1. SUBMITTING PROPOSALS AFTER LEGAL CLOSE If you plan to collaborate with VUMC investigators, you will need to include a VUMC proposal for an outgoing billing agreement or subcontract. If VUMC plans to include a VU investigator, the VU investigator will need to route a proposal for an incoming billing agreement or subcontract.

2. Use of Subcontract/Subaward Relationship Purpose: A subcontract is required when a research project is carried out by the recipient and one or more other organizations that are separate legal entities. Under the agreement, the recipient must perform a substantive role in the conduct of the planned research. These agreements typically involve a specific level of effort from the consortium organization and a categorical breakdown of costs, such as personnel, supplies, and other allowable expenses, including F&A costs.. Rule of Thumb: If for example, Duke would provide services to VU, that would require a subaward for work outlined in the grant application, we in the future would require a subaward if VUMC fulfilled the same type of activity. The use of the “Billing Agreement” is not intended to circumvent the formal subaward process but to fill the void when work required by VU faculty, staff or students does not meet the definition of subrecipient activity.

3. Proposal Review Process: Prime/Lead Organization Grant applications are due to the preaward central office for review and approval five (5) business days prior to the stated agency/sponsor submission deadline. The requested deadline for actual submission to the funding agency is two (2) business days prior to the stated agency deadline, allowing the preaward office three (3) business days to complete our review. Subrecipient Organization Sufficient proposal lead time should be given to allow for review of subrecipient documentation by preaward central office to ensure material is approved and supplied to Prime/Lead Organization to meet five (5) business days prior to stated sponsor deadline rule.

4. When To Use Sponsored Activity Billing Agreement Reimbursement for salary, fringe (and tuition/health insurance if graduate student) Billing agreements may also be used for other supporting staff F&A is not recoverable as overhead 1:1 match for each “non-grantee entity” individual working on the project (i.e. separate billing agreements required for each individual per project) Since billing agreement doesn’t include F&A at the collaborating institution, F&A will be charged on the prime award. In the prime budget going to the agency, the costs will be shown as if they were the prime’s costs. Full IDC would be collected minus any exclusions, such as tuition. The account codes will be prime account codes for salary and fringe, for example. The budget justification will explain the relationship. It will be expensed on the GL side as a “service” (i.e. not personnel).

5. One-page sponsored billing agreement

6. Proposal Submission Process: VU Prime What to include in your proposal from VUMC if it includes a proposed subcontract to VUMC: detail budget including VUMC F&A, budget justification, scope of work, biosketch and letter of commitment signed by an authorized representative of the subcontractor institution [This means that VUMC will be routing their subcontract proposal through COEUS for institutional approvals before it is provided to VU.] The lead VU PI then incorporates this information into the proposal. The amount of the Subcontractor's total budget (direct and indirect costs) is included as a separate item in the "other direct cost" or "consortium/contractual" category of the prime proposal budget with a reference to the Subcontractor's complete proposal, including a line item budget with sufficient justification, elsewhere in the proposal. Finally, the subaward is subject to VU indirect costs % on the first $25,000 for proposals submitted to agency after 04/30/2016.. 5

7. Proposal Submission Process: VU Sub-recipient When a VU investigator is asked to collaborate VU PI builds the subaward proposal, to be forwarded according to the usual routing in Coeus to Sponsored Programs Administration for review and approval. Documents include: detail budget (including VU F&A) budget justification, scope of work, biosketch and letter of commitment signed by Sponsored Programs Administration Once approval is granted by SPA, the department of the sub-recipient provides information to VUMC. 6

8. 1 VU student working in a VUMC lab on a training grant owned by VU VU graduate student works on VUMC owned R01 in VUMC lab VU Student supported from a VU owned T32 transitions to VUMC owned R01 under the direction of VUMC faculty VU staff member working in VUMC lab on a grant or contract owned by VUMC VU Faculty member performing substantive programmatic work on VUMC owned R01 Agreement Type Scenarios of proper agreement type use 2 3 4 Note: When using the “billing agreement”, IDC is not recoverable for non-grantee site. Formal subcontract allows for IDC recovery as resources at collaborating site are being utilized. No subaward or billing agreement required as the employer and owner of the grant are the same Billing agreement required to reimburse VU for students salary, health insurance and tuition supported by VUMC R01 grant No subaward or billing agreement is required while on T32, however when transitioned to VUMC owned R01 a billing agreement will be required Billing agreement is required Formal subcontract w/ IDC required Scenario* 1 2 3 4 5 5 *Same applies for reverse VU/VUMC scenario’s 7

9. BASIC SCIENCE INDUSTRY CONTRACTS All contracts (including industry contracts) should be submitted in COEUS prior to the start of negotiations : Insures that COEUS has all the institutional data and approvals concerning submitted proposals Allows the contract intake form in PEER to be simplified since all regulatory questions will be answered in PEER Allows departments to use center management to obtain center numbers Contracts for negotiation will still be submitted to SPA using PEER

10. BEST PRACTICES FOR USING PEER ALL university contracts should be submitted to SPA using PEER to initiate negotiation by the contracts team in SPA All non disclosure and confidentiality agreements to be negotiated by SPA should be submitted using PEER Any other “unfunded” agreements to be reviewed and accepted by SPA should be submitted using PEER

11. Drinking from the firehose?