs. These three agencies received substantial increases in R&D.

Agencies in the other nine unsigned appropriations bills will be operating temporarily at or below 2008 funding for several months. This includes the National Institutes of Health and other Department of Health and Human Services agencies, National Science Foundation, Department of Energy, NASA, Department of Commerce, USDA, Department of Interior, and Department of Transportation.

A detailed summary of the overall budget outlook for FY 2009 as well as in-depth analysis for each agency is available on the AAAS R&D Budget and Policy Program web site.

September 30, 2008

Redesigning the Campus Research Subaward Process

Background: Business Process Analysis

The Research Administration and Compliance Office (RAC) was one of several campus groups participating in the business process analysis workshop recently offered by the campus Center for Organization and Workforce Effectiveness (http://administration.berkeley.edu/forms/newsletter/spring-08-about.htm#bpa). The workshop, held from March to May 2008, provided coaching and training for teams actively engaged in improving real campus business processes.

The workshop provided participants with tools and methods to help analyze processes, identify areas for improvement, redesign processes to incorporate improvement ideas, and lay out a framework for ongoing review and improvement of processes.

Assistant Vice Chancellor for Research Marcia Smith selected a team of RAC and Sponsored Projects Office (SPO) staff to participate in the workshop and focus on the research subaward business process. The issuing of subawards under research grants and contracts is an operational challenge for most research institutions and is a process that is growing in volume and complexity.

The RAC business process analysis team was trained to use a set of tools and various approaches to business process redesign, and they applied that training to redesigning the subaward process. As a result of the team's effort, several improvements have already been made to the subaward process and more are on the way.

Subaward Process Improvement: Coeus Data for PIs

One major change is that more complete and current data on subawards and subawardee organizations is now being collected in Berkeley Coeus and can be shared with principal investigators and staff. Based on the new subaward information carried in Coeus, the Notice of Award sent to PIs and administrators now includes more detailed information, including the status of each subaward and guidance for the PI and department about what the status means for them. In addition, Berkeley Coeus Web will soon have a new research subaward report so that PIs and department staff can track subaward status online. The following statuses for subawards have been defined and implemented.

1. Pending: The subaward is known by SPO but a Subaward Request Form has not been submitted by the department.
2. In process: The Subaward Request Form has been received by SPO, and the subaward is being prepared for signature and transmission to the subawardee.
3. Amendment in process: The Subaward Amendment Request Form has been received by SPO and the amendment is in process.
4. Awaiting subawardee response: The subaward/amendment has been sent to the subawardee, but has not yet been returned fully signed.
5. Active: The subaward is fully executed and distributed.
6. Inactive: The subaward’s final expiration date has passed.

In addition to providing more information to PIs and staff, tracking and managing subaward data in Coeus is key to complying with federal regulations, including the Federal Funding Accountability and Transparency Act (FFATA), which will require the campus to provide data about subawards to the federal government for public access (http://www.usaspending.gov/).

Subaward Process Improvement: Subrecipient Commitment Form

SPO will be offering a new tool for campus departments, the Subrecipient Commitment Form. The new form serves as a checklist that will assist faculty and staff in collecting required information from subrecipients. Key information about a subaward project will be in one place, including information about the subawardee organization (debarment, suspension, financial controls, A-133 compliance) and the proposed project (statement of work, budget, indirect costs, fringe benefits, compliance reviews, cost sharing). The form will enhance institutional compliance with federal regulations and UC policy (A-133, FFATA, BUS-43, etc.) and reduce audit exposure.

The Subrecipient Commitment Form is based on commitment forms now in use at many other universities, including other UC campuses. The form is completed by the subawardee’s sponsored projects office and PI, endorsed by the subawardee's authorized institutional representative, and provided at proposal stage with other proposal documents. It will eliminate the need for letters of commitment currently obtained from subawardees at proposal stage. All information requested on the form is already provided at some point in the proposal and award process, often after time-consuming research by the principal investigator, department, and SPO.

Before the new forms are put into use campus-wide in January 2009, SPO has asked several departments to participate in a two-month pilot of the forms and instructions. The pilot will also include an additional form to be used for contracts only, the Fair and Reasonable Cost Analysis/Sole Source Justification Form. This form, to be completed and signed by campus principal investigators, will provide information that is required by UC policy for research subcontracts under contract awards (UCOP Contract & Grant Memo 85-31 and operating guidance for BUS-43).

Feedback from the pilot will be incorporated into the process and procedures. For more information on or to participate in the pilot, contact Patricia Gates (pgates@berkeley.edu or 2-8109).

Members of the RAC subaward process analysis team are Patricia Gates, Jennifer Nadeau, Dan Jacobs, Nancy Han, Alaisha Hellman, Neil Maxwell, and Shelley Sprandel.

Future Plans

RAC is also working on revising additional subaward procedures, guidance, and forms, as well as continuing to make internal process changes to simplify and expedite research subaward processing. Newly learned business process analysis skills will also be applied to other processes used in SPO, Office for the Protection of Human Subjects, Office of the Animal Care and Use Committee, and Conflict of Interest Committee operations in the months to come. Look for more news in the next several months.

September 24, 2008

Enhancing Peer Review at NIH: Implementation Plans for 2009-10

Grant applications to the National Institutes of Health are evaluated initially by peer review groups composed of scientists from the extramural research community.

In June 2007, NIH began a comprehensive examination of the NIH peer review system with the goal of maximizing the system’s effectiveness, documenting the effort on the Enhancing Peer Review at NIH web site.

To begin the process, NIH formed working groups that solicited formal input from key stakeholders in both external and internal communities. The Final Draft Report issued in February 2008 describes the outcome of the diagnostic phase and the recommendations made by the working groups. In March 2008, NIH established a steering committee to draft implementation plans for each recommended action. A Peer Review Enhancements and Implementation Plan was announced in June. On September 19, NIH published an NIH Guide notice, Announcing Initial Implementation Timeline for Enhancing Peer Review, that outlines the preliminary implementation plans for the 2009 through 2010 calendar years, as follows:

Priority Area 1 – Engage the Best Reviewers
  • Improve Reviewer Retention: In 2009, new reviewers will be given additional flexibility regarding their tour of duty, and other efforts will be undertaken to improve retention of standing review members.
  • Recruit the Best Reviewers: A toolkit, incorporating best practices for recruiting reviewers, will be made available to all ICs in 2009.
  • Enhance Reviewer Training: In spring 2009, training will be available to reviewers and Scientific Review Officers (SROs) related to the changes in peer review.
  • Allow Flexibility through Virtual Reviews: Pilots will be conducted in 2009 on the feasibility of using high-bandwidth support for review meetings to provide reviewers greater flexibility and alternatives for in-person meetings.
Priority Area 2 – Improve the Quality and Transparency of Review
  • Improve Scoring Transparency and Scale: Review criteria-based scoring on 1 to 7 scale commences in May 2009. Reviewers will provide feedback through scores and critiques for each criterion in a structured summary statement.
  • Provide Scores for Streamlined Applications: In 2009, streamlined applications will receive a preliminary score.
  • Shorten and Restructure Applications: Shorter (12-page research plan) R01 applications (with other activity codes scaled appropriately) will be restructured to align with review criteria for January 2010 receipt dates.
Priority Area 3 – Ensure Balanced and Fair Reviews across Scientific Fields and Career Stages, and Reduce Administrative Burden
  • Fund the Best Science Earlier and Reduce Need for Resubmissions: To ensure that the largest number of high quality and meritorious applications receive funding earlier and to improve system efficiency, NIH is considering separate percentiling of new and resubmitted applications and permitting one amended application.
  • Review Like Applications Together: NIH is establishing an Early Stage Investigator (ESI) designation. In 2009, NIH will evaluate clustering ESI applications for review. The same approach will be considered for clinical research applications.

Resources:

Enhancing Peer Review at NIH: http://enhancing-peer-review.nih.gov/index.html
NIH Peer Review Policies & Practices: http://grants.nih.gov/grants/peer/
NIH Center for Scientific Review: http://cms.csr.nih.gov/
August 2008 Extramural Nexus Article – Update on Peer Review: http://nexusdev.od.nih.gov/nexus/nexus.aspx?Month=8&Year=2008&ID=137

ACLS Offers Grants for Collaborative Research in the Humanities and Social Sciences

The American Council of Learned Societies (ACLS) is offering a new grant program that funds collaborative research in the humanities and related social sciences. ACLS Collaborative Research Awards will provide up to $140,000 per project for up to two years. Collaborations do not need to be interdisciplinary or inter-institutional, but must involve at least two scholars. Applicants at the same institution must demonstrate why local funding is insufficient to support the project. The deadline for applications is November 12, 2008.

ACLS also offers a variety of other grant and fellowship programs that support research in the humanities and social sciences. More specifics are available on the ACLS Competitions and Deadlines page.

September 11, 2008

NIH Funding New Transformative R01 Program

The National Institutes of Health has published the first Funding Opportunity Announcement (FOA) for the new Transformative R01 (T-R01) program. With the FOA, NIH is soliciting transformative Research Project Grant (R01) applications for ‘‘exceptionally innovative, high risk, original and/or unconventional research with the potential to create new or challenge existing scientific paradigms. Projects must clearly demonstrate potential to produce a major impact in a broad area of biomedical or behavioral research.’’ NIH plans to to commit $25 million dollars in fiscal year 2009 to fund up to 60 applications. Applications are due January 29, 2009.

NIH intends to invest more than $250 million in the program, which was developed as an NIH Roadmap Initiative, over the next five years. The T-R01 program will support original studies that will:
  • Forge the synthesis of new paradigms for biomedical or behavioral sciences.
  • Reflect an exceptional level of creativity in proposing bold and ground-breaking approaches to fundamental problems.
  • Promote radical changes in a field of study with a profound impact in other scientific areas.
  • Be evaluated by new procedures being piloted by the NIH Center for Scientific Review that are distinct from the traditional NIH peer review process.
NIH is encouraging applications for projects in any area of NIH interest that meet the transformative criteria. Areas of highlighted need include:
  • Understanding and Facilitating Human Behavior Change
  • Complex 3-Dimensional Tissue Models
  • Functional Variation in Mitochondria in Human Disease
  • Transitions from Acute to Chronic Pain
  • Formulation of Novel Protein Capture Reagents
  • Providing an Evidence Base for Pharmacogenomics
For more information:

September 04, 2008

NSF Encourages Comments on Cost Sharing

The National Science Board (NSB) Task Force on Cost Sharing is currently examining the National Science Foundation cost-sharing policy. The NSB recently published a notice in the Federal Register soliciting public comment regarding the research communities’ experiences on use of cost sharing in NSF-funded activities. Comments must be received by October 1, 2008.

NSF Director Arden Bement, Jr. has issued a ‘‘Dear Colleague’’ letter strongly encouraging comments from the research community in response to this notice.

NSF’s letter emphasizes that the NSB is ‘‘particularly interested in receiving feedback on the following: (1) the relationship between cost sharing and NSF program goals; (2) the relationship between cost sharing and institutional competitiveness in NSF grant funding; (3) the role of cost sharing in the NSF merit review process; (4) the importance of types, sources, and timing of voluntary cost sharing; (5) effort associated with tracking and reporting cost-shared resources; (6) the relationship between cost sharing and institutional strategic investment; (7) options for ensuring equity in NSF grant funding when cost sharing is either required or volunteered; (8) research resources from state providers; and (9) research resources from industry providers.’’

August 26, 2008

Emerging Contract and Grant Issues: Federal Focus Areas

Associate Vice Chancellor John Ellis and Assistant Vice Chancellor Marcia Smith sent the following information and guidance to campus administrative staff on August 26, 2008.


This is to bring to your attention three areas that are currently the focus of federal agencies and their audit divisions in their review of colleges and universities.

1. Advancing funds to subrecipients

The federal government only allows for advance funding in rare circumstances when a subrecipient lacks sufficient working capital to perform the work (see Circular A-110, subpart C, 22(f) at http://www.whitehouse.gov/omb/circulars/a110/a110.html#22).

In the rare event that you make an advance to a subrecipient, please ensure the advances are made in accordance with University and federal regulations prior to advancing funds. You should only advance the amount of money needed to cover the short term working capital needs of the subrecipient organization. For example if the subaward is $100k for research work to be performed over a 12 month period, you should not advance the full amount of the subaward. If the subrecipient cannot finance their working capital needs on a month-to-month basis, you might advance $5k or the equivalent of one month’s payroll needs.

If an advance has been made, care needs to be exercised to ensure the work is performed in accordance with the terms of the subaward and documentation is provided by the subrecipient demonstrating the work has been completed. If the subrecipient has not provided documented support for the work performed, you should not advance further funds on this subaward until you are satisfied the subrecipient is performing the agreed upon research and you could prove to the federal government or other parties that the subrecipient has completed the work.

See http://extramuralfundsaccounting.berkeley.edu/POLICY/SubRecipientMonitoring.htm for further guidance on monitoring subrecipients. Please note that most subrecipients can meet their short term working capital needs and can do business on a cost reimbursable basis rather than requiring an advance.

2. Cost transfers

Due to the high incidence rate of late or inadequately documented costs transfers, audit divisions of the federal government are paying special attention to cost transfers across the UC system. To minimize your exposure to disallowance, please ensure you are meeting the requirements of the campus cost transfer policy available at http://generalaccounting.berkeley.edu/costtransferpolicy.pdf.

In previous years, cost transfers that were late or inadequately documented have been disallowed by federal agencies on UC contracts and grants.

3. Sponsors enforcing contractual reporting deadlines

Some federal sponsors have recently refused to pay invoices because reports were not submitted by established deadlines. This applies to all reports including technical, progress, and financial reports. Although past practice has allowed for payment regardless of whether a report was submitted late, some agencies are now strictly enforcing their policy of non-payment for proper charges when we fail to comply with terms and conditions including federal reporting requirements.

**Departments will absorb disallowed or unpaid costs**

In the event that costs are disallowed or not paid by federal funding agencies in any of the areas described above, the administering department or unit will be required to cover these disallowed costs from unrestricted funds. UC Berkeley campus departments have in the past had to cover disallowed costs in these areas.

Please work with your Principal Investigators to ensure that your awards follow proper procedures to minimize your department’s exposure to disallowed expenses. Contact your Extramural Funds Accounting Analyst or Sponsored Project Office Analyst if you have further questions on these topics.

John Ellis
Associate Vice Chancellor-Finance, and Controller

Marcia L. Smith
Assistant Vice Chancellor, Research Administration and Compliance

August 22, 2008

NIH Publishes Web-based Tutorial on Financial Conflict of Interest Requirements

The National Institutes of Health has announced a web-based tutorial developed to help improve and enhance compliance with federal financial conflict of interest regulations. NIH designed the tutorial for use by “institutional officials responsible for managing NIH-funded grants, cooperative agreements and/or contracts and for individuals who are responsible for the design, conduct or reporting of NIH-supported research.”

The tutorial is available in both Flash and PDF format on the NIH Office of Extramural Research Conflict of Interest web page: http://grants.nih.gov/grants/policy/coi/index.htm.

July 24, 2008

UCOP Lab Research Program RFP: Special Instructions

UCOP Lab Research Program (http://www.ucop.edu/labresrfp/) proposals being submitted for the August 4, 2008 deadline should not be submitted to the Sponsored Projects Office before being submitted through proposalCENTRAL. However, if a proposal is selected for funding, then the PI/department is required to submit the proposal, PRF, and any compliance information to SPO for approval. Please direct any questions to your SPO research administrator.

July 21, 2008

Review, Approval and Reporting of Requests for Funding from Tobacco Industry Sponsors

Vice Chancellor for Research Burnside issued campus guidance on the new UC policy that require special review, approval, and reporting procedures for all research proposals to be submitted for funding to tobacco industry sponsors. The text of the memo is included below. The Proposal Review Form now includes a checkbox to indicate a tobacco industry sponsor.



Date: 7/15/2008
Sender: Beth Burnside, Vice Chancellor for Research (Campus-wide)
To: Deans, Directors, Department Chairs, Senior Administrative Officers
Subject: Review, Approval and Reporting of Requests for Funding from Tobacco Industry Sponsors

At its meeting last fall, the Board of Regents adopted a new policy to require special review, approval, and reporting procedures for all research proposals to be submitted for funding to tobacco industry sponsors. The Regental Resolution (RE-89) requires each UC campus to put in place procedures to ensure that any proposal to be submitted to "an entity whose principal business is the manufacture and sale of tobacco products, and agencies that are substantially controlled by or acting on behalf of such entities" undergo scientific peer review by the campus and be explicitly approved by the Chancellor before submittal to the tobacco industry sponsor.

RE-89 sets out guidelines for instituting the campus peer review committees and requires that the committees provide a written report of recommendations to the Chancellor. Also, RE-89 requires that the Chancellor provide the researcher, the UC President, and The Regents with a written determination approving or disapproving the request to submit the proposal. No proposal may be submitted to a tobacco company without this review and written approval.

Therefore, any PI who is considering submitting a proposal to a tobacco industry sponsor should contact my office immediately so that we can ensure timely initiation and conduct of the required review and determination process. Principal Investigators must receive a project-specific written determination of approval from the Chancellor before a research proposal can be submitted to a tobacco company.

Finally, RE-89 urges researchers to consider carefully whether or not to accept research funding from the tobacco industry and to exercise the utmost care and vigilance in all research to ensure that no funder is allowed to direct or control the outcome of the research or the dissemination of its results.

The text of RE-89 and the Model Policy on Tobacco industry Funding of Research at the University of California is available at: http://www.ucop.edu/research/policies/documents/review_approval_re89.pdf.

Please contact Marcia Smith, Assistant Vice Chancellor for Research Administration and Compliance at 642-2866 or m_smith@berkeley.edu if you have any questions about the campus procedure, or need assistance in determining whether a specific entity is, or is not considered to meet the definition of the "tobacco industry" for the purpose of the Regental policy.

Beth Burnside
Vice Chancellor for Research

June 17, 2008

Federal Agencies Implementing New Standard Research Terms and Conditions

On January 25, 2008, the National Science and Technology Council (NSTC) published a Federal Register Final Notice giving federal agencies a new standard core set of administrative terms and conditions on research and research-related awards that are subject to OMB Circular A-­110, ‘‘Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations’’ (2 CFR part 215).

The new core set of research terms and conditions is largely based on the terms and conditions that have been used for a number of years by the Federal Demonstration Partnership (FDP). Agencies are also encouraged to use the documents that the FDP maintains for national policy requirements and requirements that flow down to subrecipients. The goal is to create greater consistency in the administration of federal research awards.

Effective July 1, 2008, federal research agencies and awarding offices participating in the FDP must use the core set of administrative requirements, to the maximum practicable extent, in their research and research-related grant awards to organizations that are subject to 2 CFR part 215. Agencies and awarding offices may supplement the core set with agency-specific, program-specific, or award-specific administrative requirements, but should limit supplemental requirements to those that are consistent with 2 CFR part 215 or required by a statute that supersedes that part, and necessary for programmatic purposes or good stewardship of federal funds.

Other agencies and awarding offices that are not participating in the FDP are encouraged to replace administrative requirements in awards to organizations that are subject to 2 CFR part 215 with the core set of standard requirements and similarly limit their supplementation of those standard requirements.

Each member agency is required to post its plan for implementing the administrative requirements either at the NSTC Research Business Models Subcommittee site or at its own web site by July 1, 2008.

The National Science Foundation has established a Research Terms and Conditions web page that consolidates and organizes the new administrative requirements and related documents. The page currently includes:

May 27, 2008

New UC Program to Fund Campus/Lab Collaboration

The University of California is offering a new research opportunity funded by a portion of the management fees that may be awarded to the University for the management of the Los Alamos National Laboratory and the Lawrence Livermore National Laboratory based on an annual performance evaluation process included in each of the two management contracts. The Regents of the University have directed that this net fee income, anticipated to be approximately $20 million per year, be allocated to research that is related to the missions of the laboratories and emphasizes collaborations between University faculty, staff, and students and the research staff of the laboratories. Proposals may be for awards of $20,000 to $2 million per year for one to three years.

Update (6/19/2008): The deadline for letters of intent is now June 27, 2008 (originally June 20, 2008). Final proposals are due August 4, 2008. See http://www.ucop.edu/UC-Lab-Research for the Request for Proposals, Frequently Asked Questions, and additional information.

May 21, 2008

NIH Planning Move to Adobe Forms

The National Institutes of Health continues to plan the transition of Grants.gov application packages to Adobe forms, and has published an update in an April eRA Commons News announcement.

NIH has over 700 funding opportunity announcements (FOAs), and putting the grant application packages for all these announcements into the Adobe format is a big project. To test the system, NIH expects to issue a pilot FOA in August 2008 for an October receipt date. If the pilot is successful, then the full transition will begin in December 2008.

When the transition is complete, NIH will use the Adobe forms for all Grants.gov forms, including the training grants (T), career awards (K), and fellowships (F) application packages expected in 2009. More information about the transition is available at the NIH Electronic Submission Timeline page, updated May 12, 2008.

In the meantime, NIH has extended the expiration dates for several NRSA training, fellowship, and career development FOAs until January 8, 2010, and will continute to accept paper applications for the listed FOAs until these mechanisms have been converted to electronic submission.

Update (5/23/2008): NIH has summarized the NIH/AHRQ transition to Adobe application forms in a May 23 NIH Guide notice.

Update (7/2/2008): NIH has identified three FOAs to pilot the transition from PureEdge to Adobe-based grant application forms, with deadlines in mid to late October: Immune Defense Mechanisms at the Mucosa RFA-AI-08-020 (R21), and Harnessing Inflammation for Reconstruction of Oral and Craniofacial Tissues RFA-DE-09-001 (R01) and RFA-DE-09-002 (R21).

April 22, 2008

NEH/DOE Providing Support for Humanities Research on Supercomputers

The National Endowment for the Humanities (NEH) and the Office of Science in the U.S. Department of Energy (DOE) are working together to provide humanities scholars with access to DOE supercomputers.

Humanities High-Performance Computing grants provide computer time on DOE machines at the National Energy Research Scientific Computing Center at the Lawrence Berkeley National Laboratory, as well as training and support to enable scholars to take full advantage of those resources. The goal of the program is to provide opportunities for humanities scholars whose research requires high-performance computing to collaborate with computer scientists and others at centers already familiar with the challenges of intensive data mining, visualization, and other demanding applications.

Proposal guidelines are available at http://www.neh.gov/grants/guidelines/hhpc.html. The deadline is July 15, 2008.

April 04, 2008

NIH Creates New Central Processing Center for Closeout

The National Institutes of Health has announced a new business process and the creation of a centralized processing center for receiving closeout documents submitted for all NIH grants and cooperative agreements.

This centralized office receives and processes reports submitted by regular U.S. mail, courier, and overnight services, as well as by e-mail and fax. The office also processes information submitted electronically through the Closeout feature in the eRA Commons.

Effective immediately, all non-financial NIH closeout documents (such as the final progress report and HHS 568 Final Invention Statement and Certification) not submitted through the eRA Commons will be required to be submitted to the following address:

NIH Centralized Processing Center
6705 Rockledge Drive
RM 2207, MSC 7987
Bethesda, MD 20892 (for regular or U.S. Postal Service Express mail)
Bethesda, MD 20817 (for other courier/express deliveries only)
E-mail: DeasCentralized@od.nih.gov
Fax: (301) 480-2304

This does not include submission of the SF269 Financial Status Report which will continue to require electronic, online submission through the eRA Commons.

March 11, 2008

HHMI Offers New Grant Program for Early Career Faculty

The Howard Hughes Medical Institute (HHMI) announced a major new grant program for early career faculty in wide variety of fields, including all areas of basic biological and biomedical research, and areas of chemistry, physics, computer science, and engineering that are directly related to biology or medicine.

In the 2009 Early Career Scientist Competition, HHMI is offering over $300 million total to support as many as 70 investigators. Awardees will receive six-year, non-renewable appointments including full salary and research support while remaining affiliated with their home institution. A second competition is planned for 2011.

Applicants must have between two and six years of experience since first being appointed as an assistant professor or equivalent. The applicant's first faculty position as assistant professor must have begun no earlier than June 1, 2002, and no later than September 1, 2006.

Individuals who are selected as early career scientists may hold only one other early career award from a federal agency (for example, the NIH Director's New Innovator Award or the NSF CAREER Award) or comparable award from a foundation. Applicants may hold one or more grants from NIH, NSF, or other sponsors. Researchers without such grants are also eligible.

Prospective applicants must indicate intention to apply by April 30, 2008, at 2 p.m. ET, through the electronic application system on the HHMI web site.

February 29, 2008

Campus Training Resources: Workshop DVD Library

The Research Administration and Compliance Office has DVDs of the following NCURA workshops and other training material available for campus departments to borrow. To borrow a DVD, contact Alaisha Hellman (3-2836, amhellman@berkeley.edu). RAC is ordering the 2008 NCURA TV DVDs; they will be listed here when available.

NCURA TV Satellite Broadcast Recordings
  • Conflict of Interest: How to Spot and Manage It (June 2007)
  • Effort Reporting (March 2007)
  • Sponsored Program Essentials (January 2007)
  • Post-award Issues for the Pre-award and Departmental Administrator (January 2006)
  • Best Practices in Research Compliance: Update on Policies and Regulations and Implementation at Institutions (September 2005)
  • Principles of Federal Research and Development Contracting (June 2005)
Other DVDs
  • What Are We Signing Anyway (NCURA Course, December 2005)
  • Export Control Session (UC IP Managers/C&G Officers Meeting, November 2005)

February 28, 2008

Limited Submissions Announcements Moving to CALmessages

The Vice Chancellor for Research Office will be using the improved features of the recently upgraded CALmessages system to provide the campus with a better method for announcing limited submission funding programs. Using CALmessages, the VCRO will now send limited submission announcements to faculty within targeted departments and/or units based on the focus of the agency funding program or, when the program is more general, to faculty campus-wide. For example, a program funding public health research would be directed only to faculty within the School of Public Health.

Research administrators and other staff who also wish to be notified of upcoming limited submission deadlines must sign up for the Limited Submission CALmessages list at https://calmessages.berkeley.edu/subscribe (CalNet authorization required). Faculty members do not need to sign up for this list; they will receive messages automatically. Staff who sign up for the list will receive all messages, not just those specific to their department.

Limited submission programs with campus deadlines will continue to be listed at http://www.spo.berkeley.edu/Fund/limited.html. Messages will also be archived in CALmessages. For more information on CALmessages, see https://calmessages.berkeley.edu/. Questions about limited submission announcements on CALmessages may be addressed to either Shelley Sprandel (spore@berkeley.edu, 2-8122) or Jackie Jones (jackie_jones@berkeley.edu, 3-1795).

FY 2008 DoD Indirect Cost Policy

The fiscal year 2008 Department of Defense (DoD) appropriation includes a one-year limit, or cap, of 35 percent on indirect costs (i.e., facilities and administrative or F&A) of DoD-sponsored basic research. This bill capped the amount of indirect costs the prime contractor can receive under certain DoD contracts, grants, and cooperative agreements to 35 percent of Total Cost (TC). The limitation applies to an award at the prime level only and does not flow down to subcontractors.

UC Berkeley investigators and staff preparing DoD proposal budgets should continue to use the negotiated campus Facilities and Administrative (Indirect Cost) Rates of 53.5 percent for on-campus sponsored research and 26 percent for off-campus sponsored research.

Upon award, the DoD awarding agency will be responsible for any adjustments to the budget proposal. In those situations where the budget proposal included F&A costs that exceeded the cap, the agency may adjust the award. However, a university that has a negotiated F&A rate of 53.8 percent or less should not incur a loss of indirect cost recovery.

The Council on Governmental Relations provides an explanation of the math involved in determining if an institution is affected by the 35-percent limit:
Institutions that have a negotiated F&A rate of 53.8 percent, or less, will be financially unaffected (i.e., F&A can not exceed 35 cents for every $1 expended; therefore a ratio of 35 cents of F&A to 65 cents of direct costs is the conversion ratio to the “standard” F&A rate based on modified total direct costs. In situations where all direct costs on an award are F&A eligible, 53.8 percent is effectively the F&A rate cap).

Example one:
  • On a $100,000 award, $35,000 in indirect costs is the maximum allowed ($100,000 x 35%)
  • If $35,000 is the indirect cost, $65,000 is the direct cost ($100,000 - $35,000 = $65,000)
  • So, $35,000/ $65,000 = 53.846%
  • Thus, 35% Total Cost = 53.846% of Direct Costs
Example two:
  • $100,000 MTDC x 53% IDC = $53,000
  • $153,000 Total Costs
  • $153,000 x 35% = $53,550
  • $53,000 < $53,550 so full indirect cost rate can be applied
University of California Office of the President Research Administration Office guidance is available at http://www.ucop.edu/raohome/cgmemos/08-03.pdf.

DoD guidance on the limit is available at http://www.dod.mil/ddre/doc/LABS_Memo_indirect_cost_limitation.pdf.

January 29, 2008

NIH Announces Fiscal Policy for FY2008

The National Institutes of Health on Monday, January 28, announced its FY2008 fiscal policy. The policy reflects the $29.2 billion NIH appropriation for FY2008; a 1% increase over the FY2007 funding level. Highlights of the NIH fiscal policy include:

1) Non-Competing Awards. These will be funded, on average, at approximately a 98% level of the previously established commitments. Note, previously established commitments were based on a 3% inflation allowance. Since the NIH appropriation resulted in only a 1% increase, the previously established commitments had to be adjusted, accordingly.

2) Competing Awards. The average cost of competing awards will be allowed to increase by 1% over FY2007. It is estimated this will allow the ICs to support the NIH investigator pool with approximately 9,700 new and competing RPGs, and will allow the number of new investigators to be comparable to the average of the most recent five years.

3) Career Awards, SBIR/STTRs. These programs will generally be funded at the committed levels.

4) Ruth L. Kirschstein National Research Service Awards (NRSA). Funds for stipends, tuition and training-related expenses are held at the FY2007 levels.

Each IC will be required to manage its portfolio in compliance with the 1% NIH appropriation increase. However, the FY2008 fiscal policy does allow each IC more flexibility than was provided in FY2006 and FY2007 (both years also experienced sub-inflation appropriation increases). For example, individual Non-Competing Awards may be funded at a higher level, or a lower level, as long as the IC (in total) remains in compliance with its funding target (i.e., 1% increase).

Specific funding strategies for each IC will be available on February 6, 2008. In addition, institutions can contact an NIH Grants Management Specialist on questions related to specific awards.

January 18, 2008

Berkeley Coeus 4 Upgrade Complete: New Passwords for Coeus Web Accounts

The Research Administration and Compliance Information Systems team (RAC-IS) has successfully finished the upgrade to Berkeley Coeus version 4. All core components of the system (proposals, awards, subcontracts) and all associated infrastructure elements (state of the art development environment, future upgrade capability, Coeus-to-BFS feed, reporting mechanisms) have been upgraded and RAC-IS is now pleased to announce the rollout of the new Coeus Web.

The updated web service runs on new technology and infrastructure. All reports available on the old system are available on the new system. The campus Master Org Tree hierarchy has been implemented to identify organization units associated with proposals and awards. Benefits of the new system include enhanced capabilities for documenting proposal reviews, tracking agreement negotiations, managing subcontracts and subcontractors, and compliance information, among others.

New Coeus Web Passwords

Existing campus users of Coeus Web will need new passwords in order to access the new system.

UPDATE: To sign up to activate your account and receive a new Coeus Web password, to request a new account, or for more information on Berkeley Coeus Web and Coeus version 4, please contact Neil Maxwell (nmaxwell@berkeley.edu, 2-0123).

Please note that accounts established for departments are shared accounts; accounts for faculty are established for the individual faculty member.

More About the Berkeley Coeus 4 Upgrade

The Berkeley Coeus system is the institutional system of record for tracking all Berkeley campus research proposals and awards processed by the Sponsored Projects Office (SPO) and the Industry Alliances Office (IAO). Data captured in Coeus is passed automatically to the Berkeley Financial System (BFS) to establish and modify fund accounts for project spending, and is also used to provide required reports to the UC Office of the President.

The upgrade is a complete technical migration. The client application is now written in Java; upgrades from MIT will be incorporated as they are released, while at the same time preserving Berkeley customizations; the entire system runs on Campus Data Center Web Farm and database infrastructure; and all legacy data has been migrated to the new system.

The upgrade project lays the groundwork for future enhancements in a number of areas, including reporting and campus access to SPO data, conflict of interest disclosure tracking, routing and approval of proposals through the campus, and system-to-system submission of fully electronic proposals. When implemented, the new human and animal subjects protocol systems will be integrated with Coeus.

NIH Public Access Policy Now Required

The National Institutes of Health has issued Revised Policy on Enhancing Public Access to Archived Publications Resulting from NIH-Funded Research (NOT-OD-08-033). The revised policy implements Division G, Title II, Section 218 of PL 110-161 (Consolidated Appropriations Act, 2008), which states:
The Director of the National Institutes of Health shall require that all investigators funded by the NIH submit or have submitted for them to the National Library of Medicine’s PubMed Central an electronic version of their final, peer-reviewed manuscripts upon acceptance for publication, to be made publicly available no later than 12 months after the official date of publication: Provided, That the NIH shall implement the public access policy in a manner consistent with copyright law.
As of April 7, 2008, all articles arising from NIH funds must be submitted to PubMed Central upon acceptance for publication. As of May 25, 2008, NIH applications, proposals, and progress reports must include the PubMed Central reference number when citing an article that falls under the policy and is authored or co-authored by the investigator, or arose from the investigator’s NIH award. This policy includes applications submitted to NIH for the May 25, 2008 due date and subsequent due dates.

See http://PublicAccess.NIH.gov/ for more information.

January 09, 2008

Reminder: COI Materials Due Ten Days Before Committee Meeting

The faculty Conflict of Interest Committee meets monthly, except in August, to review all positive financial disclosures related to research gifts, grants, contracts, cooperative agreements, MTAs and human subjects protocols.

In order for a disclosure case to be placed on the agenda for any monthly meeting, all materials required for review must be received by Jyl Baldwin no later than ten working days prior to the published meeting date. Materials required for Committee review may include items requested specifically after initial review of positive financial disclosure packets, such as copies of consulting agreements.

The lead time of ten working days is critical for preparation and distribution of case materials to the members of the COI Committee.

January 08, 2008

Statement of Economic Interests (700-U) Form Revised

The State of California has issued a revised 700-U Statement of Economic Interest for Principal Investigators for immediate use. The revised form is available on the COI Committee web site and is the only version that will now be accepted. If you have any questions please contact Jyl Baldwin (jbaldwin@berkeley.edu, 2-8117).

State of California law requires disclosure of financial interest in the sponsor of a research project; the donor of a research gift; and, under certain circumstances, the provider of materials under a Material Transfer Agreement (MTA) when that sponsor, donor, or provider is a non-governmental source. For research projects, the Statement of Economic Interests for Principal Investigators (Form 700-U) should accompany the proposal and Proposal Review Form to the Sponsored Projects Office or to the Industry Alliances Office. For MTAs, the Form 700-U should accompany the Material Transfer Agreement Review Form to the Industry Alliances Office.

January 04, 2008

NIH Consolidates Late Submission Information; Issues New Plan for Applications from Study Section Members

The National Institutes of Health has reissued the NIH Policy on Late Submission of Grant Applications. The reissued notice consolidates information from previous late submission notices and serves as a companion to NIH Guide Notice OD-08-026, a new plan for continuous submission of certain types of applications from appointed members of NIH Study Sections.

NIH is implementing an alternate plan for submission and review of research grant applications from appointed members of chartered NIH Study Sections in order to recognize their service and to minimize disincentives to Study Section service. The timing of Study Section meetings and most standard due dates for grant applications overlap, so reviewers are under pressure to review applications and prepare their own applications simultaneously. Beginning February 5, 2008, the alternate submission and review procedures, described in the NIH Guide Notice, will be available. This alternate process is limited to 1) appointed members of chartered standing Study Sections and 2) applications that would normally be received on standard submission dates but not special receipt dates.

NIH Issues New PHS 398, 2950, and Other Forms

The National Institutes of Health has issued revised PHS 398, PHS 2590, PHS 2271, PHS 3734, and HHS 568 forms, available on the NIH Forms & Applications page. The newly revised forms are dated 11/2007.

NIH has made some notable changes to the revised PHS 398 form and instructions, including implementation of terminology used in the Grants.gov SF424 (R&R). The new PHS 398 may be used to submit grant applications beginning with the January 25, 2008 deadline and is required for applications received for May 25, 2008 and subsequent due dates. NIH is also requiring that appendix material submitted with paper PHS 398 applications on or after May 25 be submitted on CD only.

The new PHS 2590 form and instructions must be used for all progress reports received on or after March 1, 2008. The NIH Guide notice lists the notable changes.

The new PHS 2271 Statement of Appointment must be used for all trainee appointments made on or after May 1, 2008. The PHS 3734 Official Statement Relinquishing Interest and Rights in a PHS Research Grant form may be used immediately. The HHS 568 Final Invention Statement and Certification form may also be used immediately.

NIH Guide Notices