Transcript Document

Managing Subcontracts and
Consortium for NIH
and Federal Funding
Ramadhani Abdallah Noor, M.D., M.P.H.
Research Associate
Africa Academy for Public Health (AAPH)
Overview
• Background
• Scope—management subgrants and consortium for NIH and
federal funding
• Key areas—subgrant management
• Foreign Organization System (FOS) review
• Common compliance pitfalls and strategies for success
• Case studies with references
Background
• It’s about the systems/procedures, activities, and compliance
• Pre-award, during award, and post-award
• NIH Grant Policy Statement (Oct. 2012)
http://grants.nih.gov/grants/policy/nihgps_2012/
• NoA, institutional policies, CFRs, OMB circular, etc.
• Policy requirements “flow down”
IMPORTANT!
• A domestic institution administering a subcontract to a foreign
institution must assure NIH that it is holding its collaborator to
the policies required for foreign institutions
Scope
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General issues
Application preparation
Policies and procedures
Grant monitoring
Fiscal and scientific overlap
Standards of conduct
Consortium arrangements
Indirect costs
Records management
Local and int. requirements
• Banking arrangements
• Budget preparation and
controls
• Accounting systems
• Personnel
• Internal controls
• Procurement
• Property and asset
management
• Travel
NIH Grant Policy Statement
• Part I—NIH grants information
• Part II—Terms and conditions of NIH awards
– Subpart A: general
– Subpart B: for specific types of grants, grantees and
activities
• Part III—Points of contact [Institutes and Centers]
Make sure you have the current version
General Issues
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Good organizational charts
Clear identification of responsible person/ToRs
Clear lines of delegation authority
Clear communication lines
Required registrations (e.g., eRA Commons [organization/PI];
DUNS number; CCR registration, etc.)
Policies, Procedures, and Standards of
Conduct
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Research misconduct, conflict of interest, confidentiality, etc.
Well documented and approved
Formulated and owned by the institutions
All staff trained
Evidence of enforcement
Application Preparation
• Team work—led by PI
• RFA/Call announcement requirements (eligibility, overall
impact, etc.)
• Reviewed and supported by institution
• If consortium: reviewed and supported by members
• Peer review and scored review criteria
Application Preparation (cont.)
• Budget preparation
– Supported by verifiable information
– Based on true costs
– Reviewed by finance and accounting
• Electronic submission
Grants management and research administration support are
key from the beginning—pre-award, award, and post-award
Post-Award Grant Monitoring
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NoA, agreements, approved proposal, protocols, etc.
Periodic programmatic reviews (deliverables and milestones)
Financial review of actual versus budget
Assess and reassess compliance
Fiscal and Scientific Overlap
• Avoid duplication of payments
– Same research
– Same equipment
– Time of researchers (effort)
Consortium Arrangements
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Steering/decision-making mechanisms
Consortium agreement
Communication plan
Application, budgets—member involvement
Performance (deliverables and milestones)
Costs and expenditure monitoring
Indirect Costs
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Applicable rates
Clearly identified
How deduction is carried
Properly used
Records/Data Management
• Scientific and administrative (policies and procedures; where,
how, and storage period; how disposed)
• Biological samples (MTA, storage, future use)
• Data management plan
• Data sharing agreement
Banking and Payment Arrangements
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Separate bank accounts for the grant
Maintain accounts that allow electronic transfer of funds
How payments are initiated, authorized, and approved
Authorized signatories (preferably two)
Compliance with local institution and sponsor financial
guidelines
Budget Preparation and Controls
• Source (cost) information document
• Review by accounts for accuracy
• Once approved,
– Change by authorized person with appropriate supporting
communication and approval by sponsor
– Regular monitoring (burn rates), monthly/quarterly actual
versus budgets
• Internal controls (accounts audited annually)
– Independent accountant
– Internal/government auditors
– OMB A-133 requirement ($500,000 or more in federal funds
during a fiscal year)
Personnel and Payroll
• Personnel
– Written policy manuals
– Job descriptions
– Annual evaluations
– Time and attendance is recorded (effort)
• Payroll
– Prepared based on percentage of effort
– Verified by a second person
– Approved by PI
– Direct deposit
Procurement and Property/Asset
Management
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Written institutional policies
Local/national procurement act
National procurement regulatory authorities
Three quotes for large purchases/alternative approved
vendors list
• Applicable in all ranges of resources, including human
resources
• Purchases approved by authorized manager
• Property management (registry, tags, annual inventory,
authorized disposal)
Travel
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Written policies
How travel is approved
How expense claims are verified
Proposed per diem is reasonable, limited to mission days and
actual travel time
• Most direct route, not exceeding coach class fare
• U.S. flag carriers
• U.S. foreign travel restrictions
Foreign Organization System (FOS)
• Review of administrative and financial systems using the
foreign organization system (FOS) review document
• Ability to manage U.S. federal funds in an accountable manner
• Benefits to the grantee:
– Assists compliance with NIH terms and conditions
– Provides a global outlook at internal procedures
– Promotes understanding between PIs and administrators
• FOS is not an audit
Common Compliance Pitfalls
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Unallowable costs
Misallocation of costs
Excessive cost transfers
Inaccurate effort reporting
Inadequate monitoring of subrecipients
Administrative and clerical costs
Noncompliance with assurances and special terms and
conditions of award
• Delinquent closeout reporting
Resources
• OMB Circular A-133: This circular describes audit requirements for
organizations receiving federal funds. Sections 225 and 400,
Supplement 3, part M, all include information on
subrecipients/subcontracts.
• Sample Foreign Subaward Template
• NIH Grants Policy Statement section on Foreign Awards, including
policy requirements
• NIH Grants Policy Statement section on Consortium Agreements
• Fogarty International Center (FIC) Consortium Agreement
information
• NIAID tutorial on subawards
Questions?
[email protected]