Last update: February 2, 2015
Changes in Federal Regulations Governing Grants: Subawards
Shortly before the winter break, the Office of Grants and Contracts Accounting sent out an email referencing changes to the federal regulations governing grants that went into effect on December 26, 2014. The vast majority of these concern accounting procedures, systems and policies institutions need to have in place in order to receive grants, etc. As the College reviews and implements these new regulations, we will be sending out emails explaining how specific changes affect them. One big set of changes in the regs involve our oversight of subawards. OSP has implemented changes to accommodate the new regs in order create minimal impact on researchers. Here's what you need to know:
1) When we're putting together a grant budget, we may need to ask some additional questions to ensure third parties are classified properly as either subawardees or vendors.
Click here to review the criteria
2) OSP Staff will be more vigilant in getting the name of an administrative contact in the Sponsored Program Office at your collaborator's institution during the proposal routing process.
In addition to the budget, scope of work and letter of commitment we still require from collaborators prior to submission, TC, along with all other universities that receive grant funding, will need collaborating institutions to fill out a detailed questionnaire
about their financial systems, certain policies and funding history. This contact information has always been requested. We now require it so we can work in the background with your collaborator's administrative offices while you're completing the programmatic parts of the proposal. If an award results from the proposal, the information on the questionnaire may require OSP to follow up with additional questions and to include additional terms and conditions
in the resulting subaward agreement.
3) As always, during the course of the project, investigators are required to approve payment of all invoices from subawardees and to notify OSP immediately if there are significant/unexplained delays getting work product from the collaborator, if the work received is fails to meet the requirements of the prime grant award and/or the terms of the subaward, or if the scope of work changes.
The recent staffing changes in the Office of Sponsored Programs have allowed us to reconfigure and expand the services we now offer to the community, as part of our ongoing efforts to increase efficiency and compliance and to reduce paperwork. We are please to announce the following three new initiatives:
1. The Banner Request Form (BRF) (The BRF replaces the older Funded Authorization form created when a new grant is awarded to the College)
Upon receipt of an award letter, the Sponsored Project Administrator (SPA) for your department/center populates this form with basic budget, project period, program contact information, due dates for interim reports, deliverables, etc. Once the form is filled out, the SPA sends it to the PI, who returns it to their SPA via their own TC email address to accept the terms and conditions and to request that a new account be established in Banner for the award.
The BRF, for the first time, also incorporates key information about IRB approval and renewal dates, as well as information about other areas of compliance and program management for which the PI has primary responsibility. This single document, we hope, should become a single reference source for the conduct and management of all grants run through OSP at the college.
The Principal Investigator (PI) is required to review the document and 'sign off' accepting the Terms and Conditions pertaining to their new grant award before an index is issued.
Once the form is completed, the SPA will forward it to the (PI) for review and acceptance of the terms and conditions. The BRF form will need to be returned to their assigned SPA via the PI's own TC email address* to accept the terms and conditions and to request that a new account index be established in Banner for the award.
Effective immediately, the SPAs in the Office of Sponsored Programs will now directly provide the Banner Index Numbers to projects via the BRF. The Office of Grants and Contracts Accounting will no longer be the point of contact for index numbers.
*For verification, the BRF acceptance of grant terms and conditions must come directly from the Principal Investigator's email address, not DAA or budget administrators
2. New Award Start-Up
Once your Banner Index has been created, your SPA will be returning to you a modified version of the budget you created at submission time. The budget will be updated to reflect the approved budget in the award letter.
Starting Up (Year 1) Expenses
Next to each line item, you will be asked to confirm the dollar amount, given the opportunity to make changes and asked for approval to initiate actions such as issuing subcontracts, ICA agreements and personnel actions as appropriate. We hope this prompt at the beginning of the project help to get personnel on the payroll/positions posted in a more timely fashion and to cut down on some of the time it gets to execute contracts. Through the Spring and Summer, OSP will be looking opportunities to use this new start up process to eliminate some older forms such as the Subcontract Request Form.
3. Mentor IRB System for fully electronic protocol submission
OSP is extremely pleased to announce the purchase of Mentor IRB Human Subjects Protocol Management System. Mentor IRB will completely eliminate the need for physical signatures and hard copies. The system also allows PIs to check the status of their application online, print out approval letters, and stamped consent forms. Continuing review reminders are now fully automated, as are many of the review and administrative functions for IRB staff and committee members. In selecting Mentor, we were mindful of the fact that many of our IRB applicants are doctoral students who will only use the system for a single protocol, so it is extremely user friendly. The new online application form will be very similar to the one that has been in use for the last 7 years, optimized to take advantage of Mentor's database capabilities. Mentor also allows for single sign in with TC credentials via the Portal.
We will announce a test/training site and release basic training materials by May 1. Mentor will be ready to receive new protocols by June 1, leaving the relatively quiet summer months for us to refine both the system and the training materials before the start of the 2014-15 academic year.
Looking forward, Axiom Education, the developers of Mentor IRB, has also given TC free access to their new grant module during the first year of the contract. We hope to be able to pilot a new fully electronic internal proposal routing system sometime in the Fall.
, Research Compliance Manager. Sarah's primary role at the College is to serve as staff to the TC IRB , to maintain its records and to ensure its policies and procedures are enforced. Sarah may also be reached at 212/678-4105. As of June 4, 2013, the IRB office is located in Room 407D Russell Hall.
Natasha Guadalupe, Assistant Director of Client Services, 212-678-8199. In addition to her duties as Assistant Director, Natasha will still provide SPA services for the following Departments and Centers:
CPRE, CCF, ITS, NCREST, Office of School & Community Partnership, Office of International Affairs, Provost's Office.,
Eileen Hawley Nigro, Senior Sponsored Project Administrator, 212-678-8148 (email@example.com):
Accelerated Schools, Cahn Fellows,CPET, CTSC, CCRC, Financial Aid, Hechinger, Huber, HD, ILT, IUME, Klingenstein, Library, MST. ORL, Summer Principals Academy.
Sponsored Project Administrator, 212-678-4187.
NSF is currently implementing a significant change in the way Principal Investigators (PIs) (and Co-PIs) report on their NSF-funded projects. PIs will be required to submit their annual, final and interim project reports in Research.gov, NSF's modernization of Fastlane.
What does this mean for you as PI?
> Everyone who is currently registered in Fastlane can log on to Research.gov with the same login. If hyou do not remember your Fastlane User ID/Password, please contact your SPA for resetting.
> The Interface has changed for your reporting, however the actual content on the interim and final reports remain the same.
As of January 14,2013, the following changes have been made for all NSF grant submissions:
See NSF Grant Proposal Guide (GPG) for details
Fastlane has been modified to display three separate text boxes in which proposers must provide an overview and address the 'Intellectual Merit' and 'Broader Impacts' of the proposed activity. Proposals that do not separately address the overview and both merit review criteria within the one-page Project Summary will not be accepted or will be returned without review.
The Project Description must now contain, as a separate section within the narrative, a discussion of the broader impacts of the proposed activities. This section also was updated to indicate that the Intellectual Merit and Broader Impact activities must be described in two separate sections in the summary of Results from Prior NSF Support.
on the Bio-Sketch format. Products may include, but are not limited to, publications, data sets, software, patents, and copyrights. products, whether or not related to the proposed project. Acceptable products must be citable and accessible including but not limited to publications, data sets, software, patents, and copyrights. Unacceptable products are unpublished documents not yet submitted for publication, invited lectures, and additional lists of products.
Letter of Commitment
Ensure that any letter you provide to a prime institution or receive from your subcontractor is one of commitment not
a general letter of support (Unless the solicitation indicates this is permitted).
Proposers should describe only those resources that are directly applicable. Proposers should include an aggregated description of the resources that the organization will provide to the project, should it be funded. Such information must be provided in this section, in lieu of other parts of the proposal (e.g., budget justification, project description). The description should be narrative in nature and must not include any quantifiable financial information.
If a principal investigator will receive no salary from a grant, the investigator's name should not appear in the proposal's budget. Rather, the investigator's contribution to the project should be discussed in the facilities form. (The investigator's name can also appear on the cover sheet.) Don't attach a dollar figure to anything discussed in the facilities section. Detailed financial information could be interpreted as voluntary cost sharing, which is not permitted in NSF grants. If for some reason you have no facilities, equipment, or resources to describe, write a brief statement to that effect on the form.
- GRANT SUBMISSION REMINDER: For all electronic submissions, OSP requires the ENTIRE, COMPLETE Proposal with all components, including the project narrative, no later than 12 noon the day before the due date in order to check for compliance with the RFP, sponsor guidelines, and to resolve any system errors that may occur. OSP cannot ensure your proposal will be submitted successfully if these internal deadlines are not observed.
- NEW RESOURCES: Anyone who has applied to NSF or NIH in recent years may have noticed that the full set of guidelines for proposal submissions can be spread out over several different sources: The general agency grant policy guidelines, the Grants.gov, NIH Commons, NSF Fastlane submission portals and the request for proposals itself. In order to consolidate this information into a single reference guide, our SPA's have created the NIH Grant Proposal Checklist and the NSF Grant Proposal Checklist. They are most useful to read side by side with the full application package to define terms and help to make out your work at the beginning of the proposal development process to map out the work ahead. If you notify your SPA at least two weeks prior to your submission deadline of your intent to apply, they can customize the checklist to include RFP-specific elements.
- NEW SECTION: Periodic Progress Reporting to our federal sponsors has become more complex in recent years as well, so we have created a new section, PROGRESS REPORTING GUIDANCE (see link on menu), to assist PIs in submitting annual progress reports electronically to NIH, NSF and USED.
- Effective for the 2011-12 Academic Year, the principal investigator share of net Indirect Cost Recovery sharing increases from 3% to 4%.
- NIH has recently capped the annual cost of living increase in grant budgets to 2% per year. We will be making sure this new requirement has been met when we prepare and review budgets. Please note that larger annual cost of living increases may be charge to a grant if there are funds available. The new policy only effects new grant applications, not current projects.
- In January 2010, the National Science Foundation instituted a requirement that all students, graduate students and postdoctoral fellows paid on its grants must undergo training in the Responsible Conduct of Research (RCR). TC students and postdocs on NSF grants may satisfy the RCR via the CITI Training Program at citiprogram.org, the same website that provides our IRB training. Just follow the link, select Teachers College from the list of participating institutions, log on with your UNI and select either the RCR training for Social and Behavior Sciences or for Biomedical Sciences as appropriate. Once you complete the training, print or save the certificate of completion. You will need to show this certificate before OSP can place you on the payroll.
1. As of 1/1/08, the college has codified specific types of support for graduate students:
- Doctoral Research Fellowships: Includes a stipend of between $20-24K per year, with 12 credits tuition charged to the grant, matched by the college
- Graduate Assistant: Works no more than 20 hours a week and earns no less than $4000 per semester up to $19,999 per academic year.. Eligible for 6 points tuition waiver during the Academic Year only.
Part time hourly and part time professional lines may also be used to support graduate students.
2. The IRS sets rules as to who may be paid as a consultant. The determination as to whether a particular individual can be paid as a consultant or must be paid as an employee is made just prior to the start of work. There are no sponsor rules requiring that a given individual working on a project must be paid as a consultant; if an individual is determined to be an employee prior to hiring, that individual must be paid as an employee, with associated fringe benefit and indirect cost rate charges, regardless of how funds are budgeted in the grant.
Noncompliance in this area can lead to severe IRS penalties, so the Offices of the General Counsel, Purchasing and Payroll are extremely diligent in ensuring compliance with all applicable regulations.
3. The reference librarians have all been trained in the use of SPIN and the Foundation Center websites and are available to assist all TC faculty and students in searching for funding opportunities for research and other projects.