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- Where do I find policies related to research administration at UC Davis?
- Relevant UC, UC Davis and sponsor policies are often noted on the webpage of on the UC Davis’ Office of Research at: https://research.ucdavis.edu/policiescompliance/
- How do I find institutional information for UC Davis, such as the EID and DUNS numbers?
- The institutional Information page which includes much of the details that you may need is available at: https://research.ucdavis.edu/about-us/institutional-information/
- Where can I find sources of funding for my project?
- Funding sources can be researched through https://pivot.proquest.com/funding_main ; https://www.grants.gov/ - grants opportunities; however, if you are looking for contract opportunities, then we encourage you to look for “contract opportunities” by visiting: https://sam.gov/content/opportunities
Contract opportunities are procurement notices from federal contracting offices. Anyone interested in doing business with the federal government can use this system to search opportunities. Opportunities include pre-solicitation notices, solicitation notices, award notices, and sole source notices.
- What accreditations does UC Davis have as a minority serving institution?
- UC Davis is an Minority Serving Institution (MSI) and a Asian American and Native American Pacific Islander-Serving Institution (AANAPISI). See here for a full listing. We have active efforts to become an Hispanic Serving Institution (HSI).
- How do I submit a Material Transfer (MTA) or Data Agreement (DUA)?
- A Material Transfer Agreement (MTA) or Data Agreement is needed any time a UC Davis investigator sends or receives materials, samples, software, or data into or out of UC Davis. The Innovation and Technology Commercialization (ITC) division, which is part of the Industry Engagement within the Office of Research at UC Davis, handles all incoming materials, and all incoming/outgoing data.
The Innovation and Technology Commercialization (ITC) division at UC Davis, can be reached by visiting the website at: https://itc.ucdavis.edu/
When materials and/or data are exchanged in both directions, this should be treated as a collaboration. For collaborations with industry partners, you are encouraged to visit: https://itc.ucdavis.edu/researchers-faculty/#transactions
For collaborations with other academic institutions or non-profits, you are encouraged to begin such initial conversations with the Associate Dean for Research, Raissa D’Souza, who would then point you in the appropriate direction accordingly.
- What is a Foreign Component on an NIH project?
- Foreign Component is existence of any “significant scientific element or segment of a project” outside of the United States, in other words performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or performance of work by a researcher in a foreign location employed or paid for by a foreign organization, whether or not NIH grant funds are expended.
For Postdoctoral scholars that are required to work on their originally approved work remotely from a foreign country due to COVID-19 travel restrictions, where no grant funds are going to a foreign entity, NIH has determined this scenario does not constitute the performance of a significant element or segment of the project outside the US. Therefore, this is not considered a foreign component and does not require prior approval.
If project staff (including visiting faculty, scientists, etc.) leave the country to return home due to COVID-19 and continue to work on the project, whether paid by the project or not, this could qualify as a foreign component and would require prior approval from the NIH IC.
SOURCE: NIH NOT-OD-19-114, NIH COVID-19 FAQ
- What are some examples of a “significant element of a project” when making determinations regarding a foreign component?
- The recipient institution should evaluate the element of the project that is being conducted outside of the United States within the context of the project as a whole when making determinations about significance. Some examples of activities that may be considered a significant element of the project include, but are not limited to:
- collaborations with investigators at a foreign site anticipated to result in co-authorship.
- use of facilities or instrumentation at a foreign site
- receipt of financial support or resources from a foreign entity
SOURCE: NIH FAQs
- I have a postdoc or research associate that is coming from outside the U.S. to work on my federal award, can I charge the cost of their visa to the grant?
According to the new Uniform Guidance [§ 200.463 (d) “Recruiting Costs” you may charge visa application fees to your grant provided the postdoc/researcher is critical and necessary for the conduct of the project.
- How do I determine the F&A/indirect cost rate to use for my project?
- UC Davis' negotiated F&A rates should be used in most cases. The rate will depend upon the sponsor, project type and location. For more information on F&A, you are encouraged to visit the following website: https://research.ucdavis.edu/proposals-grants-contracts/helpful-links/indirect-cost-fringe-benefit-rates/
- Should the budget amount during an NCE be the last year's direct costs, total costs or what is remaining?
- The budget amount should be the Total Costs for the entire project period.
- Do we need to include awards where the PI has no measurable effort?
- Yes, even if there is no measurable effort, if the award supports the PI's research endeavors it must be included.
OSR recommendation is to put “Effort as Needed*” in the table and then have an explanation below the table including that the effort will not exceed XX amount. Keep in mind PI effort should not be more than 12 months in the current year. Also include the statement “This sponsor funds the research but does not allow PI support and does not require PI effort”.
Be aware different GMSs may require additional information or clarification.
- When a research is including information on a subproject, should the researcher provide the total award for the overall award, or only the subproject. Also, how should we report the effort if they are on more than one subproject?
- According to NIH's FAQs: For subprojects, recipients should provide the project number and PD/PI name for the overall project. All other information, including total award amount and person months, for the subproject only.
NIH does not provide guidance on how to report the effort if they are on more than one project. OSR recommendation, is to have a separate column in the effort table for each
- How should we calculate effort? Should it be a "snapshot"? Or based on Calendar Year, Fiscal year, or on the Budget Period?
- NIH guidance states: PD/PI's need to provide person months of effort for the current budget period and indicate the proposed level effort for each remaining budget period.
We would like to provide you with the following two (2) options for consideration:
Option1: Snapshot - For the current year, use a snapshot of what the effort currently is today. If PI efforts remains consistent, then this a more simplified option. However, if the PI effort fluctuate across different times of the year, it may incorrectly show a lower effort level. Reminder, if the researcher is listed as Key Personnel in the NOA, then prior approval is required. This may give a false impression that prior approval is needed even if over the course of the year they effort is not reduced by more than 25%.
Option 2: Budget Period -- So for each award listed, calculate effort based on that AWARDS budget period. The budget period will not be the same across the different awards. This may prevent the problems that can occur with option 1 when effort fluctuate across the year. However, because the dates vary, it makes cause the effort to appear to be over 12 CM because of the timing of when certain awards end. It is important that if the effort for the current year (the first entry in each of the effort tables) adds up to more than 12CM that and Overlap statement is included that describes how it is not a commitment overlap. For example, explain that the effort for Award Y is reduced for a few months until Award X ends.
- When should we remove something from the pending section?
- Either if the start date has already passed, or if the PI hears from the sponsor that it will not be funded.
- Do you need prior approval from the NIH’s GMS for subsumed effort on a K award?
- No, subsumed effort is complementary effort and does not require prior approval but you do need approval for concurrent support. For more information go NIH GPS Chapter 12 (see 184.108.40.206 and 220.127.116.11)
- If my faculty is a co-investigator on a grant, should I list the project costs for the whole project, or for just his/her portion of the project?
- The project costs for the whole project. If this is a large project grant (for example a P50), list only projects/core that the faculty member work on, list the project costs for the project/core
- How do I get previous copies of NIH RPPR progress reports?
- NIH RPPR progress reports are uploaded to eProposal. To find documents in eProposal follow the Finding Projects and eProposal Navigation guide (Must have an UCSF Myaccess account to view). Search by the A#.
- Should I Submit the Other Support directly to NIH, or should it go to UC Davis’ Office of Sponsored Research?
- Submit the Other Support to your Departmental Research Analyst, who would then process and transmit it through the electronic mechanism for further review by the UC Davis’ office of Research prior to its transmittal to the NIH.
- Do we need prior approval for an increase of effort?
- For NIH, no. You only need prior approval for REDUCTIONS of 25% or more (if they are listed as Key Personnel in the Notice of Award). If not NIH, please check the sponsor policy.
- What if we have received prior approval to reduce effort?
- This is the new baseline of effort. If you make further reductions, you need to ask for prior approval if you reduce by 25% of this NEW approved effort level.
- What should I do if NCE is pending?
- Keep it listed in the active section. Put the proposed new dates and next to the dates, put in Parentheses, NCE Pending.
Example: R01 HL 0000002 (Anderson) (AXXXXXX) 03/1/10– 02/28/16(NCE Pending) 5.60 calendar
- What are different types of overlap?
- Identify any scientific, budgetary, or commitment overlap that would occur if the current proposal were approved. Then state how it would be resolved.The goals in identifying and eliminating overlap are to ensure that sufficient and appropriate levels of effort are committed to the project; that there is no duplication of funding for scientific aims, specific budgetary items, or an individual’s level of effort; and that only funds necessary to the conduct of the approved project are included in the award
Budgetary overlap occurs when duplicate or equivalent budgetary items (e.g., equipment, salary) are requested in an application but are already provided for by another source.
Commitment overlap occurs when a person’s time commitment exceeds 100 percent (i.e., 12 person months), whether or not salary support is requested in the application. While information on other support is only requested for Senior/key Personnel (excluding consultants), no individuals on the project may have commitments in excess of 100 percent or 12 person months.
Scientific overlap occurs when: (1) substantially the same research is proposed in more than one application or is submitted to two or more different funding sources for review and funding consideration, or (2) a specific research objective and the research design for accomplishing that objective are the same or closely related in two or more applications or awards, regardless of the funding source. Potential scientific overlap is to be addressed by the SRG only by its identification in an Administrative Note in the Summary Statement.
- What are some examples of Overlap statements?
- Example 1: There is commitment overlap for Dr. XYZ between 5R01WE1234546-01 and the application under consideration. If this application is funded Dr. XYZ will request approval to reduce his effort on 5R01WE1234546-01 to 2 calendar months. If other pending applications are funded, Dr. XYZ will reduce his effort appropriately.
Example 2: There is scientific overlap commitment overlap for Dr. XYZ between aim 1 of 5R01WE1234546-01 and aim 2 of the application under consideration. If this application is funded, Dr. XYZ’s effort will be adjusted on 5R01WE123456-01 to remove the overlap.
As noted above, the Institute/Center’s scientific program and grants management staff will review other support information prior to award.
Resolution of overlap occurs at the time of award in conjunction with applicant institution officials, the principal investigator, and awarding agency staff. NIH staff continue to monitor changes to other support information throughout the project as part of the annual progress reviews.
- If a PI has an appointment or receives resources from another entity, does this need to be reported internal at UC Davis?
- Yes, this is considered a “Conflict of Commitment” and certain categories of outside activities require prior approval. PI should consult with their department chairs for guidance in this regard.
- For NIH Other Support, should we use Annual Direct Costs or Total Costs?
- NOT-OD-19-114 indicates using Total Costs.
- Is the department’s role w/ foreign influence just to help make faculty aware and direct them to appropriate offices? Or are we expected to verify all information against other sources of information? For instance, do we need to be vetting non-US sponsors of research against entities subject to Restricted Persons Screening?
- Yes, the department’s role is to ask faculty whether they are engaging with foreign entities for research purposes, and make faculty aware and direct them to appropriate offices. Research Administration staff are not expected to verify all information against other sources of information outside of the financial system. If a faculty member mentions that they have a collaboration with a researcher at a foreign institution, Research Administration staff should consider whether the activity requires reporting to NIH as Other Support or a Foreign Component, and make the faculty member aware that they need to report.
- Does a Foreign Component need to be included on Other Support?
- The Foreign component should be part of the proposal, R&R Other Project Information Form, not the Other Support document. The addition of a foreign component to an ongoing NIH grant continues to require NIH prior approval, as outlined in the NIHGPS, Section 8.1.2, Prior Approval Requirements. Principal Investigators should work with Research Administration Analysts to submit the prior approval request.
If an activity does not meet the definition of foreign component because all research is being conducted within the United States, but there is a non-U.S. resource that supports the research of an investigator and/or researcher, it must be reported as other support.
For example, if a PD/PI of an NIH-funded grant has a collaborator outside of the U.S. who performs experiments in support of the PD/PI’s NIH-funded project, this would constitute a foreign component, regardless of whether the foreign collaborator receives funding from the PD/PI’s grant. Additional funding from a foreign source for the NIH-supported research of a PD/PI at a U.S. institution would not constitute a foreign component but would necessitate reporting as other support.
- How should effort be listed for Industry Clinical Trials when the effort varies depending on the current progress?
- One option is to list as "aggregated effort" for all Industry Clinical Trials. List the information for each individual study and then have 1 effort table at the bottom that represents the aggregated effort. Introduce the Clinical Trials section with the following statement:
"Each of these individual projects has a varying need of effort depending on the type of activity currently in progress: protocol development, start-up, patient recruitment, enrollment, follow-up, monitoring, data analysis, publication, and closeout. Faculty determines each project's need and adjust their effort between projects within the total aggregated effort assigned to the clinical projects. Effort is reviewed and confirmed by the department based on the activity of each project
EXAMPLE FOR INDUSTRY SPONSORED CLINICAL TRIALS
Industry Sponsored Clinical Trials Aggregated Effort
Each of these individual projects has a varying need of effort depending on the type of activity currently in progress: protocol development, start-up, patient recruitment, enrollment, follow-up, monitoring, data analysis, publication, and closeout. Faculty determines each project's need and adjust their effort between projects within the total aggregated effort assigned to the clinical projects. Effort is reviewed and confirmed by the department based on the activity of each project
*Title: Economic Parameters in Early Detection of CHI
*Major Goals: The major goals of this project are to use viral strategies to express the normal p53 gene in human SCLC cell lines and to study the effect on growth and invasiveness of the lines.
*Status of Support: Active
Project Number: PCF100013
Name of PD/PI: Turner, P.G.
*Source of Support: Clinton Pharmaceuticals Corporation
*Primary Place of Performance: University of California, San Francisco
Project/Proposal Start and End Date: (MM/YYYY) (if available): 07/01/2019 – 06/30/2023
* Total Award Amount (including Indirect Costs): $500,000
* Person Months (Calendar/Academic/Summer) per budget period.
*Title: Economic Analysis Patients vs. Doctors
*Major Goals: The major goals of this project are to determine how CFRD contributes to lung function decline.
*Status of Support: Active
Project Number: N/A
Name of PD/PI: Turner, P.G.
*Source of Support: Cross Pharmaceuticals, Inc.
*Primary Place of Performance: University of California, San Francisco
Project/Proposal Start and End Date: (MM/YYYY) (if available): 09/01/2020 – 08/31/2025
* Total Award Amount (including Indirect Costs): $1,575,000
* Person Months (Calendar/Academic/Summer) per budget period.
- How do I determine if the subaward should be set up as a cost reimbursable, fixed rate, or fixed amount?
- This is determined at the time the subaward is proposed. If the subaward will cover actual costs and UC Davis will reimburse the subrecipient for its actual costs, then the subaward is cost-reimbursable. If the project meets the definition of fixed rate from the NIH and the subaward is under an NIH award, then the subaward will be fixed rate. If the project meets the definition of fixed amount under the Uniform Guidance (2 CFR 200.1), then the subaward will be a fixed amount subaward. The SOW and budget/milestone payment schedule provide most of the information for making this determination.
- What is the difference between Fixed Rate and Fixed Amount?
- Fixed Amount is defined in the Uniform Guidance at 2 CFR 200.1. Fixed Rate is an NIH term defined in the Grants Policy Statement at 18.104.22.168. Fixed amount is a predetermined amount for the activities performed. Fixed rate is a predetermined rate for an activity but the total number of that activity is unknown. Other federal agencies have not adopted that term; however, check the federal agencies applicable policies because they may have similar guidance. For example, the Department of Defense has a similar situation described under DOD General Terms and Conditions SUB Article XII Section B. View more Fixed Rate Guidance.
- Should indirect costs be added to a fixed rate or should the fixed rate be inclusive of indirect costs?
- The Subcontracts Team prefers that the indirect costs be included in the fixed rate amount. No verification of the indirect rate is needed when the fixed rate amount is inclusive of indirects.
- Can an amendment include more than one-action or do we need to submit separate request forms for different amendment actions?
- An amendment can include as much actions as needed. For example, if the amendment needs to extend the end date, change the subrecipient PI, and include a revised budget, all of the actions may be included in the one request form. Utilize the comments section to help clarify the intent of the amendment.
- Can the Subrecipient PI have 0 calendar months effort or effort as needed?
- Review the sponsor’s policies regarding effort. Subawards under federal flow through require the subrecipient PI to have measurable effort. For cost-reimbursable subawards, the detailed budget and justification will include this detailed information. For fixed rate/fixed amount subawards, the effort and commensurate salary are calculated into the fixed rate/fixed amount cost.
- Can the subaward/subcontract extend beyond the prime award dates?
- No unless the sponsor has provided pre-award spending and our PI has approved the subrecipient to pre-award spend. Otherwise dates that are outside of the prime award create an unfunded liability for the University. The University (and ultimately the PI and Department) would be responsible for covering the expenses that are outside of the prime award and not covered by the prime award. Therefore, the Subcontracts Team is not in the position to commit the Department and PI to cover such expenses.
- Can we process an NCE and a carry forward at the same time?
- An NCE extends the current budget period through the new end date. It does not create an additional budget period. Carryforward requires the addition of a new budget period so that funds may be carried forward from one budget period into another. So, carryforward would not be applicable in this instance because with the NCE we are allowing the subrecipient to continue spending the funds already allocated. If we need to create a new budget period, then the transaction would not be an NCE but an additional budget period with carryforward. The “Other” field in the Amendment Request section can be utilized to explain the request.
- Can the Subcontracts Team process the subaward if the Notice of Award is not in Cayuse?
- No, Cayuse is the system of record. If the NOA is not in Cayuse yet, then the award has not been fully setup. Most awards allow us to spend back to the start date and we can allow our subrecipients to do the same. Therefore, we wait until the NOA is setup in Cayuse before issuing the subawards. Otherwise, this creates an unfunded liability for the Department and PI.
- The department wants to revise the budget amount or some other item after the subaward has been sent out, what action is needed from my end to ensure we grant the subsite with the correct budget or revised item? Do I need to submit another request form?
- No, another request form is not needed. Please work with whomever is processing the transaction to update the budget amount instead of emailing the central Subcontracts Team email box. Also provide the PI’s approval of the new budget amount in lieu of submitting another request form.
- When is a budget justification required?
- A budget justification is required for all new cost-reimbursable subawards and amendments that add budget items that were not previously described in a budget justification. The budget justification is part of the subrecipient monitoring required under the Uniform Guidance (2 CFR 200.332(d)). We as the pass-through entity are required to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward.
- Does the Subcontracts Team review every single line item of the budget and justification?
- We review the budget and justification to ensure they conform to the regulations and policies of the sponsor and to meet our obligations of monitoring the subrecipient under the Uniform Guidance (2 CFR 200.332(d)). We will give a quick review of the calculations to ensure the budget adds up to the total amount being provided. This ensures there are no legal inconsistencies and reduces the need to issue amendments correctly errors later on.
- How do I know when we need to fill out a subaward request form?
- A completed form is required for each transaction. The form collects the necessary information for putting together the transaction as well as the contact information for where to send it. In addition, the form collects the PI’s signature and therefore approval of the transaction.
- In what type of situations, would I need to get the Subrecipient Request Form resigned or concurred by the PI again?
- The PI is responsible for the overall management of their award including the subawards. When the PI signs the Subrecipient Request Form, they are approving the scope of work, budget, budget justification, and the compliance pieces required for managing the subaward. The Subcontracts Team can only process the transactions as has been requested. We cannot assume what was intended. For instance, if the PI wanted to restrict carryforward but the form said it was automatic, then the Subcontracts Team will need PI concurrence that the carryforward should be restricted. Processing the transaction incorrectly may lead to a financial liability for the University. The Subrecipient Request Form may either be corrected and resigned, or an email with PI concurrence to the corrections is allowable.
Change in budget amount (does it matter if the budget increased or decreased?) Yes, a change in budget amount requires PI approval regardless; if the change is an increase or decrease.
Change in project dates? Yes, a change in project dates requires PI approval.
Change in Intent (I originally submitted it as in increased in funds, but realized it was for a carry forward request). Yes, if the incorrect box was marked for an amendment, the PI does need to reapprove because they approved a different transaction, and we cannot assume what was intended
- Can the budget period be longer than 1 year?
- It depends. For federal flow through, the budget period is capped at one year even if we received a multi-year award from the NIH or other Federal agency. This ensures we are monitoring the subrecipient in compliance with the Federal regulations and agency specific requirements. For non-Federal flow through, check the prime terms and conditions. We may be able to issue the subaward for the full period of performance.
- What should be included in the Scope of Work (SOW)?
- The Scope of Work (SOW) needs to describe the work that is to be performed by the subrecipient. It should contain sufficient detail so that there is no ambiguity about the activities to be performed and the deliverables required from the subrecipient. The deliverables would include any technical/scientific reports required. If the SOW contains information related to the agreement like dates, PI names, budget amounts, etc., please review to ensure they have been updated and align with the request. Inconsistent dates, amounts, etc., create legal inconsistencies in the subaward contract and can lead to issues later.
- When is a Scope of Work (SOW) required?
- A SOW is required for all new subawards. For fixed rate/fixed amount subawards, the SOW may be included on the milestone and payment schedule as one document instead of two.
- If the project dates are updated/extended, does that count as a change in the Scope of Work (SOW)?
- Yes, but we do not need a revised or updated SOW. The language in our subaward amendments updates the end date throughout the subaward contract. A revised SOW including the new end date is not required but may be provided.
- When is a revised budget and/or revised scope of work (SOW) needed for a budget decrease?
- It depends on the purpose of the decrease. If the decrease is a general decrease and there is no changes to the scope of work a revised budget is not needed. If the decrease is needed to remove specific tasks or budget line items, a revised budget/scope of work is needed. The revised documents can then be incorporated into the subaward agreement.
- Do we need a revised/additional scope of work when adding supplemental funds?
- Often yes but it depends on for what the funds will be used. If the additional funds are being provided to cover more work, then yes, a scope of work (additional or revised) is required. For example, the original SOW stated that the subrecipient would process 100 samples. We now need the site to process an additional 25 samples. The SOW should be updated to reflect that the subrecipient is processing a total of 125 samples. Otherwise, they may not be contractually obligated to process the additional samples. We may have just allowed them to invoice for more funds to process the original 100 samples.
- Do we need a revised/additional budget when adding supplemental funds?
- Yes, we need either a revised budget for the new total or an additional budget which details how the funds will be spent. If the project is a fixed rate project and we need to increase the ‘do not exceed amount’, a budget is not required because we already have the fixed rate amount. Please provide a comment in the Comment section detailing what is changing. For example, the total number of patients the subrecipient is allowed to enroll is increasing from 5 patients to 10 patients.
- Why do we need to include the total estimated period and total estimated amount for federal flow through subawards?
- Effective November 12, 2020, the Uniform Guidance was updated. Every five years the regulations are required to be reviewed and updated as needed. These are now required data elements that we need to include in the federal flow through subawards. See 2 CFR 200.332 (a)(1) (v) and (ix).
- Do we need to include the total estimated period and total estimated amount for non-federal flow through subawards?
- No, these data elements are only required for federal flow through but may be included for all other subawards.
- Is there a preferred format for the detailed budget?
- No, the Subcontracts Team does not have a preferred format for the budget. Although the SF424 budget page is a good example because it breaks the costs down by major category and includes a calculation of the indirect costs with the applicable rate and base.
- Why can't we use the PHS 398 budget page for fixed rate?
- The PHS 398 budget page does not provide the details needed for issuing a fixed rate agreement. The Subcontracts Team needs more than just the fixed rate amount. A milestone or payment schedule is needed for the fixed rate agreements. The payment/milestone schedule details the amount of each payment, what activities trigger a payment, and/or when that payment will happen. The detail needed for each payment/milestone schedule will be dependent on the project. The description of what triggers a payment should be clear and unambiguous. See Fixed Rate Guidance for more information.
- How do I determine if the UC Davis’ award was granted with automatic carryforward?
- The NIH Notice of Award will affirmatively state if carryforward is automatic or requires prior approval from the GMS/GMO. For all others review the sponsor’s terms and conditions.
- When do we need to provide the EIN on the request form?
- The EIN is needed for all domestic subrecipients when the subaward/subcontract contains federal flow through funding.
- Why is the EIN limited to 9 digits on the request form?
- The Subcontracts Team uses the 9-digit EIN to locate the Single Audit in the Federal Audit Clearinghouse (FAC). As part of our obligations under the Uniform Guidance (2 CFR 200.332(b)), the Subcontracts Team is required to locate the Single Audits for the subrecipients with which we contract. The FAC does not recognize the longer versions used by the NIH or federal agencies. Moreover, searching in the FAC by name can return inaccurate or incomplete results.
- When do we need to provide the UEI on the request form?
- The UEI is needed for all subrecipients when the subaward/subcontract contains federal flow through funding.
- Can we still include the DUNS instead of the UEI?
- No, as of April 4, 2022, the Federal Government stopped accepting the DUNS as the unique entity identifier. The UEI created in SAM.gov is the official unique entity identifier.
- Can we issue a subaward or amendment to a subrecipient that does not have a SAM.gov UEI?
- No, we may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to us a unique entity identifier (2 CFR 25.300). Moreover, we are required to include the UEI in the subaward because it is a required data element under 2 CFR 200.332(a)(1)(ii).
- Does a subrecipient have to register with SAM.gov and have an active registration before we can issue a subaward to them?
- Maintaining an active SAM.gov registration is for entities that receive funding directly from a federal agency. See 2 CFR 25.200. A subrecipient may obtain a UEI from SAM.gov without completing the fully registration process. Although review prime sponsor’s policies because they may require that the subrecipients also maintain an active SAM.gov registration.
- When do we need to include the IACUC and IRB letters with the request form?
- The Subcontracts Team collects the IACUC and IRB letters from the foreign subrecipients. This is a compliance check that Subcontracts Team has performed for many years to ensure the subrecipients have the approvals prior to working on vertebrate animals or human subjects research.
- Does the IRB or IACUC letter need to be in English?
- No, the Subcontracts Team will accept the letter in a foreign language. If the letter can be translated by Google Translate or another service, please provide that. Otherwise please provide PI concurrence that the IRB or IACUC letter is in fact the appropriate approval.
- Does the IRB or IACUC need to have an expiration date?
- No, some foreign IRBs and IACUCs do not include an expiration date. However, if the letter does have an expiration date, please make sure that the date is in the future and not about to expire. If it is expired or about to expire, please add a comment that an updated IRB or IACUC letter will be provided once received by the PI.
- Does the Subcontracts Team need the UC Davis’ IRB or IACUC?
- No. The IRB or IACUC numbers can be found in the system of Record of the Office of Research at UC Davis. If the Subcontracts Team needs to review, then we can find the information in the system of Record accordingly. Even when the site is relying on the UC Davis’ IRB, the Subcontracts Team does not need a copy of the UC Davis’ IRB.
- What F&A/indirect cost rate should be applied to the outgoing subaward?
- Unless the sponsor indicates a specific indirect cost rate in their written guidelines/policy, subrecipients on UC Davis’ projects should apply their Federally negotiated F&A rate, their State-negotiated rate for State of California agencies (e.g., City of Davis and Yolo County), the de minimis rate of 10%, or elect to not apply indirect costs. UC Davis does not negotiate F&A rates with the subrecipient entity.
- When do we include the F&A rate agreement?
- The F&A rate agreement is needed whenever the subrecipient will use their negotiated rate for calculating the indirect costs. If the sponsor has a different policy like 0% on some non-profit funded projects or 8% for NIH K awards, then the negotiated rate agreement does not need to be provided. We are required to include the applicable rate in the subaward because it is a required data element under 2 CFR 200.332(a)(1)(xiv).
- Why do we need to include the F&A rate agreement with each request form?
- As part of our obligations to monitor the subrecipients under the Uniform Guidance (2 CFR 200.332), we need to review the budget each time to ensure the F&A rate used on the budget is an allowable rate. If the rate changes, we need to include the new rate in the amendment because it is a required data element under 2 CFR 200.332 (a)(1)(xiv).
- What if the F&A rate has not changed from the previous year?
- Yes, we still need a copy to review the budget that has been provided to us. This review becomes a part of the auditable record and we need the back-up documentation each time.
- Can we determine the indirect rate to be used on the subaward budget?
- No, we must follow the sponsor’s policy regarding indirect costs. The subrecipient institution may decide to accept less than they are allowed. Moreover, under the Uniform Guidance we are required to honor the negotiated rate agreement of the subrecipient (2 CFR 200.332(a)(4)).
- What is a resource-constrained country?
- These are countries where resources are limited for carrying out the project. A good reference is the World Bank’s list of low and middle-income countries. Countries on those lists would meet the definition of a resource-constrained country.
- Why is the working capital advance limited to 2 months of the annual amount?
- The purpose of the advance is to provide enough capital so that the subrecipient has funds on hand to pay for the project. The subrecipient is required to invoice monthly. The subrecipient will spend down the funds in the first month, invoice for those funds, and still have funds for the next month. This way the subrecipient always has some funds on hand to cover their expenses until the end of the project when the advance is reconciled (either completed, spent, and invoiced; or the site returns the unused funds).
- How is the working capital advance calculated?
- The working capital advance is limited to 2 months of the annual amount plus the purchase of equipment. The purpose of the advance is to provide the subrecipient with 2 months’ worth of funds
Example 1: If the subaward is for 1 year and the total amount for that year is $120,000, then 2 months of the annual is $20,000 (annual amount is $120,000 divide by 12 to obtain the monthly amount, which is $10,000. So 2 months would be $20,000).
Example 2: If the subaward is for 6 months and the total amount for that six-month period is $60,000, the 2 months of the annual is $20,000. To obtain the annual amount double the total since that would make the project theoretically 12 months. That theoretical total is $120,000 and the monthly amount is $10,000. So, 2 months is $20,000.
Example 3: The subaward is for 1 year and the total amount is $65,000 with $5,000 being included for the purchase of equipment. The equipment costs are excluded. So the annual amount is $60,000. The monthly amount is $5,000 ($60,000/12) and 2 months’ worth of funds is $10,000. The working capital advance would then be the $10,000 plus the $5,000 for the equipment for a total of $15,000.
- What information is available for animal subjects?
The Office of Research provides oversight for the use and care of animals in research at UC Davis. Led by the Campus Attending Veterinarian, this division is organized into the following three units (Teaching and Research Animal Care Services – Husbandry; Institutional Animal Care& Use Committee; Campus Veterinary Services). While each serve a unique purpose, together they ensure the humane care and use of animals in research and teaching at UC Davis. We encourage you to visit the following website for more information: https://research.ucdavis.edu/policiescompliance/animal-care-use/
- What information is available for human subjects?
The Institutional Review Board (IRB) Administration is committed to following the federal regulations to protect the rights and welfare of human subjects involved in research conducted under the auspices of the University of California, Davis. We encourage you to visit the following website for more information: https://research.ucdavis.edu/policiescompliance/irb-admin/
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