Professional Documents
Culture Documents
for
Administrators
Sean Hine
Branch Chief
Office of Grants Administration
National Cancer Institute
June 2014
What we will be discussing:
Let’s discuss some logistics
How do you start the request?
Electronic submission
Discussion of costs
Overarching rules
Types of budgets
Dive into the nitty-gritty – budget specifics
Pre-award considerations
After the award
We have an idea for a project…now
what?
All applications to the NIH must be in response to
a Funding Opportunity Announcement (FOA)
Be sure you understand the specifics of the FOA
Including: period of support, type of budget(s),
limits in $ levels, additional reporting, etc.
Abide by any provided submission dates
Welcome to the
electronic world!
NIH has completed the process of transitioning all
competing applications to the electronic (SF 424)
process
This includes multi-project proposals
More information at the following Guide Notice:
http://
grants.nih.gov/grants/guide/notice-files/NOT-OD-13
-075.html
The
requirements may change from mechanism to
mechanism – be careful!
All about costs
A grantee is responsible for following and NIH for ensuring that all
cost considerations are met
Ensure your understanding of the applicable cost principles
Particularly with the change to the uniform principles
Grantees may shape their own systems as long as the principles are
followed and the CFR standards are met for financial management
systems
Four tests for determining allowability:
1. Reasonableness
2. Allocability
3. Consistency
4. Conformance
Costs (cont.)
Differentiationbetween a Direct Costs and Facility &
Administrative (indirect) Costs
Directs – can be identified to a specific grant, project, etc.
F&A – common or joint costs that cannot be readily
identified with a specific grant
More information including discussion on cost
transfers, reimbursement of F&A, specific items of cost,
etc. can be found at the following within the NIH
Grants Policy Statement: http://
grants.nih.gov/grants/policy/nihgps_2013/nihgps_ch7.ht
m
Costs (cont.)
Itis NIH’s responsibility as stewards of Federal
funds to ensure that a grantee’s financial
management systems are adequate to receive
support and that all costs being requested within a
proposal are allowable
If we have any concerns, we will be in touch!
Salary Cap
EffectiveJan. 12, 2014, the salary cap for
Executive Level II has increased to $181,500
Guide Notice announcing the change: http://
grants.nih.gov/grants/guide/notice-files/NOT-OD-14
-052.html
This level also applies to consortia
General Rules/Considerations
Bona Fide Need
In any request, please be sure that the expenses you
are including can be reasonably expected to be
expended in the request time of support
A budget tells NIH what is needed in terms of $
for the proposed research. It is not used to assess
the merit of that research; only accounted after the
merit has been established
General Rules/Considerations (cont.)
Cost Sharing
Not required
Is assumed however when an expense is listed but there
is no reimbursement requested (includes personnel
contributing effort exceeding the level of salary
support)
Application requesting more than $500,000 Direct
Costs (exclusive of consortia F&A) must seek
permission from NIH at least six weeks prior to
submission
Understand the specifics of the FOA
General Rules/Considerations (cont.)
Well-funded investigators should discuss
appropriateness and specific-Institute policies
prior to submission
Responsibility for the Fiscal Management of the
award rests with the award recipient and listed
principal investigator(s)
Types of budgets
Modular
Categorical/Itemized
Inclusionof consortia (modular & categorical)
Program specific:
SBIR/STTR
Ruth L. Kirschstein National Research Service
Awards – Fellowship & Training
Research Career Development Awards
Modular Budgets
Availability of use is dependent on mechanism: R01,
R03, R15, R21, R34 and others as identified on FOA
Application and associated review process does not
require a detailed (categorical) budget
Capped at $250K direct costs per year (exclusive of
consortium F&A costs)
If you exceed $250K directs, you are moving to the
categorical budget request
If mechanism listed above, modular budget must be
used if at or below $250K
Modular Budgets (cont.)
Grantee should begin with a categorical budget for all
years to craft the “module” request
Module = $25K direct costs
General example: All five years of an R01 budget is
$841,432. The average per year is $168,286. Modular
budget request per year (rounding to next module) would
be $175,000.
No escalation per year
Request may fluctuate if appropriate per FOA or one-
time expense (i.e. equipment) but it should be justified
Modular Budgets (cont.)
Full justification on personnel
Personnel should include names, person months and
description of role
Include other information as you deem appropriate
to assist in clarification of request
Consortia costs are calculated separately but same
justification (personnel) requirements apply
Modular Budgets (cont.)
A few more things:
If NIH needs further information, even a detailed
budget explanation, we may ask for it
The NIH Salary Cap should be accounted for in your
calculation/estimate of the number of modules
needed
Be thorough in your personnel justification
Time for the details – Categorical
Budgets
Personnel
Indicate level of effort (calendar months)
Provide institutional base salary up to the NIH salary cap
If salary exceeds the cap, welcome to include a statement indicating
as such in the justification
Apply applicable fringe benefit for position
Explain fluctuations in efforts!
Equipment
Generally, expected to be a one-time expense
Be sure to comply with institution’s definition of equipment
(NIH defines as $5K or more and an expected life exceeding
one year)
Categorical budgets (cont.)
Travel
Dependent upon the needs of the research but be sure it
provides direct benefit to the project
Must be consistent with institution’s own travel policies
Comply with Fly America Act: http://
grants.nih.gov/grants/policy/nihgps_2013/nihgps_ch4.ht
m#fly_america_act
Participant/Trainee Costs
With exception of Training grants, this section should be
left blank unless specifically identified within FOA
Categorical budgets (cont.)
Other Direct Costs
Highly dependent upon the type of research being
conducted – be realistic!
Must be well justified – explain fluctuations and
atypical expenses in the justification section
Include tuition remission in this section
Categorical budgets (cont.)
F&A (indirect) costs
Be sure to follow the rate agreement in place at the
time of the application explicitly
NIH will utilize whatever rate is in place at the time
of award
If the indirect cost base calculation is rather
complicated, it may be beneficial to include a brief
explanation in the justification
Consortia Expenses
Modular budget
May exceed the $250K direct cost limit only for consortia
F&A
May round to the nearest $1,000
Beneficial to explain the direct cost need per year
Personnel justification still required
Categorical budget
Detailed budget and justification similar to the parent
grantee required
Regardless, flow/pass-down rules are in effect!
Some Classic Mistakes
Did not request permission for submitting
application greater than $500K directs
Modular with multiple consortia without a clear
idea as to how much is needed for each site – we
need to reflect their costs including appropriate
F&A too!
Categorical budget does not justify fluctuations
Application indicates that the grantee is going to
take care of the PI’s salary BUT when the award
hits, not so much…
Some Classic Mistakes (cont.)
The listed calendar months when applied to the
base salary does not equate to requested salary
Base salary exceeds current salary cap
Calendar months in budget differs from
justification
Costs in budget differ from justification
Indirect cost base calculation makes no sense
given rate agreement and costs
Reminder:
If you are submitting an R01 and the request is:
At or less than $250K each year, use a modular
format
Above $250K in ANY year OR a foreign (non-US)
applicant, use a categorical format
The $250K direct cost limit is exclusive of consortia
F&A
Special Programs
Thefollowing programs have individual budgeting
requirements:
SBIR/STTRs
NRSA
Career (K) awards
Besure to comply with the specifics of the FOA
and the listed budget requirements
Pre-Award Costs
Costs associated with a project that are incurred prior
to the receiving of the NIH Award
Remember – only the award is a guarantee of the
Federal commitment
Allowable up to 90 days prior the start date of a
competing award
Beyond 90 days requires prior approval
Cost considerations still apply
Incurred at the grantee’s own risk and expense – no
requirement of the Federal government!
You got the $!! Now what?
When receiving the award, be sure to:
Check that it was sent to the correct location
Ensure the funds are available in payment
management
Understand the level of support - $ and time
Account for any terms & conditions; keep an eye out
for any special restrictions on funds
Any restricted funds must be tracked by the grantee
separately!
After the award (cont.)
Funds not matching what you asked for?
Study section cuts have been applied
Can discuss these with your awarding Institute/Center
for reconsideration
Funding policies have been put into place
Not appealable and most likely being applied to all (i.e.
you are not the only one!)
If there may be necessary changes, be sure to discuss
any potential changes in scope to the project with the
awarding Institute/Center
After the award (cont.)
Build an internal budget utilizing the information
provided in the award
Again, be sure to track restricted funds separately
Follow all regulations and policies
If you are encountering start-up issues that may
result in a large amount being unspent, have a pro-
active discussion with your NIH staff
We are here to help!!
Last words…
This is all of our Federal tax $ at work – we have a
mutual obligation to take care of it wisely!
There is a lot that goes into putting forward an
application and conducting reviews – ask
questions prior to help the process go smoothly
For investigators, learn what a great resource your
own sponsored programs office can be
Resources
NIH Grants Policy Statement (10/13):
http://grants.nih.gov/grants/policy/nihgps_2013/
SF424(R&R) Application and Electronic
Submission Information:
https://grants.nih.gov/grants/funding/424/
NIH Modular Research Grant Applications:
http://
grants.nih.gov/grants/funding/modular/modular.htm
Thank you!!
QUESTIONS???