All those who hold faculty status or staff positions of Director or above may be named in leadership positions as Principal Investigator/Project Director on proposal submitted for external support. These positions include tenured or tenure-track faculty, clinical faculty, adjunct faculty with approval of the Vice President for Research and research faculty of the University at consortium hospitals and universities. Faculty and staff that hold term/temporary positions may serve as a principal investigator with the approval of the Vice President for Research and depending on the funding agency restrictions. In this case, a Fiscal Agent Form must be completed, naming a full-time permanent employee as the fiscally-responsible party.
Please notify ORSP as soon as you decide you intend to submit an application so we may assist you with the process but please notify us no later than 10 business days prior to the submission deadline. You should allow at least five business days for ORSP review and approval of your proposal. If you have compliance related components, e.g., animal subjects, human subjects, recombinant DNA, biohazardous materials, isotopes, please allow additional time because an abbreviated review by the relevant compliance committee(s) is also involved.
In order to expedite the review and approval process, the budget and proposal documentation should be in close to final form when submitted by ORSP through Kuali Research for internal review at least five (5) business days prior to the agency deadline. All proposal documentation should be finalized at least two (2) business days prior to agency deadline.
In addition to the proposal narrative and budget, the forms required for proposal applications are determined in working with your ORSP contact based on the funding opportunity:
When your proposal is assigned to an ORSP representative, s/he will review the guidelines with the investigator(s) to determine the application requirements. Proposals typically require:
- Narrative/Research Plan
- Budget and Justification
- Subaward documentation (if subs on project)
No, the Principal Investigator and other investigators must personally complete the certifications and questionnaires. This is accomplished electronically in Kuali Research using your NEOMED ID and password.
The ORSP reviews the proposal for issues such as research compliance; whether costs are allowable, allocable and reasonable; if cost sharing is committed; as well as verifying that sponsor requirements and University guidelines and objectives are being met. The approval process is structured to assure that the appropriate physical and human resources are available to execute the sponsored project successfully and that the proposed work can be carried out safely and in full compliance with federal, state and local laws/regulations. The process is also structured to resolve, in advance, questions concerning budgeting, staffing, space utilization or other priorities and to provide a written record of institutional commitments for additional space, staffing or matching funds for the project.
Although proposals for sponsored projects are developed and written by faculty and staff members, the resulting grant and contract awards are made to Northeast Ohio Medical University. Signatory approval of all University personnel in the line of authority for the project, including the Principal Investigators/Project Directors (PI/PD) and department chairs (or Dean, as appropriate) is necessary.
In addition, information concerning sponsor type, funding source and other variables are tracked by the ORSP for reporting purposes.
The ORSP needs to review only pre-proposals, notices of intent, letters of intent, or white papers that include any budget information or require approval of the Authorized Organizational Representative (AOR) before submission to the sponsor. If the pre-proposal is non-binding and does not require AOR approval, then it does not need to be submitted to the ORSP for approval before submission. We do appreciate receiving a copy for our files.
All proposals with compliance related components (animals, humans – including human cell lines or tissue, rDNA, isotopes, biohazards) must be reviewed by the appropriate compliance committee(s) prior to proposal submission. Please alert your ORSP proposal contact when such compliance matters may be involved and s/he will indicate this potential in the Kuali record and guide you to the appropriate electronic questionnaire(s).
You should first determine the total effort required to perform the proposed work on the project and then determine what portion can be supported by the grant. Any effort explicitly mentioned in the proposal but not requested in the budget from the sponsor is considered cost shared effort. Any effort committed in the proposal becomes mandatory effort if the project is funded.
No. Regardless of the number of hours you work, your total effort is 100 percent.
The University’s current fringe rates, effective 01/01/19, for budgeting are:
(federal, state, local)
Faculty- FT: 31.87%
Faculty- FT (>= 30 hr/wk): 30.81%
Faculty- PT: 15.54%
Administrative-FT (>=30 hr/wk): 30.81%
Classified- FT (>=30 hr/wk): 47.61%
Indirect Costs are those costs that are incurred by the University that are not readily assignable to a specific contract or grant. These include costs such as building and equipment use charges, utilities, library costs, security, general administration, sponsored programs administration and departmental administration.
The F&A (facilities and administrative) rate is based on an agreement with the University’s cognizant federal agency, the Department of Health and Human Services. The F&A Rate Agreement effective July 1, 2017 is 56.0% MTDC (modified total direct costs) for on-campus projects and 19.3% MTDC for off-campus projects. Reference: F&A Information.
The Modified Total Direct Cost (MTDC) is determined by subtracting the cost of equipment, tuition, fellowships and subcontract amounts over $25,000 from the total direct costs to determine the F&A base, to which the applicable rate (currently 56% MTDC) is applied.
Yes. In certain cases, sponsors may provide either no facilities or administrative overhead reimbursement or only a fraction of what the University’s negotiated agreement for indirect costs allows. It is important to determine the percentage of indirect costs permitted by the sponsor and to apply it to your budget. The difference between what the sponsor is willing to provide and what the costs the University incurs based on our federally-negotiated rate is considered “cost-sharing.” Before a proposal is submitted, cost-sharing must be approved by the Vice President for Research as the University must understand its financial obligations toward the project. If the sponsor includes information in its guidelines concerning the payment of indirect costs, please include a copy of this documentation with your proposal routing materials as this will speed up the review process.
The appropriate indirect cost rate to apply is determined by where the preponderance of project work is to be done. If, for example, 51% or more of the work plan is undertaken on campus, then the on-campus rate should be used. Conducting fieldwork does not qualify to the off-campus rate. Using off-campus facilities for short-term project-related activity does not qualify for the off-campus rate. Utilizing the on- and off-campus rates for different line items within the same project budget is not permitted per the federal Office of Management and Budget (see Uniform Guidance 2 CFR 200, Cost Principles for Educational Institutions). Thus, there can be no “blended” rates.
Cost share represents that portion of the total project costs (direct or indirect) of a sponsored agreement borne by the University, rather than by the sponsor.
Cost sharing should be limited to only those situations where it is mandated by a sponsor or where a Principal Investigator has determined that such a contribution is necessary to ensure the success of a competitive award or proposal. When cost sharing or matching is required by the sponsoring agency or volunteered by the university, it becomes a commitment of the university. Details and approval of the cost share must be documented through the internal approval process.
Cost sharing that is required by some sponsors is called mandatory cost sharing. Cost sharing included in proposals that is not required by the sponsor is referred to as voluntary cost sharing. Once cost sharing has been included in a proposal and that proposal has been accepted by the sponsor, the University has an obligation to provide the cost sharing proposed, regardless of whether it was mandatory or voluntary.
Yes. Although NIH has adopted the modular budget format for budgets of $250,000 per year and less, the University, as do many universities, requires a detailed itemized budget for internal purposes. Under Cost Accounting Standards (CAS), the burden is on the University to apply costs consistently. Without a detailed budget, ORSP does not have any way to assure costs are in general compliance with CAS.
The University defines “equipment” as any tangible, nonexpendable property having: (1) a useful life of more than one year and, (2) an acquisition cost of $5,000 or more per unit. Items not meeting these two conditions are not to be classified as and placed in, the equipment category.
Office supplies (pens, paper, notebooks, clips, stamps, envelopes, ink cartridges/copying toner, local telephone service, etc.) are those costs that are incurred for a “common or joint objective” of the University and, therefore, cannot be identified readily and specifically with a particular sponsored project. While one can easily recognize that a printer cartridge might be “needed” for a research project, we don’t want to have to set up an accounting system to track all of the department’s printer cartridge inventory in order to direct cost them to all the various accounts/projects on which they are used. So, although it is possible to practically direct charge any cost to a project, the accounting system that would be required and the staff effort to ensure each unit of these various costs are properly distributed makes it an unrealistic and inefficient way of handling such costs. We, therefore, recover these costs through the indirect cost reimbursement process. There are exceptions to the general rule. A major project requiring a full time clerical employee could possibly be an extraordinary circumstance, thus justifying the direct costing of clerical salaries.
Congressional District: OH-016
State Legislative Districts
Ohio House of Representatives: 75
Ohio Senate: 28
Under the Department of Health and Human Services (DHHS) human subjects protection regulations (at 45 C.F.R. 46.103), every institution engaged in human subject’s research funded or conducted by DHHS must obtain an Assurance Of Compliance approved by the Office for Human Research Protections (OHRP). Both “awardee” institutions and collaborating “performance site” institutions must file assurances.
NEOMED’s number is FWA00000027.
In general, grants carry obligations for reporting of either technical or financial activity to the sponsor and require separate, auditable accounting.
Usually, a grant:
- Is intended to support a project with a specific set of objectives.
- Requires a formal written proposal that indicates total project costs.
- Requires periodic written reports of a descriptive, technical and/or financial nature.
- Must be budgeted and accounted for separately from other awards.
- Must be applied for and awarded through the ORSP to assure compliance with University and agency policies.
And a gift:
- Normally requires no formal proposal and no reporting of a descriptive, technical, or financial nature.
- Is made and accepted without consideration of project costs, but rather as project or institutional support.
- Can be combined with gifts of a similar nature for similar purposes and does not need separate accounts or budgets.
May be for a specific project or unrestricted institutional purposes.
Applications that can only be awarded to 501(c)(3) organizations are submitted by the NEOMED Foundation on behalf of the University. However, the proposals are first reviewed by the ORSP, so please follow the standard proposal submission process. Documents related to the NEOMED Foundation required by most sponsors, such as the IRA letter of determination, can be found through the NEOMED Intranet.
In many cases, as a result of the imposition of the Cost Accounting Standards (CAS), federal sponsors no longer perform in-depth reviews of proposal budgets. Under CAS, the federal agencies expect the applicant to be familiar with the Cost Principles and to exclude non-allowed costs from those budgets. As a result, Universities cannot depend on the “rationalization” that since the sponsor did not remove it from the awarded budget that, in fact, the sponsor has “approved” that cost item. In order to position your argument along that line, at a minimum the proposal’s budget should include a separate page titled “Budget Justification” in which those non-routine or normally non-allowed expenses are identified and justified for the project – the ORSP initially must make the judgment call based upon the circumstances of the PI’s justification.
A postdoctoral associate who works on a research project is considered an employee of the University. As such, his or her salary is subject to the full fringe benefits rate.
Key personnel are individuals who contribute in a substantive way to the scientific development or execution of the project, whether or not salaries are requested. This role should be determined by the Principal Investigator.
Post Award Process
You should immediately notify the Office of Research and Sponsored Programs (ORSP) and forward the document to the ORSP. Sometimes awards are sent to the ORSP as well as the Principal Investigator, but occasionally the sponsor only notifies the Principal Investigator. All awards must be reviewed and approved by the Vice President for Research or his designee.
The Vice President for Research, Steven Schmidt, Ph.D., or his designee in the ORSP, Rebecca L. Hayes, Executive Director.
After an award or contract/subcontract has been accepted by the University Authorized Organizational Representative (AOR) and all other documents are finalized, the ORSP sends the documents to Grants Accounting. Grants Accounting personnel set up a restricted index in the University accounting system to which project expenses will be charged. After the index is established, the ORSP will notify you of your index number via email.
The Principal Investigator has primary responsibility for achieving the technical success of the project, while also complying with the financial and administrative policies and regulations associated with the award. Although a Principal Investigator may have administrative staff to assist him or her with the management of project funds, the ultimate responsibility for the management of the sponsored research award rests with the Principal Investigator.
The Principal Investigator:
- Executes the project as outlines in the funded proposal, using sound management techniques
- Attests to the allowability and reasonableness of all expenditures
- Monitors and ensures the integrity of any collaborative relationships
- Initiates and approves subcontract agreements and payments
- Implements the project’s financial plan as presented in the funded proposal, or makes changes to the plan following a prescribed set of policies and procedures
- Assists in the process of documenting cost sharing/matching costs
- Is responsible for the completion, accuracy and timeliness of all technical reports as outlined in the terms of the award
- Complies with all University policies and procedures related to project management and personnel practices
Please email Becky Hayes in the ORSP at email@example.com to request that a subcontract/subaward be prepared for your project. Note that the subcontract must be ALLOWED by the sponsor on the grant, i.e., must already be in the scope of work and budget approved by the sponsor. If it is not, specific approval from the sponsor must be sought. The information you will need to provide for each subcontract requested includes:
- The award for which the subaward is requested, including the title and index number
- Full legal name and address of the subawardee entity
- Names of the PI/PD for NEOMED and subawardee (the “PI/PD” — NEOMED’s must be our official PI/PD)
- The Scope of Work for the subawardee (in enough detail so that both institutions can judge whether or not the SOW has been completed at the end of the performance period)
- Subawardee Period of Performance (cannot be earlier or beyond the prime award budget period or cross over to NEOMED’s prior fiscal year)
- Amount to be given to subawardee (funds must be available in your budget in the subcontract line) and detailed budget.
- Standard payment terms include cost reimbursement and invoicing no more often than monthly (sometimes I use quarterly). If you wish to request anything different, you need to include that information and we can discuss the options. We do NOT “prepay” (except under extraordinary circumstances)
- Programmatic reporting requirements (We will require a programmatic report as a condition of paying the invoice.)
- Contact information for the Administrative, Fiscal and Technical (programmatic) people, with address, email and phone number (if available).
- Any special terms and conditions of the subaward
- Note that if our award is federal, we would also need the organization’s DUNS and confirmation they are registered SAM.gov. This requirement should be discussed with the subawardee prior to committing funds to them.
You will be asked to approve all invoices for subcontracts on your award. The reason for this is that the Principal Investigator is assumed to have knowledge of the progress of each of their subcontractors and, therefore, is in the best position to know whether an invoice appears reasonable given the progress of the research at that time. After approving the invoice, forward it to Grants Accounting.
Contact Grants Accounting for assistance in determining funding agency rules regarding budget changes. If the rebudget would allow a change in personnel effort, a Prior Approval form may be required in addition to the Grant Budget Reallocation Form, available through DOCS. If prior approval from the sponsor is required, Grants Accounting will contact the sponsor for permission. A change in personnel effort may require prior approval of departmental chair and/or dean.
Grants Accounting will prepare any invoices and/or financial reports that a sponsor requires.
If a grant period is scheduled to expire and the Principal Investigator has not finished the proposed objectives, a no-cost extension may be an option. Many sponsors allow a first time 12-month extension without sponsor approval. Other sponsors require a formal written request to review. Forward a Prior Approval form to ORSP prior to the end of the award requesting the no cost extension.
Please notify the ORSP if you: (1) withdraw from the project entirely; (2) anticipate being absent from the project during any continuous period of 3 months or more; (3) are substituted with an alternate individual; or (4) intend to reduce effort commitment by 25% or more. This rule applies to a budget period, not a single quarter.
Please email Rebecca Hayes in the ORSP at firstname.lastname@example.org to request that a consulting agreement be prepared. Note that the consulting agreement must be ALLOWED by the sponsor on the grant and generally must already be in the scope of work and budget approved by the sponsor. The PI should provide the following for each consulting agreement:
- Award for which the consulting agreement is requested, including the title and index number
- Full legal name and address of the consultant AND email address (we email the draft of the agreement, so they can request changes or make corrections).
- The Scope of Work for the consultant, in enough detail so that NEOMED and you can judge whether or not the invoices are appropriate
- Period of performance (cannot be earlier or beyond the prime award or cross over to the prior fiscal year) – start date and end date
- Amount to be given to consultant (the maximum amount) and hourly rate (sufficient funds must be available in your budget in the consulting line). In some circumstances, a daily rate might be used.
- Standard terms include invoicing no more often than monthly (sometimes I use quarterly). We do NOT “prepay”
- Programmatic reporting or product requirements (we will typically require a programmatic report as a condition of paying the invoice)
- Any special terms and conditions that need to be included
Please make sure the information is accurate. We will email the agreement to the email you provide. Note that if the Consultant has not worked with NEOMED before, he/she must provide a Personal W-9 New Hire form, W9 form, and OPERS Independent Contractor Acknowledgement form before Grants Accounting can establish the Purchase Order. ORSP will send these forms along with the draft agreement, if required. Let us know if you have any questions.
A collaboration between Sheila Fleming, Ph.D., and a colleague at Michigan State University to research the effect of exercise in […]