Composite Fringe Benefit Rate Update

The composite fringe benefit rates for fiscal year 2016-17 have been approved. Projected rates (FY18-FY22), which are estimates for planning purposes, have also been posted on the SPO website.

New Process for Some Subrecipients: UCB Participating in FDP Pilot

UC Berkeley is now participating in a pilot test of a new way of processing subawards being conducted by the Federal Demonstration Partnership (FDP). The goal is to reduce the amount of time and effort that organizations like UC Berkeley spend collecting institutional information from each other.

What this means to campus is that beginning August 18, 2016, UC Berkeley will have two sets of requirements for subrecipients listed in Berkeley proposals:

1. Any subrecipient that is participating in the FDP pilot will only need to complete a one-page form, the FDP Pilot Subrecipient Project Information sheet.
2. All other subrecipients will be required to provide a longer form, the Subrecipient Commitment Form (Non-FDP Pilot Institutions).

Both documents can be found under Forms on the SPO website.

The FDP pilot group now includes approximately 78 institutions and organizations across the nation. See FDP Expanded Clearinghouse - Subrecipients for a link to the list of entities that will be participating in the pilot. Institutional information for each entity participating in the FDP pilot will be maintained on the FDP website so it will no longer be necessary to collect this type of information on a subrecipient commitment form.

The pilot test will last 18 months. If results of the pilot are positive, the plan is to allow other FDP institutions to participate.

CSS and Department administrators are encouraged to become familiar with the names of the entities participating in the FDP pilot to ensure that these entities receive the proper form when requesting subrecipient information. Note that only groups participating in the FDP pilot should be asked to fill out the FDP Pilot Subrecipient Project Information sheet.

---

August 5, 2016 Research Advocate: Upcoming: New Process for Some Subrecipients

NIH Changing Allowed Appendix and Post-Submission Application Material

The National Institutes of Health issued two NIH Guide notices related to changes in materials allowed for applications submitted on or after January 25, 2017.

New Policy Eliminates Most Appendix Material for NIH/AHRQ/NIOSH Applications Submitted for Due Dates On or After January 25, 2017 (NOT-OD-16-129)

This Notice alerts the scientific research community of plans to eliminate most appendix materials for applications submitted to the NIH, AHRQ or NIOSH for due dates on or after January 25, 2017. Application instructions will be updated by November 25, 2016 to reflect this change.

 The Notice also clarifies:

• Status of appendix materials in peer review
•  Allowable appendix materials
•  Consequences for submitting disallowed appendix materials

Changes to the NIH/AHRQ/NIOSH Policy on Post-Submission Materials for Applications Submitted for Due Dates On or After January 25, 2017 (NOT-OD-16-130)

This Notice simplifies and consolidates current NIH and AHRQ policy concerning post-submission materials, and extends this policy to NIOSH. Post-submission application materials are those submitted after submission of the grant application but prior to the initial peer review. The policy is based on the principle that, for the majority of applications, the only post-submission materials that these agencies will accept are those resulting from an unforeseen event. The policy on post-submission application materials is not intended to correct oversights/errors discovered after submission of the application.

NIH Announces Projected FY 2017 NRSA Stipend Levels

The National Institutes of Health has published projected stipend levels for fiscal year 2017 for postdoctoral trainees and fellows on Ruth L. Kirschstein National Research Service Awards (NRSA).

The projected stipend levels, planned to be effective December 1, 2016, align with the “spirit” of the U.S. Department of Labor revisions to the rules on paid overtime under the Fair Labor Standards Act (FLSA). NIH states that the “exact stipend levels and the actual date of implementation are subject to the availability of FY 2017 appropriations and implementation of the new FLSA threshold for professional workers to be eligible for paid overtime.”

For the chart of projected stipends and more information, see Projected FY 2017 Stipend Levels for Postdoctoral Trainees and Fellows on Ruth L. Kirschstein National Research Service Awards (NRSA) (NOT-OD-16-131) (rescinded).

August 10, 2016 update (corrected effective date):  Revised: Projected FY 2017 Stipend Levels for Postdoctoral Trainees and Fellows on Ruth L. Kirschstein National Research Service Awards (NRSA) (NOT-OD-16-134)

Upcoming: New Process for Some Subrecipients

UC Berkeley will be participating in a pilot test of a new way of processing subawards being conducted by the Federal Demonstration Partnership (FDP). The FDP pilot is scheduled to begin in mid-August; the exact date has not yet been released.

What this means to campus is that after the FDP pilot starts, UC Berkeley will have two sets of requirements for subrecipients listed in Berkeley proposals:

1. Any subrecipient that is participating in the FDP pilot will only need to complete a one-page form and provide project-related information at the proposal stage.
2. All other subrecipients will be required to provide both project-related and institutional information using SPO’s Subrecipient Commitment Form.

The pilot group will include approximately 90 institutions of higher education across the nation, and the pilot test will last 18 months. If results of the pilot are positive, the plan is to allow other FDP institutions to participate.

SPO is developing new procedures for the pilot test, which will be announced to the campus as soon as the pilot start date is known. SPO also will post the list of subrecipients participating in the pilot test as soon as this information is released by the FDP.

NSF Implementation of Overtime Rule FAQs

The National Science Foundation Policy Office has published Frequently Asked Questions on the Fair Labor Standards Act overtime rule and has sent out the following notification.

The Department of Labor recently announced the Fair Labor Standards Act (FLSA) final over time rule. The FLSA final overtime rule automatically extends overtime pay protections to millions of workers and could impact some personnel on NSF grants, including postdoctoral researchers. The National Science Foundation continues to acknowledge the important role of postdoctoral researchers on NSF-funded projects, and, in general, NSF postdoctoral programs already include a stipend or salary in excess of the new minimum established by the FLSA final overtime rule.

Since the announcement of the new rule, NSF has received many questions on how this rule will affect NSF-funded projects. NSF has created a set of Frequently Asked Questions in order to address these questions. The FAQs are posted on the NSF Policy Office website at http://www.nsf.gov/bfa/dias/policy/faqs/flsa_faqs.pdf.

Reminder on PHS Regulation to Disclose New Significant Financial Interests in 30 Days

A reminder from the Conflict of Interest Coordinator:

The Public Health Service (including National Institutes of Health) regulations require that when new Significant Financial Interests are acquired or discovered by an Investigator, they must be disclosed within thirty (30) days of that acquisition or discovery. When this is not done in a timely manner, the institution is not in compliance with the regulations and must perform a mandated special retrospective review which causes delays in the ability of the Committee to approve ongoing projects. This is an onerous process and falls on the faculty Conflict of Interest Committee and the COI office to handle.

Please direct any questions to Jyl Baldwin, COI Coordinator, at jbaldwin@berkeley.edu or researchcoi@berkeley.edu.

Compliance Information Form for Research Gifts No Longer Required

Effective immediately, the Compliance Information Form for Research Gifts has been discontinued and is no longer required with the Form 700-U (Principal Investigator Statement of Financial Interests) when research gifts are received. The form has been removed from the COI and SPO websites. Please direct any questions to Jyl Baldwin, COI Coordinator, at jbaldwin@berkeley.edu or researchcoi@berkeley.edu.

NSF FastLane: New Automated Proposal Submission Compliance Checks

The National Science Foundation has issued a notice that effective July 25, 2016, all proposals will be subject to a new series of automated compliance validation checks to ensure proposals comply with requirements outlined in Chapter II.C.2. of the Proposal and Award Policies and Procedures Guide (PAPPG).

The new set of automated compliance checks will trigger warning or error messages depending on the funding opportunity type for each of the following rules:

• Biographical Sketch(es) and Current and Pending Support files are required for each Senior Personnel associated with a proposal.
• Biographical Sketch(es) can only be uploaded as a file, must not exceed two pages and can no longer be entered as text.

Proposers should be aware that if a proposal was previously submitted successfully with only one Biographical Sketch and/or Current & Pending Support file (rather than individual files for each senior personnel), a Proposal File Update performed on such proposals will be prevented from submission if it does not comply with the new compliance checks.

Proposers submitting through Grants.gov should be aware that Grants.gov will allow a proposal to be submitted, even if it does not comply with these proposal preparation requirements. Should NSF receive a proposal from Grants.gov that is not compliant, it may be returned without review.

For additional information see:
FastLane Advisory: Attention Proposers: New Automated Proposal Submission Compliance Checks Coming to FastLane
Research.gov: Attention Proposers: New Automated Proposal Submission Compliance Checks Coming to FastLane

---

July 26, 2016 update: NSF has notified the community that “this implementation was rescheduled due to a power outage which caused all servers to shut down. The new automated proposal submission compliance checks will be available on August 1.”

NIH SF424 and R&R Forms: Continue to Use Despite Expiration Dates

The National Institutes of Health has published OMB Approval for SF424 R&R Forms Used Federal-wide Underway - Continue to Use Current Forms Until Further Notice (NOT-OD-16-120) in the NIH Guide. From the notice:

NIH and AHRQ grant application form packages include both agency-specific forms (typically labeled PHS) and federal-wide forms (typically labeled Research & Related or R&R). Although our agency-specific forms were recently approved for use through October 31, 2018 (FORMS-D, NOT-OD-16-004), the forms used federal-wide are on different clearance cycles and have recently expired or will expire soon.

Applicants and grantees should continue to use the application form packages (FORMS-D) posted with our funding opportunity announcements despite the expiration dates noted on each form.

Grants.gov is working with the Office of Management and Budget (OMB) on the federal-wide form clearance and expects OMB approval for proposed form changes later this summer.

Second Part of Report on Federal Research Regulations Issued

The National Academies of Sciences, Engineering, and Medicine has released Part 2 of the report Optimizing the Nation’s Investment in Academic Research: A New Regulatory Framework for the 21st Century.

The report, issued on June 29, 2016 by the Committee on Federal Research Regulations and Reporting Requirements, contains the full contents of Part 1, first released in September 2015 as a separate publication.

The report “reviews the federal regulatory framework for research institutions as it currently exists, considers specific regulations that have placed undue and often unanticipated burdens on the research enterprise, and reassesses the process by which these regulations are created, reviewed, and retired. It identifies specific actions Congress, the White House, federal agencies, and research institutions should take to reduce regulatory burden.”

June 30, 2016 update: The Council on Governmental Relations (COGR), Association of American Universities (AAU), and Association of Public and Land-grant Universities (APLU) have released a joint statement on the report, related to shared concerns regarding the recent Common Rule Notice of Proposed Rulemaking (NPRM) for the treatment of human subjects in research. COGR plans to issue a full analysis in the coming weeks.

---

September 23, 2015 Research Advocate: New Report on Regulation of Federally Funded Research

NSF Award Terms and Conditions Revised

The National Science Foundation Policy Office in the Division of Institution and Award Support has announced that the NSF Award Terms and Conditions have been revised to implement the requirements stipulated in Appendix XII to Part 200 of 2 CFR § 200 (Uniform Guidance) regarding the Federal Awardee Performance and Integrity Information System (FAPIIS), as well as other clarifications to the conditions.

The revised Terms and Conditions will apply to all new NSF awards and funding amendments to existing NSF awards issued on or after July 1, 2016.

Revisions have been made to the following:

• Grant General Conditions (GC-1);
• Cooperative Agreement Conditions:
  • Cooperative Agreement Financial and Administrative Terms and Conditions (CA-FATC),
  • Cooperative Agreement Supplemental Financial and Administrative Terms and Conditions for Managers of Large Facilities,
  • Cooperative Agreement Supplemental Financial and Administrative Terms and Conditions for Managers of Federally Funded Research and Development Centers (FFRDCS);
• Special Conditions:
  • International Research Terms and Conditions,
  • Small Business Innovation Research (SBIR)/Small Business Technology Transfer (STTR) Phase I Grant General Conditions,
  • Small Business Innovation Research (SBIR)/Small Business Technology Transfer (STTR) Phase II Grant General Conditions, and
  • Administration of NSF Conference or Group Travel Grant Special Conditions (FL 26).

PIs Can Now Request Early Review of NIH COI Disclosures

The current process for review of complete positive financial disclosures for new National Institutes of Health proposals by the Conflict of Interest (COI) Committee has been to conduct that review at the time a Just-In-Time (JIT) request arrives from NIH. As JIT is generally some indication that the project may be funded, review at this juncture alleviated some of the burden on the COI Committee for review of all NIH positive disclosures at the proposal stage, when a significant percentage of those proposals are not funded. For funders that do not have an equivalent JIT process (e.g., NSF) review of complete disclosures has always been conducted right after the proposal is submitted. However, beginning on June 20, the COI Committee will conduct early review for new NIH projects with complete positive financial disclosures, at the request of the Principal Investigator. Any request for early review should be sent to researchcoi@berkeley.edu.

New COI Review and Approval Process

On June 1, the COI Committee began a new review and approval process for all complete non-substantive PHS (specifically including those which are unchanged or unrelated) and NSF financial disclosures, and for State 700-U disclosures that meet certain specified expedited review criteria. All such disclosures are now reviewed and approved on a rolling weekly basis, leaving the monthly COI Committee meeting for deliberation of more complex and/or complicated cases.

This new process will allow the Sponsored Projects Office to set-up many awards more quickly, and Donor and Gift Services to more quickly make gift funds available.

Approval letters will be issued via email from the COI office every Monday or Tuesday. In all cases, the COI office will copy the CSS RA identified with the individual who filed the disclosure, unless another contact is identified.

Please address any questions to COI Coordinator Jyl Baldwin at jbaldwin@berkeley.edu or researchcoi.berkeley.edu.

NIH Fellowship Application Problem

Today, June 10, 2016, the National Institutes of Health informed the research community that there is a temporary issue with the application form packages associated with the fellowship funding opportunity announcements listed in the NIH Guide Notice Form Correction Made for All NIH Fellowship Opportunities (NOT-OD-16-106).

The application forms packages posted with these opportunities on June 3, 2016 included an incorrect version of the PHS Fellowship Supplemental Form. This posting error was corrected the evening of June 7, 2016.

Anyone who started a grant application for any of these opportunities prior to June 8, 2016 must return to the funding opportunity announcement and begin again.

The ASSIST system recognized the posting issue and prevented users from initiating an application with the incorrect form package. If you attempted to initiate an application prior to June 8 and received an error, you can now safely initiate your application.