1. Rice University Research Administrators Forum March 22, 2017
Office of Sponsored Projects & Research Compliance
And
Research and Cost Accounting

2. Welcome & Introductions
Attendees (name, title, & department)
SPARC
RCA

3. Housekeeping
Sign-In Sheet
Pickup Handouts

4. Agenda Research Administrators Forum SPARC Overview Effort Reporting
Compliance Updates
Provide Feedback
Cost Transfers
Grants & Contracts Updates
Subcontract Invoices

5. SPARC Overview
Krystal Toups, CRA
Assistant Vice Provost,
SPARC

6. SPARC
Authorized Signing Officials
Submit Applications

7. SPARC
SPARC is committed to supporting the research endeavors of faculty members and staff, and helping them to understand their obligations under applicable governmental regulations and university policies.
Sponsored Projects (Grants and Contracts)
Provides assistance to faculty and staff in the development and submission of proposals, and award acceptance for federal sponsors. Serves as the central point of coordination and tracking for sponsored projects and is Rice’s authorized representative for grants, subcontracts, and other and other 3rd party agreements related to sponsored academia.
Research Compliance
Oversee all activities related to the ethical and legal aspects of research compliance, including export control, conflict of interest, institutional compliance programs for Animal Use, Human Participants, use of Recombinant DNA, and responsible conduct of research.

8. SPARC Review Activity SPARC RCA OTT General Counsel OCFR OPD
Architectural/Engineering Contracts X
Collaboration Agreements (Sponsored)
Confidential Disclosure Agreements (In)
Confidential Disclosure Agreements (Out and/or Mutual)
Consortia / Industry Consortia Memberships Agreements
Consortia / Industry Consortia Memberships Fees/Award
Construction Contracts
Consulting/Professional Service Agreements - In or Out - Sponsored Projects
Consulting Agreements - In or Out - Non-Sponsored Projects
Cooperative Agreements
Copyright Agreements
Contracts - Industry
Contracts - Federal
Data Use Agreement X 
Export Control Licenses
Faculty Recruitment Awards
Federal Contracts
Fellowships
Final Invention Statements
Financial Status Reports
Foundation - Proposals
Gifts - Proposals
Gifts - Awards

9. SPARC Review Activity SPARC RCA OTT General Counsel OCFR OPD
Grant Applications X
Instructional Training Contracts - Sponsored Academia
Instructional Training Contracts - Non-Sponsored Academia)
Interagency Agreements (research projects)
Licensing Agreements (Technology)
Limited Submission (internal review)
Limited Submission (proposal)
Letter of Intents (LOI)
Master Agreements (sponsored projects)
Material Transfer Agreements (In & Out)
No cost extensions
Patents
Progress Reports (Annual and Final)
Salary Reimbursement Agreements (Non-Sponsored Projects)
Salary Reimbursement Agreements (Sponsored Projects)
Service Agreements (In)
Service Agreements (Out)
Site Agreements (Sponsored)
Sponsored Research Agreements
Subcontracts/Subawards (In & Out)
Transfer Applications In (Grants & Contracts)
Transfer Applications Out (Grants & Contracts)

10. Compliance Updates Melissa A. Gambling, J.D.
Associate Director of Compliance
SPARC

11. Two objectives Show the regulatory structure for research compliance.
Arm you with one tip for each compliance area.

12. Regulations and Contacts
Area
Regulations
Purpose
Contact
Conflict of Interest
42 CFR Part 50 & 45 CFR Part 94
Research integrity
Melissa Gambling
Export Controls
15 CFR & 22 CFR
National security
Institutional Animal Care and Use Committee (IACUC)
9 CFR Chapter 1
Humane care of animals
Jacqueline Abendroth*
Institutional Biosafety Committee (IBC)
74 FR 9411
Safety of researchers
Institutional Review Board (IRB)
45 CFR part 46
Safety and rights of human participants
Stephanie Thomas
I won’t go through each regulation, but I wanted to show this slide to show that (1) our requirements implement federal requirements and (2) the federal regulations each have a purpose.
I’ll briefly introduce the contacts and mention Jacqueline is arriving later in March.

13. Conflict of Interest
Confirm with the PI for how to answer the COI question on CayuseSP
My COI tip relates to the COI question on Cayuse. And folks ask me, how do I know whether to check yes or no? So my tip is: if you don’t know the answer to this question, ask the PI. They are the ones who can access their own financial disclosures and know whether their activities are related to this proposal and whether their proposal is updated. Or ask me, and I can reach out to the PIs myself.

14. Export Controls
Contact Melissa Gambling if International Traffic in Arms Regulations (ITAR) restrictions are referenced in the proposal or award.
My tip for export controls relates to ITAR—this one of the regulations protecting our national security interests because it regulates technology and equipment that could be used in military. So it’s not that common that we deal with ITAR here at Rice, but if you see a reference that ITAR restrictions do apply to a project (not that we’ll comply with ITAR, but that restrictions apply), let me know and I’ll take it from there. Here is an example in a funding announcement, like here for a DOD project.
I also check this independently, but it’s great to know there’s another set of eyes on this.

15. IACUC and IBC
Congruency reviews* are required before processing awards, and these reviews involve:
An approved IACUC and IBC protocol
Verifications from PIs
*IRB awards also require congruency reviews.
And my tip for IACUC and IBC: If your PI is asking you what’s holding up the award and the project deals with animal or recombinant DNA research, sometimes it’s the congruency review.
Federal regulations require institutions to verify (before award) congruence/matching between components of the grant applications related to animal care and use and rDNA and the corresponding approved protocols.  The IACUC and IBC administrator is the one who initiates these reviews. So the administrator will look at the award and see it says rat research. But approved protocol involves rabbit research. In that case, amendments and corrections have to happen before the award is issued.
And as you can see, it depends on having an approved protocol and sometimes back and forth with the PI.

16. IRB
Stephanie Thomas, CIP
Compliance Administrator, IRB
SPARC

17. IRB When is IRB Approval Required? When to Submit the IRB Application?
Research
Data through intervention or interaction
Identifiable private information
With Human Participants = IRB Required
When to Submit the IRB Application?
“JIT” (Just in Time)
Time for IRB review
And I’ll hand it over to Stephanie so she can provide her tip for IRB compliance.

18. Grants/Contracts Updates
Aaron Parvis, CRA
Associate Director of Grants and Contracts
SPARC

19. 5 Day Rule
Cayuse proposal should be received by SPARC 5 business days prior to the sponsor’s deadline.
Stated in Rice University Policy No. 301
Contact your Grant Specialist as early as possible for late submissions.

20. Subawards Heidi and Peter currently handle all agreements for SPARC
After the Rice award is set up the PI & Dept. Admin. are contacted to verify the budget, period of performance, reporting, etc.
An agreement is then drawn up and sent to the subawardee
Negotiations take place and once the terms are agreed upon, the agreement is executed

21. Subawards
The subaward is then entered into Cayuse and sent to RCA by the data analyst for the sub fund to be created
Questions? Please contact
Get the PI involved if the progress stalls at the subawardee

22. NSF Update
NSF New Proposal & Award Policies and Procedures Guide 17-1 effective January 30, 2017
Combines the GPG & AAG into one document
2 new proposal types, RAISE and GOALI
Any IDC rate lower than the Federally negotiated rate is considered cost share and is a violation of NSF’s cost sharing policy.

23. NIH Update
NOT-OD released on March 17, 2017 increases the salary cap from $185,100 to $187,000 effective January 8, 2017
NOT-OD released January 13, 2017 states effective January 25, 2017 that proposals submitted with appendix materials not specifically listed in the FOA or in this notice will be withdrawn as noncompliant.

24. NIH updates Allowable Appendix Materials
For applications proposing clinical trials (unless the funding opportunity announcement (FOA) provides other instructions for these materials):
Clinical trial protocols
Investigator's brochure from an Investigational New Drug (IND) application, as appropriate for the goals of the research proposed in the application.
For all applications:
Blank informed consent/assent forms
Blank surveys, questionnaires, and/or data collection instruments
Other items only if they are specified in the FOA as allowable
No other items are allowed in the Appendix.  Simply relocating disallowed materials to other parts of the application will result in a noncompliant application (NOT-OD ).

25. Website Feedback
SPARC is working to update and improve our website and we want your feedback!

26. Research Administrators Forum
March 22, 2017
Research and Cost Accounting
Research/Training/RCA Overview 02 17

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28. Effort Reporting Update

29. Effort Reporting Due Date
Effort Reports due
Friday, March 31, 2017

30. Updated Effort Reporting Procedures
PDF copy of signed reports is acceptable
Scan the signed reports and them to Reporting Group:

31. Updated Effort Reporting Procedures
If PI is not physically at Rice, can certify via
PI writes an to approve effort reports of
specific persons using full names
for specified reporting periods
Example: “I have reviewed and approved effort reports for Jul 2016-Dec 2016 reporting period for John Smith, Matthew Miller.”
PI’s approval should accompany each effort report

32. Effort Reports - Summary
Verify that the percentage of effort for each fund / title is reasonable in relation to the work performed by the employee during the reporting period

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34. Effort Reports - Summary
Changes are needed if the printed percentage of effort differs significantly from the employee’s actual effort, defined as ±5 percentage points of total effort.
To make changes, update the summary page:
Cross out the printed percentage.
Enter the correct % in “ACTUAL (3)” column.
Enter any additions in the space provided.

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36. Effort Reports - Summary
Obtain signature and date
Complete the required form for any changes:
Online Labor Redistribution (prior activity)
Submit the certified Effort Report
Return all pages (summary and payroll detail)

38. Contact Information: RCA Effort Reporting
Chuck Tarantino, Assistant Controller; x3180,
Reporting Group (Effort Reporting Questions):
Roxie Woodward, x3228,
(Single Audits, Special Reports, F&A Rate Proposal)
Lina Nguyen, x2244,
(Effort Reporting)
Located in Memorial Hermann Medical Plaza 2640
Mail Stop 74.

39. Cost Transfers

40. Cost Transfers: Policy 302 and Related Procedures
Submitted timely*
Within 90 days after posting month or within 30 days after project end
Well-documented, including
Reason for transfer and benefit to award
Re-coded transaction identified in “Doc Ref”
Posting support provided
Properly approved by PI or designee*
* If submitted late, cost transfer request also needs:
(a) Reason for the delay;
(b) Steps being taken to prevent future similar delays;
(c) Chair approval (or Dean, if Chair is the PI).

41. Cost Transfers: Submission Methods
EX Form paper copy (EX######)
Be sure to follow coding and support instructions or it will need to be re-submitted by department.
See EX Form Checklist (Controller’s website, Forms section for RCA).
Expense/Revenue Correction (EX1#####) via Web Entry
Preferred method; incorporates all three policy requirements.
Online upload (JX######) forwarded to General Accounting
Effective 07/01/17, must use download template to provide required posted transaction support.
Template will be available on the Controller’s website, Forms section for RCA.
Note: All submission methods are subject to the additional support required for late requests.

42. Subrecipient Invoices

43. Subrecipient Invoices: Roles and Responsibilities
Based on Policy 307 and related procedures
P – Primary responsibility S – Support role
* For additional information see checklist on SPARC website. #
Invoice Processes / Tasks PI DA
RCA 1
Review for compliance with subaward terms, including current and cumulative costs by category and budget restrictions. P* 2
Approve – PI approval certifies amounts are appropriate and reasonable in relation to technical progress. P 3
Review to ensure invoice is within project period and cumulative amounts are within subaward total budget. 4
Obtain, review and approve final subrecipient invoice. S

44. Announcements Research Terms and Conditions 2017
2017 Summer Salary Guidelines
Closeout Recaps
ACT OMB Uniform Guidance Overview

45. Thank you School of Engineering for Hosting This Meeting!!!
Next Meeting
May 17, 2017
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