Grant and Financial Management
November 09, 2022OPSSD: Janeway Society First Friday
November 4, 2022
Grant and Financial Management
Presenters:
Amy S. Ellis, Director, Proposal and Award Management at OSP
Krystina Gross, Associate Controller for Sponsored Projects Financial Administration at OSP
John Palmieri, Associate Director of Finance, Department of Pathology
Panelists:
NIH Program Officers:
Naila Makhani, MD, MPH, Associate Professor of Pediatrics
Richard Pierce, MD, Assistant Professor of Pediatrics
Information
- ID
- 8245
- To Cite
- DCA Citation Guide
Transcript
- 00:00Welcome to 1st Friday and today.
- 00:06We have two pronged.
- 00:10Plan, we're going to start out with a
- 00:13grants management presented by Amy Ellis,
- 00:16Christina Gross and and John Palmeri
- 00:19and they will introduce themselves.
- 00:23I think they have an intro slide
- 00:26and and that'll be the first.
- 00:28Probably 2/3. Of the.
- 00:31Hour and a half, or at least the and.
- 00:36Then the last part we're going to have.
- 00:40A panel discussion led by some of our own.
- 00:44Folks about interacting with
- 00:49program officers.
- 00:51So go ahead, take it away.
- 00:53Thanks.
- 00:59That's.
- 01:10Ohh. Sorry.
- 01:28No spell in the back.
- 01:35That's good enough. I was told once
- 01:38that technology will humble you,
- 01:40and I see that's true today.
- 01:42So hi everyone,
- 01:44and thank you for inviting us to
- 01:47your little meeting here today.
- 01:51And how are we progressing
- 01:53through these, nick?
- 01:56Down Arrow did not work. Right, new.
- 02:07OK. All right.
- 02:09So we're going to introduce ourselves.
- 02:11I am Amy Ellis. I'm director of
- 02:13proposal and award management and
- 02:15the Office of Sponsored Projects.
- 02:17I've been at Yale for 23 years.
- 02:19And before I landed in OSP nine years ago,
- 02:22I worked at the School of Medicine.
- 02:24I was in internal medicine in the
- 02:26Cancer Center, each for about 7 years.
- 02:28And I worked in the business offices
- 02:29and I handled grants most pre,
- 02:31ward and post award.
- 02:32So I basically know some of the functions
- 02:34that John is going to speak about.
- 02:37OK. So hand off to Christina.
- 02:39Hi, I'm Christina gross.
- 02:41I've been at Yale since May of this year.
- 02:45Prior to that I was at Washington
- 02:47University in Saint Louis in Post Award
- 02:50Research Administration for about 22 years.
- 02:53So not new to research administration,
- 02:56but very new to Yale and I'm very
- 02:58excited to be here and and have this
- 03:00conversation with you all today.
- 03:03And I'm John Palmieri.
- 03:04I'm associate director of
- 03:06Finance Post Award currently in
- 03:09pathology as of October 2nd.
- 03:11Prior to that, I was opposed to Associate
- 03:14Director of research in Pediatrics.
- 03:17And then I, I've been here about, oh,
- 03:2014 years and I started actually in the
- 03:23office of development for a year and
- 03:25a half and also in OSP for a year and a half.
- 03:29So I do have that kind of translational
- 03:31knowledge with Amy to understand.
- 03:33All sides, yes, OK.
- 03:38Oh, it doesn't want to.
- 03:41Yeah.
- 03:51Doesn't want you. There it goes. OK.
- 03:54And we're just going to go here, all right?
- 03:57It's going to be a manual process,
- 03:58so bear with us. Sorry about that.
- 04:00So we want to talk 1st about the,
- 04:03oh, you know what,
- 04:05we missed this one. The agenda.
- 04:07So we're going to talk a little
- 04:09bit about the research enterprise
- 04:11at Yale and just the overall.
- 04:13And overall, look of what research
- 04:14enterprise at Yale looks like.
- 04:15And then we're going to talk
- 04:17about some freeware basics,
- 04:18including some facts and figures,
- 04:19talk about post award compliance,
- 04:21managing your award, which I'm sure
- 04:23you're all very anxious to hear about,
- 04:25talk about annual reporting and closeout.
- 04:28And then talk about some of the
- 04:29resources that you have available to
- 04:31yourself on a day-to-day basis. OK.
- 04:34So now we're going to skip over here and
- 04:36this is the research enterprise at Yale.
- 04:39You can see that the majority of
- 04:40our funding is federal funding,
- 04:42largest piece of that pie.
- 04:43And so we are very,
- 04:46very cognizant of the fact that we have
- 04:48to be compliant with federal regulation.
- 04:50OK? There, our largest funder,
- 04:52we never want them to say, hey,
- 04:53you're doing something wrong,
- 04:54we're going to take money away from you
- 04:56or levy fines or penalties against us, OK.
- 04:58So when we say federal regulation,
- 05:01This is why.
- 05:02And if we ever have a problem
- 05:05where they hold,
- 05:07withhold federal funding,
- 05:09that can also affect student
- 05:12scholarships and grants.
- 05:14And student from from the federal government.
- 05:17So we want to make sure that no activities
- 05:20are harmed because of what we're doing here.
- 05:22The second largest piece of the
- 05:24pie is our non federal sponsors.
- 05:25We will accept money from almost
- 05:27anybody who wants to support our
- 05:29research at Yale and then you can
- 05:31see clinical the clinical trials
- 05:32is a smallest but obviously a
- 05:34very important piece of what we
- 05:37do and sponsored projects.
- 05:42So again, just to give you an overarching
- 05:47idea of what we do in our office,
- 05:49we had last year over $964
- 05:53million in grant expenditures.
- 05:55So you know we are one of the top
- 05:57ten universities across the country
- 05:59in terms of grants and that shows
- 06:02here that does include 245 million in
- 06:05facilities and administrative costs.
- 06:08And those RFA costs,
- 06:09we also call them indirects.
- 06:10That's what keeps the lights on.
- 06:12That's what keeps our salaries,
- 06:13basically our offices paid and your
- 06:15support staff paid so that we can
- 06:17make the research enterprise happen.
- 06:19At the university.
- 06:20We had close to 6000 active awards
- 06:22and you can see the breakdown
- 06:25between federal and non federal
- 06:26and clinical trials there as well
- 06:29as almost 1500 outgoing subawards.
- 06:30All right.
- 06:31So if you get something and we're subbing
- 06:33it out to a colleague in another university,
- 06:36that is handled by a separate unit
- 06:38within our office because there's a
- 06:39whole nother set of regulation that.
- 06:42Um involves outgoing subaward monitoring,
- 06:45right.
- 06:46Also Christina's office did 2555
- 06:49financial status reports and if you
- 06:51think about that over the course of a year,
- 06:52that's a lot.
- 06:53We also had last year over 2000 active award
- 06:57principal investigators like yourselves.
- 07:00We have a lot of activity going
- 07:02through our office, all right.
- 07:04And we try to great,
- 07:06give great customer service
- 07:07to each and every one of you.
- 07:10We had 17161.
- 07:13Active in unique sponsors and a lot of
- 07:15times they all have different requirements.
- 07:18So if you say,
- 07:19well,
- 07:19what does this sponsor say,
- 07:21I really don't know until I go
- 07:23in and dig through either the
- 07:26solicitation that you answered
- 07:28for your proposal or your notice
- 07:30of award because there's so many,
- 07:32even within the NIH they have you know,
- 07:35a couple dozen different agencies.
- 07:37Those different agencies can have
- 07:39different nuances to what they require
- 07:41and and what they're looking for us to do.
- 07:44So it's very important that we always
- 07:46go back to the written documentation
- 07:48before we can give an answer,
- 07:51all right.
- 07:52And then we had almost 5500 new
- 07:55and competing proposal submissions
- 07:57totaling over $4 billion last year.
- 07:59So the proposals that went through
- 08:01my proposal team,
- 08:02which is 6 people for the entire university,
- 08:06totaled over $4 billion dollars
- 08:07worth of funds that we asked for.
- 08:10OK.
- 08:15Alright, we're going to talk
- 08:17a little bit about pre award.
- 08:20OK. So when you are,
- 08:22you know, looking for funding,
- 08:24some of the question that comes
- 08:26up often is grant versus gift.
- 08:28John, go ahead and jump in.
- 08:31This question a lot, you know.
- 08:32You know, I'm getting this funding source.
- 08:34Where does it go?
- 08:35I applaud everyone for asking for help
- 08:38and not for forgiveness, which is great.
- 08:42Also to think when you ask for forgiveness,
- 08:45just as an as an aside,
- 08:47you can't you might hold up those
- 08:48funds that you're trying to
- 08:49unlock to further your research.
- 08:51So think about it in that respect.
- 08:54But I can also say is that there can
- 08:57be different mechanisms for the gift.
- 09:01There could be different
- 09:03reporting requirements.
- 09:03There's definitely a different
- 09:05indirect rate when it comes to
- 09:07a gift versus a sponsored award.
- 09:09Umm.
- 09:11So it you know usually we get asked
- 09:13and you know your business office
- 09:15will be the first line always for
- 09:16your questions and if they have if
- 09:18they cannot make a determination
- 09:20generally comes to my office and
- 09:21so we are looking to see what are
- 09:24the requirements from the sponsor.
- 09:25So if a sponsor says you have
- 09:28reporting requirements,
- 09:28there is a provision for termination
- 09:31either from their side or our side
- 09:34or if they say you have to send
- 09:36back any use unused funds that
- 09:38is generally a grant but a gift.
- 09:41Is more of an unrestricted pot of money
- 09:44that is being given to the university,
- 09:46usually a specific Pi for either
- 09:49restricted or unrestricted use.
- 09:51And that could be to support your
- 09:53Project X or it could be just to further
- 09:57Doctor Jones's research in general, OK.
- 09:59And what we're looking for there is
- 10:02there are generally no reporting
- 10:04requirements or minimal reporting
- 10:06requirements and that could be either
- 10:09scientific reporting or financial reporting.
- 10:12And also they there will not be provisions
- 10:14for termination because they're
- 10:16giving us these funds unrestricted.
- 10:17They're basically saying here's the money,
- 10:19there's no strings attached,
- 10:20OK and they will never ask for
- 10:23us to return any unused funds.
- 10:26All right.
- 10:27So those are some of the very obvious
- 10:29differences between these two mechanisms.
- 10:33But always check with your
- 10:34business office 1st, please.
- 10:36Yes. You know, we, we will triage
- 10:38as best we can before we hand
- 10:40off to OSP or or the OR the.
- 10:42Development, right?
- 10:46OK.
- 10:47Oh, OK, not mine here.
- 10:52So there's different types
- 10:53of funding mechanisms.
- 10:54There's the clinical trial,
- 10:56clinical research and the grants.
- 10:58Again it's the,
- 11:01it depends on what you're doing
- 11:03will determine how this works.
- 11:04Also it determines what kind of
- 11:06indirect or taxes if you will,
- 11:08that the university will take.
- 11:10Right now on brands and sponsored research,
- 11:13it's 67 1/2% may go up, I don't know.
- 11:18No, it's not gonna you heard it here 1st
- 11:22and then you have your clinical trial
- 11:24and that that indirect rate is about 30%.
- 11:26There's different mechanisms of how
- 11:28it each are taxed or the interact
- 11:32is applied in clinical trials.
- 11:35The indirects are applied on the
- 11:37funding that comes in as opposed
- 11:40to a grant where it's a it's
- 11:42assessed on each expense
- 11:44and another thing to keep in mind that not
- 11:47all clinical work. Is a clinical trial,
- 11:49it can be considered clinical research.
- 11:51So again that is driven by the scope of
- 11:53work and if you have questions on that,
- 11:55you reach out to your business office
- 11:57support staff and they can reach out to SP.
- 12:00And you know, we might toss it around
- 12:01to a couple different individuals,
- 12:03but we will make that determination with you.
- 12:05OK. Not necessarily for you.
- 12:07We always want to work in conjunction
- 12:08with all of our faculty.
- 12:10OK. All right. All right.
- 12:15Here's my scare slide.
- 12:16This is the proposal submission days
- 12:20to deadline slide for all of last year.
- 12:23So you can see the first line
- 12:26is proposals that were received
- 12:28in OSP the day they were due.
- 12:30Why is that the highest you ask?
- 12:33I don't know.
- 12:34So you can see.
- 12:37Nearly 50% of our proposals are received
- 12:40the day before or the day that they are due.
- 12:44All right, I don't advise that.
- 12:46And here's why. Because things can go wrong.
- 12:49All right. If we get your proposal
- 12:51at 2:00 o'clock in the afternoon,
- 12:54you have to know by looking at this graph
- 12:56that our proposal team has 15 other grants
- 12:58that are coming at the same time as yours.
- 13:00So it's not like, well,
- 13:02my proposal manager has
- 13:02three hours to look at that.
- 13:04Your proposal manager may have 10 minutes
- 13:05to look at that because they have.
- 13:07Four more in the queue either
- 13:09before or after you, OK.
- 13:11And we do review in the order that proposals
- 13:14are received on top of that if there are.
- 13:18Significant changes that need to be made.
- 13:21Then you, we need time to to make those.
- 13:24All right for NIH applications.
- 13:26You should have enough time for us to submit
- 13:28that and then you can go into ecommons and
- 13:30look at your proposal and if you say, hey,
- 13:33this is wrong I want to swap out a section.
- 13:36Can you resubmit? Yeah.
- 13:37If you've sent it to us in enough time,
- 13:39we certainly will do that for you.
- 13:41And that could be, you know,
- 13:42a typo that's significant.
- 13:44That could be, you know whatever it
- 13:46is that you want to change something.
- 13:48You have the luxury of doing
- 13:50that if you get it to us.
- 13:51Very late and we don't push
- 13:53the button until 4:30.
- 13:54You likely will not have time to do
- 13:57that last quality control check.
- 14:00All right? So I don't advise that.
- 14:02Some of the problems that we have run into
- 14:05a couple of years ago during an NIH deadline,
- 14:08it was on the day of the NIH deadline, all
- 14:11of the servers down the East Coast went out.
- 14:16And we couldn't submit anything.
- 14:17There was no power.
- 14:18There was no juice.
- 14:19It was not Yale, it was not ITS.
- 14:21It was the servers down the East
- 14:23Coast we still had.
- 14:24It was about 2:00 or 3:00 o'clock
- 14:25in the afternoon.
- 14:26We still had four proposals to
- 14:27get out the door,
- 14:28which was good.
- 14:30Based on this graph,
- 14:32we were able to get them out in time.
- 14:36But you know that's something you never want
- 14:37to find yourself on the other end of, right?
- 14:39That is a heart stopping.
- 14:42Type of situation.
- 14:42You don't want to find yourself,
- 14:44you know, having to explain to the
- 14:46NIH if there are system problems.
- 14:49We have a system to system
- 14:51proposal development application.
- 14:53It's software.
- 14:53There can be glitches if something happens.
- 14:56You can't write a letter to
- 14:57the NIH that says, you know,
- 14:59our iris system went down or there was a
- 15:01hiccup or something happened within the NIH.
- 15:04Late submission policy,
- 15:05it says that is not a justifiable excuse.
- 15:08They won't,
- 15:08they won't buy it.
- 15:10So they're your application is
- 15:11going to be returned.
- 15:12That we view and I'm sure
- 15:14you've all spent months
- 15:15working on this, on your work.
- 15:17We don't want that to happen.
- 15:18We want your proposal to go in and
- 15:20the very best condition it can so has
- 15:23the highest possibility of funding.
- 15:25OK, we're working with you to do that.
- 15:27We do not review scientific components,
- 15:31but we do review the budgets,
- 15:33we do review for compliances.
- 15:35We look to make sure page limitations
- 15:37are accurate and so on and so forth.
- 15:39All right. You give us more time,
- 15:40we can do more review on your behalf.
- 15:43All right. OK. Can I can I add, yes.
- 15:49Tickets submitted on the same day
- 15:52don't get accepted by the public,
- 15:54you know, I don't have those
- 15:56numbers off the top of my head.
- 15:59I would love to say there's a huge
- 16:01correlation that it's like you know,
- 16:02like 1%, but I can't,
- 16:03I can't say that and be accurate.
- 16:06What I do want to say is that we
- 16:10first of all putting our resources,
- 16:12straining our resources that you
- 16:15know to that extent is tough and.
- 16:18You don't get the best review.
- 16:21So again we want to give you the best
- 16:25opportunity for funding and if there is,
- 16:27there was an example something I went,
- 16:29I was a proposal manager when I first
- 16:31started OSP and we had a proposal
- 16:33came through and it was at the very
- 16:34last minute and there was all kinds
- 16:36of problems and we were trying to get
- 16:38everything fixed as best as we can.
- 16:40And finally I received it like 10
- 16:42minutes before 5 right NIH 5:00 o'clock.
- 16:44It's a deadline if you if you submit to
- 16:47the NSF National Science Foundation at 50001.
- 16:50Your system shuts down. All right.
- 16:52So there there's you can't even
- 16:54get out the door.
- 16:54So but within the H,
- 16:56you know,
- 16:57said I submitted it was about 10-5
- 16:59or 10 minutes before the deadline.
- 17:00The Pi went and looked at it and
- 17:02she said Oh my God,
- 17:03there was an entire upload that was wrong.
- 17:06It was supposed to be like my
- 17:08scientific portion of whatever.
- 17:10And the person who had was in a
- 17:12hurry now trying to make changes,
- 17:14uploaded a presentation on effort reporting,
- 17:18a 19 page presentation on effort reporting.
- 17:21And you know.
- 17:22I can't fault them because they
- 17:23were in a hurry frantically trying
- 17:25to make this deadline because the
- 17:27PR gave them everything very late.
- 17:29And it got returned,
- 17:30it got rejected without administrative
- 17:32review because it was noncompliant.
- 17:33That's what they say.
- 17:34It's not compliant.
- 17:35So we never want to see that happen,
- 17:37OK.
- 17:39Amy, if I could add that, please do.
- 17:42Since I was also working on,
- 17:44I used to submit proposals,
- 17:46so I worked very closely with
- 17:47Amy and her group at that time.
- 17:49And the rule of thumb is, you know,
- 17:52really to to get everything to SP in
- 17:55its final form as best as you can,
- 17:57five days ahead of the deadline.
- 17:59I don't think they mentioned that. So
- 18:01that is our official policy 5 days.
- 18:05Or cut off if I'm not.
- 18:06There are schools across the
- 18:08country that do have hard cut
- 18:09offs so. So and I always used to say you
- 18:12know if you want the business office to
- 18:14look at it you know every business off.
- 18:16I'm going to say this a lot actually
- 18:19every business office here at yales
- 18:21different there's no consistency except for
- 18:24inconsistency here in here at Yale I find.
- 18:26So if you really you know you want the
- 18:28business office to look at it because
- 18:30they're going to look at you know your
- 18:32budget justification to make sure that
- 18:34you're budgeting appropriately and I'll.
- 18:36I have a few slides on that,
- 18:37so I'll get into that in a little bit, OK?
- 18:42Michael, modular.
- 18:43So modular versus detailed budgets.
- 18:46There are two types of budgets
- 18:48that can be submitted.
- 18:49Modular budgets typically are threes,
- 18:52our 20 ones on 250 less or and or less.
- 18:58But really the important piece here
- 18:59and they have different requirements
- 19:01for budget justifications.
- 19:02But the real important piece here
- 19:04from for me and I've actually
- 19:06advised us to faculty to six the
- 19:09success of the certain faculty.
- 19:11That wanted to do the modular budget
- 19:14because it was quote easier budget what
- 19:17you need to be successful really and
- 19:19you know the the NIH is not I don't
- 19:22think I would just because you're low
- 19:24you're budgeting at a lower amount.
- 19:27You may think you're going to
- 19:28get funded really that's not
- 19:29they're not going to bounce it.
- 19:31It's really your science right.
- 19:32So just budget what you need
- 19:34to be successful.
- 19:37OK. And so just to piggyback off of that,
- 19:39the second bullet point, prior approval
- 19:42is required for any NIH budgets.
- 19:44Again, we're very NIH centric care
- 19:47that exceed $500,000 in direct costs
- 19:50in any budget period. All right.
- 19:52So the NIH does require that you reach out to
- 19:55the program officer or what we call the PO,
- 19:58which I'm sure you're all familiar with
- 20:01at least six weeks in advance and prior
- 20:04written approval is required to submit.
- 20:07If you don't have that as part
- 20:09of your application package,
- 20:10when it goes to the Center for
- 20:12receipt and referral, they're going
- 20:14to say you don't have prior approval,
- 20:15they're going to send it back to us
- 20:17without review and say it's rejected, OK.
- 20:19And there's very little that
- 20:21we can do about that.
- 20:23So that's something to keep in mind as well.
- 20:25And if you don't know,
- 20:26you can ask questions,
- 20:27talk to your business office, talk to OSP,
- 20:29we can help you make that determination,
- 20:31put you in touch with the right people.
- 20:33OK.
- 20:34And one more important,
- 20:35important point about budget.
- 20:37Educations, even though they're
- 20:39not required an itemized budget
- 20:41justification for a modular budget,
- 20:42the business Office still needs
- 20:44that just to make sure we're
- 20:46compliant with the you're spending.
- 20:48That's all.
- 20:50See you too. All right. OK.
- 20:53Budgeting. Well, this is my side.
- 20:55I'm so I'm going to go over just,
- 20:56you know, if you have grants,
- 20:58you know how you should know how to budget.
- 21:00I mean I, I have a home budget.
- 21:01I, you know, we should all budget
- 21:04within our means and you know,
- 21:06but really you're going to start out with
- 21:08your personnel and your other expenses.
- 21:10But there's also this part that
- 21:12we kind of alluded to before like
- 21:15indirect cost currently at 67
- 21:171/2% that kind that really covers,
- 21:19as Amy said, the lights and any OSP.
- 21:22Um, may, may or may not be
- 21:24parts of your business office.
- 21:27But, and the other kind of caveat
- 21:30to budgeting is also the fringe.
- 21:33Depending on the type of staff you want
- 21:36on your on your grant or in or in your
- 21:39lab to assist with your research, it's.
- 21:44Fringe is kind of get gets lost in
- 21:46that in in budgeting because it is
- 21:48a huge factor and it will eat up a
- 21:51large portion of your of your budget.
- 21:56What else do I want to say?
- 21:57Again, you you should when
- 21:59working with your business office,
- 22:01you know indirect are part
- 22:02of the overall budget,
- 22:03but really you want to look at
- 22:05the direct costs or the costs
- 22:07that are are directly applied
- 22:09to the grant or sponsored award
- 22:12and that's really what you have
- 22:14available and you know you know you.
- 22:17In thinking about when you develop
- 22:18your budget, you know how many.
- 22:20You know supplies am I going
- 22:23to need or how many? Uh.
- 22:25Different lab pieces that
- 22:27you're going to need.
- 22:30So you should be able to kind
- 22:31of get a sense of that.
- 22:32Again, work with your business office,
- 22:34have them go through it,
- 22:36have them look at it.
- 22:39Yeah, I want to raise.
- 22:41Can I just put it in my budget?
- 22:43No, and I'll tell you why.
- 22:46Because we are bound by Yale policy
- 22:49that we have to propose at the
- 22:52current institutional base salary,
- 22:54or what we call IBS.
- 22:56So you we we can put in anticipated
- 23:00raises for outgoing years,
- 23:02but maybe not a promotion where you're
- 23:04going to get like an extra $250,000 so.
- 23:08Also, if you think about it,
- 23:10if you're already over the cap.
- 23:12Yeah, it doesn't matter if you're yeah,
- 23:14you're you're so if your cat,
- 23:16which is convenient, which
- 23:17is a little more convenient.
- 23:18Although as you could see that
- 23:20you know the maximum amount you
- 23:22could actually apply for is 500K.
- 23:25Well, that hasn't gone up in June.
- 23:27How many years?
- 23:28And you could probably do a number
- 23:31of years even the modular budget
- 23:33I don't think has gone up and.
- 23:35No, not not not. Line. OK. OK.
- 23:40So I was going to talk about a
- 23:41little bit of fringe costs here.
- 23:43So fringe cost covers all
- 23:45employee benefits and are charged.
- 23:49Talking about, we're talking about.
- 23:53I my slides are there
- 23:55too. Yeah, we're going to talk about
- 23:56that a little bit more in detail.
- 23:59So fringe. So when you think about friends,
- 24:03there's different rates for fringe.
- 24:05There's the grants of clinical trials
- 24:06and the Med school has its own fringe.
- 24:08So, so that's that's fun for everyone.
- 24:12And the fringe covers all fringes
- 24:14applied on all paid absences.
- 24:16So even if your CNT goes on parental
- 24:21leave or your postdoc goes on parental
- 24:24leave you are still paying for it on
- 24:27a direct charge you to your grant.
- 24:30But what friends actually covers is
- 24:31in the lower part part of this slide.
- 24:33It's it's really all those extra
- 24:35benefits that Yale gives everyone.
- 24:37You know I was, I was,
- 24:38I took on the adoption benefit which
- 24:40is awesome. So thank thank you all.
- 24:43And you know,
- 24:44there's there's a whole list there that I,
- 24:46I don't need to get into but it's
- 24:48really all this is found in the act
- 24:50of the university rate agreement.
- 24:51I believe it's,
- 24:52it's published
- 24:53and it's all over our website.
- 24:57But really the other caveat to
- 24:59this is if you have staff and
- 25:02you're trying to figure out, well,
- 25:03should they go on my startup,
- 25:04should they go on my grant,
- 25:05buy them to your grant,
- 25:06there's a difference of 12% there.
- 25:08So, you know, think about where your
- 25:10costs are actually going to be applied.
- 25:13And just one further thing,
- 25:15our fringe agreement, like our F and
- 25:18a agreement that is set by the feds,
- 25:20so we have to put in proposals and
- 25:23they set that rate for us, all right.
- 25:25So that's not something we just pull out of.
- 25:27The air or that the School of
- 25:30Medicine sets that is set by our
- 25:33our federal agency, OK. Yes, ma'am.
- 25:39Medicine and startup.
- 25:42Yeah. Yeah. Yeah.
- 25:43So if you have actually go to the next slide,
- 25:46it might be a little bit easier.
- 25:48There's a better visual there.
- 25:49OK. So here we have just the
- 25:53salary and fringe portion.
- 25:55So this would this budget would be
- 25:57on a grant. So you're covered by
- 25:59the 30% for faculty or MP. Yeah.
- 26:04Ohh, can I use it? Oh yeah, sorry.
- 26:05The those those peoples in the Cyberspaces,
- 26:07right? Let's see.
- 26:10This is it up there, no.
- 26:13This one I got to do.
- 26:16That's thanks.
- 26:23Oh, it's it's a red screen on here,
- 26:25which is great.
- 26:27So, so there's there's
- 26:30three different rates here.
- 26:32So there's the grants,
- 26:33the clinical trial and the YSM rate.
- 26:35So on this budget we have,
- 26:38we're going with the,
- 26:39this is a sponsored agreement rate,
- 26:41so grant rate, so you're at 30%
- 26:43for the Pi and then the lab tech
- 26:46which is the CNT would be at 73%.
- 26:48However, if you said well maybe you'll want
- 26:51to split that 50% on your startup, right.
- 26:53So then you're now heard you're going to be
- 26:56charged this rate over here which I can't.
- 26:5968% rather than the 7068.
- 27:03Yeah, it went down.
- 27:05Needless to say,
- 27:06it used to be the other way around on my
- 27:07last slide or last year when I did this,
- 27:09but it's so.
- 27:12The API's are higher hourly.
- 27:16What do you mean?
- 27:18For faculty is higher on my SF, but lower.
- 27:22Yes, exactly. And the reason for that
- 27:24actually is to cover the leave of ABS.
- 27:28So I think it's just a
- 27:30simplified look at this.
- 27:31It depends where you charge the fund,
- 27:33where you charge the salary and fringe
- 27:36determines the fringe rate grant funds.
- 27:39If you're charging to grant, it's one rate.
- 27:40If you're charging it to a School
- 27:42of Medicine funds like startup
- 27:44or gift account or something,
- 27:46it's a different rate.
- 27:47Does that make sense?
- 27:49Part of the reason for that difference
- 27:51is going to be because there are certain
- 27:54fringe benefits that are not allowable
- 27:56on a federal grant to begin with.
- 27:58So. While we may provide them as
- 28:02an institution that has a lower
- 28:04friend rate because we can't charge
- 28:05that to the federal government.
- 28:07That's part of the negotiation
- 28:09process and building out those rates.
- 28:12Yeah.
- 28:21Doesn't matter.
- 28:21So at this point we're not on a
- 28:24cost basis fringe application here.
- 28:27They've just decided we're in going
- 28:29into our finance system work day,
- 28:31it's kind of a limitation of work day.
- 28:33You really need a rate that's
- 28:35why the government allows us
- 28:37to negotiate a friend rate.
- 28:39So it kind of spreads even the costs.
- 28:41So it's it's an average base of fringe
- 28:44per person across the university.
- 28:46So if we over under recover from our actual.
- 28:49Costs that'll get put into
- 28:51consideration for our next negotiation
- 28:54for the next set of fringe rates.
- 28:56They don't.
- 28:58It ends up being charged.
- 28:59The difference between Grant
- 29:01pays what you get and you know.
- 29:07I'm getting these. Thank you.
- 29:13Yeah. They can get really
- 29:15complicated really fast,
- 29:16especially when you're doing like
- 29:18cost transfers and moving things
- 29:19onto and off of a grant and then
- 29:21you have different fringe rates.
- 29:22So it wasn't one rate and
- 29:23now it's a different rate.
- 29:24So that's a good reason why it's
- 29:26good to get things accurate up front.
- 29:32This is. OK.
- 29:34But it's not showing the right
- 29:36click down here.
- 29:40That one, this one. OK. OK. Sorry.
- 29:44You're better at driving Amy than I am.
- 29:46Sorry I said that to me. I want that.
- 29:51There you go. Sorry. OK. Anyway,
- 29:54so let's talk about cost share, right.
- 29:56OK. So Nick wanted me to discuss a
- 29:59little bit about cost share and this
- 30:02is a portion of project costs that
- 30:05are not directly paid by the federal,
- 30:08by federal funds.
- 30:09So in this I'm showing AK award example.
- 30:13So this would be a faculty that has
- 30:17225,000 that gets paid in institutional.
- 30:20Your salary.
- 30:23Trying to learn that one now of 225,000
- 30:25and as a requirement for having K award,
- 30:30it's 75% effort to to the K award.
- 30:34However 75% we have to take 75%
- 30:39of the overall salary of the
- 30:41225 which is the one 68750.
- 30:43Now there is also a salary cap
- 30:46on that K award of 100,000.
- 30:48So really the cost share is that
- 30:50difference plus the higher fringe.
- 30:53So the department or startup
- 30:55depending on what was negotiated
- 30:57would have to cover the difference
- 31:00of that of that cost which is the
- 31:0397 and there's there's 97488 and
- 31:05they're in our financial system.
- 31:07There's ways of doing that.
- 31:08I actually haven't example later
- 31:10an effort reporting that kind
- 31:12of breaks that out a little bit
- 31:13that that you could see that.
- 31:15Any questions there, you know?
- 31:18I'm just going to add there that we we
- 31:20talked about this in terms of cost share,
- 31:22but it is different from true cost share
- 31:25where we need to have a form filled out
- 31:27and all kinds of signatures on that form.
- 31:29So for salary over the CAP cost share,
- 31:32no prior approval is required.
- 31:35And different departments
- 31:37manage the cost share. Yep. So.
- 31:43Department the cost.
- 31:46I think in medicine.
- 31:49Sometimes it gets charged.
- 31:52It it it all depends I've seen and
- 31:54I don't when you were internal Med
- 31:56maybe it was Amy and I know when I
- 31:58was Internet it was actually part of
- 32:00the startup package so it was it was
- 32:02we have many moons ago I don't know
- 32:04if this still they still do that but
- 32:07it's you know there's I think there's
- 32:09a larger conversation about how cost
- 32:11shares funded and you know that's
- 32:14something that you should really ask
- 32:16you know always ask those questions.
- 32:19And you know and especially when
- 32:20it comes to startup packages you
- 32:22know because you never know.
- 32:23You know you want you want to make sure
- 32:25that you you're all on the same page
- 32:28department faculty recruits and what
- 32:30your true cost will be down the road
- 32:32so that you can work on your research
- 32:34and have all the funds available for
- 32:36your research as you anticipated.
- 32:38And you know we don't like I don't
- 32:41I'm you know I'm all about full
- 32:43transparency that's for sure.
- 32:45So I just want to give some
- 32:48somewhat of a similar.
- 32:50Cost share again with the CAP,
- 32:52this is on the NIH cap of currently
- 32:55203 seven and the fact that this
- 32:58faculty member makes up 275,000.
- 33:00So we're doing kind of this on
- 33:02the same kind of difference here,
- 33:0660% salary,
- 33:0660% salary on multiple RNH type awards
- 33:12to get our 60% of 165 thousand and then
- 33:17taking the 60% of also the cap of 122
- 33:21and then you have the difference of.
- 33:2332780.
- 33:29Did I get that OK? Yeah, OK. OK.
- 33:35OK. We're going to Amy's going to
- 33:37talk about some compliance holds
- 33:39and I'll add what I see from the
- 33:41department perspective as well.
- 33:46Alright, so once you're award comes in,
- 33:49we have a process within OSP of
- 33:52setting up your reward right.
- 33:54So we have to set it up in several systems.
- 33:57So to start with the award or could
- 33:59be a contract manager depending on
- 34:01the mechanism will review and make
- 34:03sure that everything is in place.
- 34:05For federal awards we generally
- 34:08do not negotiate,
- 34:09we accept their terms as given for
- 34:12your non federal sponsors we will.
- 34:14Potentially negotiate your awards
- 34:15to make sure that we have terms that
- 34:18are favorable to the university
- 34:19and that we can live with. OK.
- 34:21And that sometimes can take
- 34:22a little bit of time,
- 34:23but let's stick with Federals.
- 34:25Federal work comes in,
- 34:27your Ward manager reviews it and
- 34:30they will send out an e-mail to
- 34:31both you and your business office
- 34:33with a copy of the notice of award
- 34:35and what we call a Noah and OA.
- 34:37And we will highlight if there are
- 34:39any special terms and conditions
- 34:41that you need to be aware of.
- 34:42OK. So pay attention to those
- 34:44emails when they come in.
- 34:45Because the ultimate
- 34:46responsibility lies with you.
- 34:49Once that e-mail goes out,
- 34:52it is then sent over to our Iris
- 34:55setup team and the dollars are
- 34:57recorded within the iris system.
- 35:00That is for reporting purposes.
- 35:03So we do run reports out of the
- 35:06iris system for our schools and
- 35:08especially School of Medicine.
- 35:10They analyze that.
- 35:14Ohh just to the very bottom level and
- 35:16that helps them with their forecasts
- 35:18and their projections for further,
- 35:21you know for the upcoming years.
- 35:22So we want to make sure
- 35:23those numbers are right.
- 35:24Once that is done,
- 35:26it then gets sent to Christina's
- 35:28team SPF A and it is set up within
- 35:30work day and work day is the,
- 35:32our financial system of record which
- 35:34your business office will also use.
- 35:36So that is the financial management system.
- 35:39We will,
- 35:40we do require an award budget set
- 35:43up form and that gives both OSP
- 35:46and PSPFA the financial information
- 35:48that we need to set up the award
- 35:51accurately within both of our systems
- 35:53and it is the departmental staff's
- 35:55responsibility to fill that form out
- 35:57and get it over to our office, OK.
- 35:59So hopefully they're talking
- 36:01to you about that.
- 36:02You know, is there any budget cuts?
- 36:04Do we need to make any rebudgeting decisions,
- 36:07are there some awards and how much are
- 36:09you going to go out to the sub awards?
- 36:10OK.
- 36:11Yeah,
- 36:11that's a very important step
- 36:13communication with your business office.
- 36:17Because that could delay
- 36:19the entire setup process.
- 36:21So we want to be cognizant about you
- 36:23know if it's multiple PRI how the
- 36:25budget split between two departments
- 36:27it's it's you know we need to know
- 36:29all that so we could send that
- 36:31information over to Christina's group
- 36:33so that they could set it up properly.
- 36:35Same thing with subcontracts.
- 36:36So the subcontract group we need
- 36:39to know if there was budget cuts
- 36:41is there is will the subcontract
- 36:42be affected or will they take the
- 36:45same cuts as Yale did so you know.
- 36:49And sometimes it needs to be
- 36:51a little more itemized,
- 36:52especially for subcontract reporting.
- 36:54I think, Christina,
- 36:55you could probably talk about
- 36:56that a little bit and reviewing
- 36:59the invoicing on subcontracts
- 37:00for the department level.
- 37:03Just to have as much of that complete
- 37:05information package as possible.
- 37:07So right now an SPF A,
- 37:09you know we're receiving new
- 37:11Noah's on a day-to-day basis.
- 37:13You know our Q is about
- 37:155 days behind right now.
- 37:17So there's a lot that goes into setting
- 37:19that up in the financial system.
- 37:21The financial system controls the accounting,
- 37:23how the FDA is charged,
- 37:25what kind of spend restrictions are
- 37:26in place on that particular grant
- 37:28as well as how we get reimbursed
- 37:30from the federal government.
- 37:32So there's a lot of complex things that.
- 37:34Go into setting up that award
- 37:36and nine times out of 10,
- 37:38the biggest delay is us not having
- 37:40the appropriate level of information
- 37:42from the Department Business
- 37:43Office in order to set that up.
- 37:46So just you know where we are
- 37:49actually implementing a team that
- 37:51just specializes in award set up
- 37:52so that we have a little bit more
- 37:55of a streamlined process to provide
- 37:57better support for our faculty
- 37:59and your business office.
- 38:00Someone in your business office should
- 38:02be reviewing those setups because.
- 38:04You know. Things happen wrong F and
- 38:06a rates on K awards some something
- 38:09like that happens and you know it.
- 38:11There's so many pieces of information
- 38:13that has to be input into work day that
- 38:16it's there's a lot of room for error.
- 38:18So you know look we all make mistakes we try
- 38:21to minimize those mistakes where we can.
- 38:24But having that second set of eyes
- 38:25and even your set of eyes as well,
- 38:27it's also important that you look at
- 38:29these you know when when you get your
- 38:31account Holder report packages or your or
- 38:33meeting with your your business office.
- 38:35After that, you know you are doing
- 38:37your due diligence at the same time.
- 38:40Right. So if we don't have an ABS
- 38:43form once it, it kind of makes its
- 38:45way through our different teams,
- 38:47it's going to go on ABS hold and
- 38:49that is one of the compliance
- 38:50holds so to speak that could slow
- 38:53down getting your reward set up.
- 38:54So if you want to make sure that we
- 38:57get the information that we need that
- 39:00will allow us to you know jump right in
- 39:04other compliance holds that potentially
- 39:07could slow down your reward setup.
- 39:09Conflict of interest,
- 39:10your disclosure has to be current course.
- 39:13It's an annual disclosure.
- 39:15If there are any significant updates,
- 39:18those are supposed to be filed
- 39:20within I think it's a 30 day window.
- 39:22So make sure that your disclosure
- 39:24is up to date and it's the
- 39:26correct pathway for NIH awards.
- 39:27It has to be the PHS pathway.
- 39:29All right.
- 39:30So we do check that before we
- 39:32set up the awards.
- 39:33We have to be confining.
- 39:34We also want to make sure we have IRB or
- 39:37IACUC approvals in place before we allow.
- 39:39Spending to start, all right.
- 39:41So make sure your protocols are
- 39:43you know submitted timely and
- 39:45your approvals are on the way all
- 39:46right or here they have to be here
- 39:50and there. There is from the business
- 39:52Office perspective there is a
- 39:54work around to the IRB approvals.
- 39:55We could submit an attestation letter
- 39:58because we IRB also has backlogs and
- 40:01not enough staff to review these in
- 40:05an appropriate amount of time but.
- 40:09The biggest. Challenge that I've
- 40:13come across with IRB approvals is
- 40:15actually just linking the Irish
- 40:18record to the funding source.
- 40:20So that's which is just a really A1.
- 40:23I think it's just a one like just one
- 40:26piece of the greater puzzle fraud.
- 40:29Yes. Sorry I'm not so sure,
- 40:31but my office is actually working on
- 40:34a step by step instruction currently.
- 40:36So I'm hoping to like actually
- 40:37give that out to everyone because
- 40:38I think it'll be very helpful.
- 40:42OK. So we've talked a lot about compliance.
- 40:46So we do have this compliance hierarchy
- 40:48here and it's a little daunting,
- 40:49but this is what OSP, SPF a,
- 40:53this is kind of the, Umm,
- 40:55the regulation and the departments, right.
- 40:58And I mean at the end of the day,
- 41:00right, it sits with us.
- 41:01So we have to make sure that we
- 41:03are in compliance with all federal
- 41:04and state legislation, right.
- 41:06So you know we can't do anything
- 41:08that's against any federal law
- 41:10or any state law, all right.
- 41:12So that's the overarching then we also have.
- 41:14Federal regulation and that is all of
- 41:17the regulation specific to sponsored
- 41:20projects and for for the federal regulation,
- 41:23it's called uniform guidance and
- 41:25that was put out in 2014 and
- 41:28it is anything but uniform,
- 41:30OK, because every different,
- 41:31every sponsor has a different set of rules.
- 41:33That is a companion guide
- 41:36to uniform guidance.
- 41:37So there's a lot to know after that.
- 41:40We have agency specific,
- 41:43all right.
- 41:44Again the agencies after uniform guidance,
- 41:47you know when they were implementing
- 41:49that they had the option to go and
- 41:52codify the their own set of guide
- 41:55guidelines in addition to uniform
- 41:57guidance or and companion to.
- 41:58So that's a whole nother level.
- 42:00And then we have institutional
- 42:03policies and procedures.
- 42:04So that's yales policies and procedures.
- 42:06Our auditors hold us to our
- 42:09written policies and procedures.
- 42:11So you can tell me that doesn't make
- 42:13sense Amy. Well, I might agree with you.
- 42:15But if it's written down,
- 42:16we still have to, you know,
- 42:18we we still have to be compliant
- 42:19with that and follow that.
- 42:21All right.
- 42:21It might,
- 42:22you know maybe in the next
- 42:23couple of months we can look at
- 42:24that and and do some revisions.
- 42:26But if it's in writing when you
- 42:27and I are having a conversation,
- 42:28I cannot get around that.
- 42:30All right.
- 42:31So and the little caveat on the bottom.
- 42:35Yale's policies and procedures may be
- 42:38more restrictive than our sponsors
- 42:40policies and procedures and we always
- 42:42follow the more restrictive policy.
- 42:44All right.
- 42:44That's going to keep us out of hot
- 42:46water and out of orange jumpsuits,
- 42:47which I don't look good in orange.
- 42:49So and then finally,
- 42:50we do have to abide by the special
- 42:53award terms and conditions and that
- 42:55is the language that is contained
- 42:57within your notice of award and that
- 42:59is kind of like the last guidance.
- 43:01So if we want to say hey for your K award,
- 43:04what is the? Provision for carryover.
- 43:07I'm going to your ward notice I'm
- 43:09not going to uniform guidance.
- 43:10I want to know what I specifically
- 43:12said about your award note.
- 43:14Your award.
- 43:15OK.
- 43:16So all of that,
- 43:18we have to comply with all of that and it,
- 43:19like I said,
- 43:20it is daunting,
- 43:21but you have a full complement
- 43:23of staff to help you.
- 43:26Sludge through
- 43:26it. Yeah, exactly.
- 43:27And I could tell you one of the.
- 43:30The from the business Office perspective,
- 43:31again the the institutional policy of 90 day,
- 43:3790 day adjustments is more restrictive
- 43:39here at Yale than probably any institution.
- 43:43I don't know, you could,
- 43:44I don't know where it was where you are.
- 43:46It's untrue. I don't know.
- 43:47You know I think the guidance is
- 43:50when it's discovered as opposed to.
- 43:5390 days, I don't know. That's
- 43:54Christina's area. I'm, I'm not,
- 43:56I'm not getting into that.
- 43:57Depends on the sponsor.
- 44:00Thursday, 90 days from the day discovery.
- 44:02Other sponsors HHS. So NIH says 90
- 44:04days from the date of discovery.
- 44:06You have to correct, correct an error.
- 44:08But their parent agency,
- 44:10DHS, says 90 days from the
- 44:12original transaction date.
- 44:13And that's what Yale follows,
- 44:14and that's what Yale follows.
- 44:16So it could go either way.
- 44:17Actually, it's 95 days from
- 44:18the end of the month in which
- 44:21the transaction occurred.
- 44:22I got lots of little nuances.
- 44:25We're all learning
- 44:26and that's sore spot for John,
- 44:27but we will get into that all right.
- 44:33So I just so these are what some of
- 44:35those compliance things and and again
- 44:37I want to just talk about budgeting
- 44:39again so this is your notice of award.
- 44:42So on the face page it really gives you
- 44:45sorry I'm just looking over it gives
- 44:48you just all the pertinent information
- 44:50of start and end dates and who to
- 44:52contact and who your contacts are and
- 44:55the awarding agency pay attention to
- 44:57your award dates sometimes you know
- 44:59you'll have a truncated budget period.
- 45:02So you'll actually have more money in
- 45:05nine months as opposed to the 12 months,
- 45:08which also leads to other carryover
- 45:11things down the road and a lot
- 45:13more work for everyone,
- 45:14but it's how the NIH budget,
- 45:16budget budgets their funding.
- 45:18I guess also one thing to notice
- 45:20here is when you look at your
- 45:21notice of one look at the budget,
- 45:23there is no inflation increase.
- 45:27So again,
- 45:28when you're budgeting your notice of award,
- 45:30when you're budgeting for your submission,
- 45:32think about that.
- 45:33There are ways that we handle
- 45:35that here at Yale.
- 45:37And then also if there is
- 45:39a reduction in your budget,
- 45:42you have to really think can you
- 45:44actually do the project with
- 45:46the with the reduction I've?
- 45:48Actually mentioned to API's where
- 45:50you know well can you do the work.
- 45:52This is a pretty. Pretty large restriction.
- 45:56Is there a reduction?
- 45:57Do you have to do a reduced scope?
- 45:59You know,
- 46:00I mean you might have to think
- 46:01about your staffing, you know,
- 46:02you know, you you really budget
- 46:04that postdoc in the first year.
- 46:06But in honest, in all honesty,
- 46:08it takes forever to get a postdoc these days.
- 46:10So you know you're not really going
- 46:12to spend that money in that first,
- 46:14you know,
- 46:15in the first six months.
- 46:16So that kind of banked that a little bit too,
- 46:18if you think about it.
- 46:18So there there's ways around
- 46:20the rebudgeting process,
- 46:21but again work with your business office.
- 46:24And then what else I think that was
- 46:27it for here? OK, moving on.
- 46:33OK. So we've mentioned a lot about you
- 46:36know the NIH grants policy statement,
- 46:38uniform guidance etcetera.
- 46:39What it a lot of it boils down to when
- 46:42you're thinking about spending on your
- 46:45awards are the cost principles and
- 46:47there's four tests to determine the
- 46:49allowability of a cost on your grant.
- 46:51It's reasonableness,
- 46:53which includes necessity.
- 46:54So an item has to be necessary for
- 46:57the completion of the project,
- 46:58but it also needs to be reasonable.
- 47:01And what reasonable means,
- 47:02when I think about it,
- 47:03is like a prudent person.
- 47:05What would a prudent person do?
- 47:06What would you not be embarrassed to
- 47:08see on the front page of a newspaper if
- 47:11your name and that dollar expenditure
- 47:13on a federal grant was described?
- 47:15So that's kind of what
- 47:18reasonableness boils down to.
- 47:20A more complicated concept is Alec ability,
- 47:23and it doesn't seem like it
- 47:25should be complicated, but it is.
- 47:27Applicability is,
- 47:28is there a clear line between your cost
- 47:30and that grant you're charging it to.
- 47:33So if it's your salary and it's an
- 47:35accurate representation of your effort,
- 47:37we have a clear line of applicability.
- 47:39If it's an administrative supply,
- 47:42there is no clear line of applicability.
- 47:44It's really hard to track how
- 47:46much administrative supply you're
- 47:48using on a particular grant.
- 47:50And that's why things like administrative
- 47:52supplies become F and a costs and
- 47:55it gets applied as a proportion.
- 47:57Of your direct cost,
- 47:59where eligibility gets kind of
- 48:01complicated is in a lab, you know,
- 48:03if you have a lab and you've got.
- 48:055 to 10 research grants supporting that lab,
- 48:08then you really have to think
- 48:10about how you're going to allocate
- 48:11specific costs amongst those grants
- 48:13that are supporting your lab.
- 48:15And I'll get into that a little bit more,
- 48:16but that's kind of the basis of allowability.
- 48:19Umm, consistency.
- 48:20This one is really just boiled down
- 48:22to we need to make sure at Yale
- 48:25we're treating costs consistently
- 48:27between direct and indirect.
- 48:29So that's why things that are normally
- 48:31indirect, we typically say no,
- 48:32that's already covered in the F and a base.
- 48:34That's something we put into that 67% rate.
- 48:37So we have to always remain
- 48:40consistent with that.
- 48:41Now in grants,
- 48:42we know that our biggest thing
- 48:44is it depends and it's Gray.
- 48:46So everything I say to you here.
- 48:49There's probably an it depends
- 48:51or an exception to that rule,
- 48:54and that's what your department
- 48:56business office will help you with.
- 48:58PFA like basically, at the end of the day,
- 49:01sometimes our jobs boil down to
- 49:03what can I defend in an audit,
- 49:05right, so we get audited,
- 49:07and I'll talk about that more later too.
- 49:10But that's all that's thinking in my mind.
- 49:1390% of the time when I'm answering
- 49:16questions for faculty members is
- 49:18can I keep us safe in an audit?
- 49:20Because I want to protect your
- 49:23funding and Yale's reputation.
- 49:25Conformance.
- 49:25So this is really allowance,
- 49:27does it conform with all of those policies?
- 49:29So going back to that triangle that we
- 49:32looked at and all those different layers
- 49:34of laws and policies and regulations,
- 49:36we have to be in conformance with that.
- 49:38So it's those four key things that we're
- 49:41thinking about anytime we're trying to
- 49:43charge something to a grant. Umm. So yeah.
- 49:48My favorite thing to tell faculty members,
- 49:52and this is straight from the
- 49:54NIH grants policy statement,
- 49:55the fact that a proposed cost is awarded
- 49:58as requested by an applicant does not
- 50:00indicate a determination of allowability.
- 50:02So I I at least five times a year
- 50:05I will have a faculty member say,
- 50:08but I put that in my budget.
- 50:10That's great, but did you get your budget
- 50:13to Amy at 4:00 o'clock on a Friday?
- 50:15Did anyone really look at that
- 50:18budget before it went in?
- 50:19As carefully as we should have or could have.
- 50:23And the people reviewing
- 50:24the applications at the NIH,
- 50:26they don't know they're looking
- 50:28at your science,
- 50:29they're not looking at the
- 50:30intricacies of your budget, right?
- 50:32Plus, they're not an expert
- 50:34on Yale's internal policies.
- 50:35So they might know their own NIH policies
- 50:38on budgeting or the uniform guidance rules.
- 50:41But again,
- 50:42Yale could be more strict in a certain
- 50:45aspect and and where that really comes
- 50:47down to is like what we include in our.
- 50:50Stephanie rate might be different than what
- 50:52Washington University in Saint Louis does,
- 50:54or Harvard or something like that,
- 50:56and then they don't know so.
- 50:58We're not trying to, you know,
- 51:00hamper your research in any,
- 51:02any way when we're telling you you
- 51:05can't charge something to your grant.
- 51:06We're trying to keep us from having an audit.
- 51:09Frightening. So.
- 51:12OK.
- 51:14So to piggy back on that,
- 51:16so I'm going to talk a little
- 51:18bit about awards management.
- 51:20So I took some excerpts out of a typical
- 51:24account holder report and you know.
- 51:28You should be you should be getting your
- 51:30account holder reports at least monthly.
- 51:32There's a guideline for by the
- 51:35Controllers Office to that effect.
- 51:37So if you are not, please ask those
- 51:39questions of your business office and
- 51:41you should be reviewing your expenses.
- 51:43You know is it correct?
- 51:46Sometimes things get charged
- 51:47inappropriately to the wrong grant.
- 51:49You know, do you have mouse charges?
- 51:51Did did someone enter the mouse charges on
- 51:55a on a grant that does not have an icon?
- 51:59And I cook. Sorry, sorry.
- 52:03So which has, which does happen,
- 52:06I've had that happen and you know,
- 52:07there's no, there's no stops either.
- 52:09So so your,
- 52:10your business office does do a
- 52:12high level review of these as you
- 52:14can see how many grants we have
- 52:17and then you think about how many
- 52:19people are in your business office.
- 52:20You know, it's, you know,
- 52:22it can be a lot, but also in this,
- 52:24in the case of the effort,
- 52:26which is right here,
- 52:27this is a telltale sign that
- 52:30something went awry.
- 52:32Where you have two staff effort on here and
- 52:35then you have zeros for two months well.
- 52:38Maybe someone wasn't charged for those
- 52:39two months and you could see that an
- 52:41adjustment was done in the next month.
- 52:43So you so you know you could you
- 52:45you could catch these as they as
- 52:47they come along you know you you
- 52:49are responsible for the expenses.
- 52:50Also on the on the on the expense
- 52:53side over here you know review these
- 52:55you know it looks like a lot this is
- 52:58more the high level detail but this
- 53:00is what I look at on a monthly basis
- 53:01when supporting a faculty member or
- 53:03or a portfolio I look at those very
- 53:05high dollars that are hitting the award.
- 53:07That doesn't make sense to me.
- 53:10Your business office is not going to
- 53:11know what you're doing in your lab.
- 53:12I can tell you that right now you know
- 53:14we we look at we we're just looking
- 53:16at the trends to be honest and and
- 53:18we should be meeting with you monthly
- 53:20again all business offices are different.
- 53:23If you if you have K award or maybe
- 53:25a smaller portfolio it might be
- 53:27quarterly or every other month.
- 53:29So which is totally fine too but as
- 53:32long as you're reviewing them and
- 53:33giving them your it's due diligence.
- 53:40All right. OK. OK.
- 53:42So just talking a little bit about
- 53:45actually charging to your grant,
- 53:48the first thing I'd like to
- 53:49talk about is Pi authorization.
- 53:52So that is a requirement that the faculty
- 53:54member is authorizing the charges that
- 53:56are posting to their grant, right?
- 53:58There is the exception to that which you
- 54:01can delegate your authority to someone.
- 54:05It has to be in writing and maintained
- 54:07within your Department business office
- 54:08and that should be someone with.
- 54:10Direct scientific knowledge
- 54:12of your grants being charged.
- 54:14So it it shouldn't be the
- 54:16Department business office,
- 54:17it shouldn't be an administrative
- 54:19assistant somewhere give you lab manager.
- 54:21Someone who is involved in the
- 54:23development of the grant budgets,
- 54:25understands the complexities of
- 54:26the funding that is supporting
- 54:28the science and able to make the
- 54:30determination of how those things
- 54:32should be charged to the grant.
- 54:34Allocation methodology needs.
- 54:37Yeah.
- 54:38Yeah. So a common thing that I
- 54:39got is what do you think, John?
- 54:41Well, I, you know, I'm not going to
- 54:43tell you how to charge your grants.
- 54:45I can tell you where your funds are.
- 54:46You know, I could tell you
- 54:48which accounts have funds,
- 54:49but I'm not going to make that determination.
- 54:51You have to make that determination
- 54:53in writing to me. Thank you.
- 54:56Sorry, no
- 54:58allocation methodology documentation.
- 54:59So this goes back to that example
- 55:02where you have a lab that's being
- 55:04supported by multiple grants.
- 55:05There is a policy that talks about
- 55:08what acceptable and unacceptable
- 55:09allocation methodologies are.
- 55:11It could be based on FTE,
- 55:13it could be based on actual usage.
- 55:16But basically at the end of the day,
- 55:18when the auditors come in and they,
- 55:19they ask, they see like a transaction
- 55:22that's been split evenly amongst 4 grants,
- 55:25they're going to ask me.
- 55:26How did you come up with
- 55:28this allocation methodology?
- 55:28And I'm going to come back and I'm
- 55:30going to ask you what did you do?
- 55:31And you're going to say,
- 55:32oh, I don't know,
- 55:33I have four grants,
- 55:34so I split it 1/4 to each grant.
- 55:36And I'm going to say I can't tell them that.
- 55:39So that's where we really need to
- 55:41make sure that prior to making
- 55:43an actual charge to a grant,
- 55:45you have this allocation methodology
- 55:48and documented and in writing.
- 55:50Now we go back to that concept of reviewing
- 55:53your account holder reports monthly.
- 55:56If if your business office is not
- 55:58meeting with you monthly and talking
- 56:00through those account holder reports,
- 56:02I would suggest saying,
- 56:03hey,
- 56:04why am I not getting this kind
- 56:07of customer service from you?
- 56:09Because that's that's really how
- 56:10you should be supported from your
- 56:12department business office and that's
- 56:14the perfect opportunity to look at.
- 56:16Here's the grants that you have.
- 56:18Do we have the delegation of
- 56:19authority updated for those grants,
- 56:21making sure that if someone is
- 56:23authorizing transactions besides you,
- 56:24we have that in writing and also the
- 56:27opportunity to readjust your allocations.
- 56:29Anything,
- 56:30yeah.
- 56:32I love the form.
- 56:33There's always a form for everything.
- 56:34That's all. I'm going there.
- 56:36And the and the allocation
- 56:38methodology is a larger form,
- 56:41but it, you know,
- 56:42we will ask for it when there are,
- 56:45when we see those split purchases
- 56:47or requisitions, I should say.
- 56:49A lot of things come down to
- 56:51documentation and justification.
- 56:52So I know that it's
- 56:54administratively burdensome,
- 56:55but the more data we can capture upfront
- 56:58to understand those four cost principles,
- 57:01you know, why does this relate
- 57:03to this particular grant?
- 57:05What can we say about it in a narrative
- 57:08form and include on a transaction
- 57:10that just just puts it all right
- 57:13there from an audit perspective.
- 57:15Anything that can be looked
- 57:17at as a standalone document,
- 57:19then we're not going to come
- 57:20bother you about it later.
- 57:21But when an auditor pulls a transaction
- 57:23and there's no documentation and
- 57:25no justification to support it,
- 57:27we're going to come back to you and say,
- 57:28what were you thinking two years
- 57:30ago on a Tuesday when you bought
- 57:32$5 worth of whatever I mean,
- 57:34and it really does get down to that,
- 57:36which is unfortunate.
- 57:38Yes.
- 57:40How do you?
- 57:45Or spots contacts instead.
- 57:50Contracts versus grants.
- 57:51So if it's a if it's on a GR work tag,
- 57:57if you have a an award or a grant work tag,
- 58:00it's it's all going to be very similar.
- 58:02So whenever we talked about that
- 58:05consistency on those key principles,
- 58:09we have to make sure we have consistent
- 58:12practices across all of our funding.
- 58:13So there really isn't a lot of difference.
- 58:16We might be able to make certain
- 58:19exceptions when funding is private versus
- 58:20federal and even then we don't like.
- 58:23To do that,
- 58:24because you could charge something,
- 58:26you could purchase something and
- 58:27split it between two different sources
- 58:29of funding or transfer it later,
- 58:31which we don't like but but.
- 58:34So that's why we can have really
- 58:37consistent practices across all.
- 58:39I also find this frustrating because I
- 58:41just tried to get a consultant hired
- 58:42and I am not supported with federal
- 58:44funds or grants in any capacity and I
- 58:47still had to jump through all the hoops.
- 58:49Yeah I mean the the system work,
- 58:52they system it's it's the same
- 58:54process to charge whatever.
- 58:56It just as long your your business office
- 58:58or what we call the 1K approver has the
- 59:01correct charging in the first review.
- 59:03They will be able to either bounce it back
- 59:05if if they're if they notice the error.
- 59:08But as long as you have to really
- 59:10send that e-mail and say I want
- 59:12it charged to this grant,
- 59:14you may not know the number but as
- 59:15long as there's a common name there
- 59:17from the business Office perspective.
- 59:19That that works on our end.
- 59:20The only thing that I would say the caveat
- 59:22is you have to make sure that there is
- 59:25no restrictions on your grant, right.
- 59:26So that was go back to the your notice of
- 59:28award to make sure there's no restrictions.
- 59:30And for federal contracts as opposed to
- 59:34federal grants or cooperative agreements,
- 59:37there can be more restrictions.
- 59:39They are a bit more restrictive.
- 59:41So just throwing that out there. It's
- 59:44Gray. It's all Gray.
- 59:46Things something gets charged for granted.
- 59:48It's not allowed, right?
- 59:49Whether it's six months down the line
- 59:50or four years down the line or not,
- 59:52that's called a cost transfer.
- 59:57It's going to your
- 59:59department business office,
- 01:00:00so that would also be your in certain cases.
- 01:00:05I I like in my view,
- 01:00:07and this is only my opinion,
- 01:00:08it you know who's what happened you
- 01:00:10know did the faculty know about it?
- 01:00:13Did they were they the ones that pushed?
- 01:00:14Then the faculty should eat it, right?
- 01:00:16It would go to a startup if you know but
- 01:00:19if it was business officer well maybe.
- 01:00:22The department will eat it,
- 01:00:23or the section,
- 01:00:24or however your business office is set up,
- 01:00:26but it really comes down
- 01:00:27to culpability, yeah.
- 01:00:32Generally. Specific advice about the
- 01:00:36kinds of things beyond the science that
- 01:00:38are allowable there was like education.
- 01:00:42That might not be applicable.
- 01:00:45Yeah, so. So keywords are very special
- 01:00:50and I and quite honestly I've got
- 01:00:52the documentation in front of me.
- 01:00:53I'm not sure either of the three
- 01:00:56of us can can speak to it directly,
- 01:00:59but if there are specific cost categories
- 01:01:01that you're only allowed to budget within,
- 01:01:03those are what you're restricted
- 01:01:05to spend with it, right?
- 01:01:06And so I can have a private conversation
- 01:01:09with you that you know may help.
- 01:01:12I wish I could pull it out of the air
- 01:01:14for the for the group, but I just can't.
- 01:01:16We had a K award matrix in here.
- 01:01:19Like every single K mechanism
- 01:01:22has a different.
- 01:01:23Standard of what it it supports
- 01:01:27and when I think about K words,
- 01:01:29I really, you know go back to like
- 01:01:30what is the intent of the K word.
- 01:01:32I mean it is to get you into an R1,
- 01:01:35right?
- 01:01:35So it's it really does boil down
- 01:01:37to the majority of things would be
- 01:01:40anything that supports your career that
- 01:01:42research that you're working on in
- 01:01:44order to get you to that next level.
- 01:01:46And that should be in the funding
- 01:01:48announcement more or less because it will
- 01:01:50tell you what you can and cannot do.
- 01:01:52That's part of a special term
- 01:01:53and condition and K word.
- 01:01:54I've noticed that there's like travel
- 01:01:56to certain meetings and you know,
- 01:01:58presenting at certain things.
- 01:01:59So you know, those are those
- 01:02:01are direct examples maybe.
- 01:02:06OK. So going back to charging to your award,
- 01:02:09I highlight a few things, travel,
- 01:02:11procurement and subrecipient monitoring.
- 01:02:14The reason why I highlight these
- 01:02:16is that this tends to be where the
- 01:02:19auditors like to poke around in travel
- 01:02:21because you know anything that has an
- 01:02:24intricate policy and travel usually
- 01:02:26does is a great place for auditor to
- 01:02:29auditors to find us making mistakes.
- 01:02:32One of the key things about.
- 01:02:35Travel is the Fly America act.
- 01:02:37I think this is one of those things that,
- 01:02:38like, hangs people up more often than
- 01:02:40not because you think, Oh my gosh,
- 01:02:42I'm going to fly to England for this
- 01:02:45conference and the cheapest thing to
- 01:02:46do is fly on British Airways and then
- 01:02:49all of a sudden you're in violation
- 01:02:51of the Fly America Act because,
- 01:02:53you know, long, long time ago when the
- 01:02:57airline industries were in trouble,
- 01:02:59I president decided that we needed
- 01:03:02to fly on American Airlines.
- 01:03:04So no regard to today's world,
- 01:03:07but it is a federal law and
- 01:03:08we have to follow it.
- 01:03:09So I always tell people,
- 01:03:10if you're paying for something
- 01:03:12on federal funds,
- 01:03:13the easiest thing to do is just
- 01:03:15fly an American air carrier.
- 01:03:16There are open skies agreements.
- 01:03:18I won't get into those today because I
- 01:03:21need a matrix and it's it's ridiculous.
- 01:03:24I could speak for an hour on it but
- 01:03:27so we do have training through OSP so
- 01:03:31I'm not you're you're welcome to take
- 01:03:34that but your staff that potentially
- 01:03:36is booking your travel should have
- 01:03:38taken it OK or suggest that they do.
- 01:03:41I always suggest any admin that's
- 01:03:43booking travel on your behalf take
- 01:03:45that training they may not get it.
- 01:03:47But you know again, talk to your.
- 01:03:51Business office and again.
- 01:03:53Ask for help, not for forgiveness.
- 01:03:56Yeah, I mean, I think that's the key, right?
- 01:03:58It's we're trying to give you a highlight
- 01:04:00of things to like keep in the back
- 01:04:01of your head when it comes up to go
- 01:04:03talk to your business office, right,
- 01:04:05because you've got better things to do,
- 01:04:07which is your science.
- 01:04:08So it's just we don't want you to
- 01:04:10get in trouble. So if you do have
- 01:04:12to fly and it's to another country,
- 01:04:13talk to your department business
- 01:04:15office before you book that flight.
- 01:04:17Procurements, another tricky
- 01:04:19place with uniform guidance.
- 01:04:21They put in a lot of rules and restrictions
- 01:04:24on procuring goods and services.
- 01:04:27Mostly you'll hear something called
- 01:04:29a micro purchase threshold and and
- 01:04:31so basically it sets enforce all
- 01:04:33these rules that say that if you know
- 01:04:35you're entering into an agreement
- 01:04:37over 10,000 then we have to have
- 01:04:39competitive bids like we're basically
- 01:04:41trying to protect the money and
- 01:04:42making sure that we're paying the
- 01:04:44best price for the good or service.
- 01:04:46Um, so our procurement office,
- 01:04:48you have to jump through a lot
- 01:04:50of hoops in order to do things.
- 01:04:53Anything over $10,000 subrecipient monitoring
- 01:04:56is another place where I feel like we,
- 01:05:00you know,
- 01:05:00hit a lot of audit tricky things.
- 01:05:03So we're giving money to
- 01:05:04another institution to do work.
- 01:05:06So basically it means that you as
- 01:05:08the faculty member need to keep
- 01:05:10good tabs on what your sub is doing
- 01:05:12programmatically and financially,
- 01:05:14like if it's six months goes by
- 01:05:16and they haven't billed.
- 01:05:17But you've heard from talking to your
- 01:05:19colleague that they've actually done,
- 01:05:20you know,
- 01:05:21some of the scientific work
- 01:05:22that you've asked them to do.
- 01:05:23You need to be asking them to
- 01:05:25prompt their people to give you an
- 01:05:26invoice so that we can pay for it.
- 01:05:28And from the business Office perspective,
- 01:05:31I add that you are signing
- 01:05:33off on that invoice,
- 01:05:35not the business Office does,
- 01:05:36but you are the first approver.
- 01:05:39And also look at the line item budget.
- 01:05:41I've had to kick back invoices
- 01:05:44because they had a post.
- 01:05:46Or some or someone on that that really
- 01:05:48shouldn't have been there in the 1st place.
- 01:05:51Also pay attention to the
- 01:05:53Pi on the invoice there.
- 01:05:54I can't tell you how many times I
- 01:05:57received an invoice from another
- 01:05:59institution with the wrong Pi so
- 01:06:01which would also have to get picked.
- 01:06:03Kick back and please answer
- 01:06:05that e-mail from your business
- 01:06:06office as soon as you get it,
- 01:06:08because that invoice has to be paid
- 01:06:10within 30 days.
- 01:06:13Yeah. Institutions got mad because
- 01:06:15nobody was paying anybody else on time.
- 01:06:17So now there's rules about having
- 01:06:19to pay each other within 30 days,
- 01:06:21almost unachievable, right?
- 01:06:23So. So cost transfers. Why?
- 01:06:26Why do we care about cost transfers?
- 01:06:28I think it's the single biggest
- 01:06:30auditable issue at the university.
- 01:06:33It's really easy for an auditor to
- 01:06:34come in and say show me all of the
- 01:06:36cost transfers that have occurred.
- 01:06:38And why do they want to do that?
- 01:06:39Because that means we didn't
- 01:06:40get it right the first time.
- 01:06:41So we had to take that.
- 01:06:43That charge and put it somewhere else.
- 01:06:45What that can mean is that if
- 01:06:47we put that charge on a grant,
- 01:06:49well my office went and drew
- 01:06:50down funding from the federal
- 01:06:52government to cover that charge.
- 01:06:53So we've been sitting on their money when
- 01:06:56it really wasn't their charge to pay for.
- 01:06:59So we do look at cost transfers
- 01:07:01volumes is it is an indication
- 01:07:03that we've got a problem and again
- 01:07:05going back to you know reviewing
- 01:07:07your transactions monthly with
- 01:07:09your department Business Office
- 01:07:10on those account holder reports.
- 01:07:13We should be catching things timely,
- 01:07:15so any cost transfers that are happening
- 01:07:18late is an even bigger problem for us.
- 01:07:20And there could be a great reason for that.
- 01:07:23You know, if an award was set up
- 01:07:25late and you have to go back to
- 01:07:27the start date because of IRB
- 01:07:28protocol not being set up timely,
- 01:07:30that that's a that's a legit cost
- 01:07:32transfer has to be documented
- 01:07:34though you also have to approve it.
- 01:07:38Another pitfall is spending in
- 01:07:39the last 90 days of your award.
- 01:07:41That's another really easy thing
- 01:07:42for an auditor to come in and say,
- 01:07:44show me all the transactions that
- 01:07:46happened in the last 90 days.
- 01:07:47Why do they care?
- 01:07:48Because if you buy a piece of
- 01:07:50equipment in the last 90 days, well,
- 01:07:52it really didn't benefit the budget
- 01:07:54period you just charged it to.
- 01:07:55You're buying it because you had money
- 01:07:57left and you don't want to lose that money,
- 01:07:58which is not lawful,
- 01:08:01allowed or per regulations.
- 01:08:04So, you know, we're just trying to make sure,
- 01:08:06again, reviewing your account.
- 01:08:08Holder reports, that's just like
- 01:08:09looking at your checking account, right.
- 01:08:11You're looking at how much money do I
- 01:08:13have left to spend over how much time.
- 01:08:15So we want to avoid having big
- 01:08:18balances in the end and trying
- 01:08:19to spend those down because we
- 01:08:21will have to pay them back
- 01:08:22and you should be meeting with
- 01:08:24your business office portfolio
- 01:08:26analyst 90 days prior to the end.
- 01:08:28So you could kind of look at these items.
- 01:08:30You know, you know you don't,
- 01:08:31we don't want to leave any
- 01:08:32money on the table either,
- 01:08:33but we also want to spend appropriately and
- 01:08:36there could be different reasons for that.
- 01:08:38With COVID taught us anything,
- 01:08:40it's, you know, spending kind of
- 01:08:41goes out the window at some point,
- 01:08:43as does budgeting, apparently.
- 01:08:45So, you know, really pay attention to that.
- 01:08:50And the last bullet point here is that,
- 01:08:52I mean yes, we get $1,000,000
- 01:08:55grant coming in the door,
- 01:08:57that's a promise of funding,
- 01:08:59not we don't get $1,000,000 check on day one.
- 01:09:02I get asked this question all the time.
- 01:09:04We don't get reimbursed until you spend it.
- 01:09:06So at the end of the award,
- 01:09:08it's not like we're sitting on
- 01:09:10$100,000 if you know you have $100,000
- 01:09:12left in your budget.
- 01:09:13We never got that money, it's not here.
- 01:09:17That could be different from non federal
- 01:09:19sponsors funders so we we we may get a
- 01:09:22check up front so it you know Christina
- 01:09:25specifically talking to federal.
- 01:09:26So Nick how's our time?
- 01:09:29We have about 10 slides.
- 01:09:31Are we good are we there's so much
- 01:09:32information we want to share we really
- 01:09:34we're just pouring everything out here.
- 01:09:37OK, we're gonna have this.
- 01:09:39Rick just cancelled.
- 01:09:41Who's going to talk about some of her
- 01:09:43experience talking with the program?
- 01:09:44OK, why don't
- 01:09:45we go to that slide?
- 01:09:47The program office like when?
- 01:09:48Let's see, what do we have? Let's see.
- 01:09:51Our approval request, here we go.
- 01:09:54So the people that you deal most
- 01:09:56often with or that you know,
- 01:09:58we're more most familiar with at
- 01:10:00the NIH is your program officer and
- 01:10:02your grants management specialist.
- 01:10:04So what we call PO and the GMs,
- 01:10:07they have different roles at the
- 01:10:08NIH and I took this information
- 01:10:10right off the NIH site, OK.
- 01:10:13So I'm not making it up.
- 01:10:14So the people PPO roll,
- 01:10:17they're basically going to help you
- 01:10:19with the scientific guidance right
- 01:10:20throughout the life of your of your award.
- 01:10:22Umm, and they're monitoring programmatic,
- 01:10:25scientific and or technical aspects.
- 01:10:28They generally do not get involved
- 01:10:31with the financial component.
- 01:10:33That is all for from the GMs, OK.
- 01:10:36The GMs is the individual that will
- 01:10:40say will handle all the prior approval
- 01:10:43requests including carryovers,
- 01:10:45rebudgeting, etcetera.
- 01:10:47The GM should only be contacted by those
- 01:10:50who are considered AOR or authorized
- 01:10:53organizational representatives and
- 01:10:55AOR's are from OSP within our office.
- 01:10:58Those are designated individuals
- 01:11:00within OSP who serve as a liaison
- 01:11:03on behalf of the university, OK.
- 01:11:06And generally most of them also have
- 01:11:09signing authority that have has been
- 01:11:11given them by Yale Corporation.
- 01:11:13All right.
- 01:11:14So if you send something to a GMs,
- 01:11:16they may say. Alright, that's OK.
- 01:11:19But I need your AOR to concur.
- 01:11:21Nothing will happen until the
- 01:11:24AOR from my office, you know,
- 01:11:26sends an e-mail back and says I concur.
- 01:11:28All right,
- 01:11:28so they want us to be aware of everything
- 01:11:31that's happening on your rewards.
- 01:11:33Alright,
- 01:11:33so we're really the point people there,
- 01:11:35your PO's,
- 01:11:36you absolutely are free to speak to
- 01:11:38your PO's about scientific concerns,
- 01:11:41progress, questions, whatever,
- 01:11:42all right,
- 01:11:43but the GMs contact should only
- 01:11:46go through our office.
- 01:11:48OK.
- 01:11:49And I could say there is a reason for that,
- 01:11:51at least from my standpoint.
- 01:11:52It's because the money received
- 01:11:54from the federal federal
- 01:11:56government belongs to Yale.
- 01:11:57Although the faculty think
- 01:11:58it belongs to them, they're,
- 01:11:59they're able to spend the money on
- 01:12:01behalf of Yale. Yes,
- 01:12:04yeah. Do you concur?
- 01:12:06Thank you. Thank you.
- 01:12:08OK, let's see what else we can do
- 01:12:11to move this along reducing efforts.
- 01:12:13So all of you on your key awards,
- 01:12:16you all have minimum required effort.
- 01:12:18It's one of the caveats of OK award.
- 01:12:21The federal and non federal sponsors,
- 01:12:23they have different thresholds,
- 01:12:24they may have different policies,
- 01:12:26but we're going to talk
- 01:12:27specifically about the NIH.
- 01:12:28They require prior approval
- 01:12:30for any reductions in effort
- 01:12:32equaling or greater than 25%.
- 01:12:35Cumulative over the life of the award. OK.
- 01:12:37So for K award recipients in particular,
- 01:12:41you have to maintain your effort
- 01:12:43throughout the life of the ward,
- 01:12:44including the no cost extension
- 01:12:46period if you should request one.
- 01:12:48All right.
- 01:12:49And it's specifically spelled
- 01:12:50out within both the solicitation,
- 01:12:53the FOIA funding opportunity
- 01:12:54announcement and the Noah.
- 01:12:56All right.
- 01:12:57Umm,
- 01:12:57the effort that is required is different
- 01:13:00from mentored and non mentored K awards.
- 01:13:03So again,
- 01:13:04your.
- 01:13:05Information will be in both the FOIA
- 01:13:08and the Noah and PI's and mentored K awards.
- 01:13:12You can reduce your level of effort
- 01:13:15in the last two years if you have
- 01:13:18successfully competed for and won
- 01:13:20a peer review research award.
- 01:13:22Generally that would be your R1.
- 01:13:23It also can be a non federal all right,
- 01:13:26but you should be having conversations
- 01:13:28with your PO about that and any
- 01:13:30prior approval for reducing effort
- 01:13:31will be addressed specifically in
- 01:13:33your Noah and this is where we say.
- 01:13:35It depends or it's Gray.
- 01:13:37It is very project specific.
- 01:13:38It is very fact dependent.
- 01:13:40So we would have to have that
- 01:13:42conversation one-on-one.
- 01:13:43OK, again, read your Noah.
- 01:13:45That is where a lot of the information
- 01:13:47that you need to know specific
- 01:13:48to your ward is going to live.
- 01:13:50OK. We want to stop the question.
- 01:13:53All right.
- 01:13:54You want to wrap
- 01:13:56up? We wrap up.
- 01:13:59OK.
- 01:14:01You have, so do you have any question?
- 01:14:04So can you make our slides available
- 01:14:05to the group so that if they
- 01:14:07they go through that they have
- 01:14:08questions, they can come to us?
- 01:14:11Let's say so. We do have
- 01:14:14two questions about fringe.
- 01:14:16Do we pay fringe on hourly paid students?
- 01:14:20Yes. And then why are the
- 01:14:23fringe rates difference for the
- 01:14:24different grant mechanisms?
- 01:14:27Different grant mechanisms.
- 01:14:30Non federal had a different grant,
- 01:14:32different French, non federal. Same
- 01:14:35right for non federal it's different
- 01:14:39because it's we have to abide by
- 01:14:41the federal rate agreement and
- 01:14:43that's they're saying for the
- 01:14:44pots of money that we give you.
- 01:14:46So it's only specific to federal.
- 01:14:48So we're not bound for all the sponsors.
- 01:14:54In terms of that.
- 01:14:58In terms of sort of spending
- 01:15:00appropriately for the the year
- 01:15:02versus the duration of the award,
- 01:15:04is that you have to spend each
- 01:15:06yearly amount or is it you and
- 01:15:08that doesn't roll over or is that
- 01:15:09you have to use up the amount?
- 01:15:12It depends. Sure. I guess just
- 01:15:16like federal awards like DoD or
- 01:15:19like NIH based, it still depends.
- 01:15:22It depends on the award itself.
- 01:15:24So awards come in with either
- 01:15:27automatic carryover or carryover
- 01:15:28requires prior approval.
- 01:15:30So if your award comes in
- 01:15:32with automatic carryover,
- 01:15:33we just roll that over and at the end
- 01:15:35of your five year competitive segment,
- 01:15:38if you're getting a second five
- 01:15:40year competitive segment at the
- 01:15:42time we file the Fr that goes
- 01:15:44automatically to your new award.
- 01:15:47There's an amount right over
- 01:15:49certain amount may still need
- 01:15:51to read yes on your RPR.
- 01:15:55And someone who's taking all
- 01:15:56the questions, yes, yes.
- 01:15:58So on the RPR there is a G10,
- 01:16:01I know it by heart.
- 01:16:03It does say that if you're over
- 01:16:0625% threshold plus carryover from
- 01:16:07the prior year of remaining funds
- 01:16:09anticipated at the end because we're
- 01:16:11not at the end of the at the end of
- 01:16:14the that award segment for year,
- 01:16:16I should say,
- 01:16:17then you would have to re almost
- 01:16:19rebudgeting those things.
- 01:16:21And I just want to caveat that that.
- 01:16:24If you estimate it to be under 25%,
- 01:16:27the NIH will look at how much money
- 01:16:30we've drawn down in their cash system.
- 01:16:32And if that does not agree,
- 01:16:34they come back to us and say you said this,
- 01:16:37but you still see this,
- 01:16:39we see this and so that will that's
- 01:16:41going to be a question that we comes
- 01:16:43back to the award managers in the form
- 01:16:46of a pram after you submit your PR.
- 01:16:48So you know we may have to reconcile
- 01:16:50that with just an explanation like well
- 01:16:52our sub award hasn't built, you know.
- 01:16:55Board institution hasn't billed
- 01:16:56and and so here's the difference.
- 01:16:58But by our accounting this is what we
- 01:17:01see and generally without getting too
- 01:17:03detailed they will accept that answer.
- 01:17:06They don't want to see big carryover requests
- 01:17:08because they want to make sure that you are.
- 01:17:10We're spending the money as we told them
- 01:17:12we would and if they say but you're,
- 01:17:15you know, you're only spending half
- 01:17:16of what we are giving you every year.
- 01:17:18Why right, because maybe they're not.
- 01:17:20They're going to say,
- 01:17:21well you know you don't need that money.
- 01:17:22We're going to take that away.
- 01:17:24And we're gonna give it to
- 01:17:25somebody else who doesn't need it,
- 01:17:26right?
- 01:17:26So,
- 01:17:27and that should be in your
- 01:17:28progress report, right?
- 01:17:28So if you say, well,
- 01:17:29I'm having trouble hiring a postdoc,
- 01:17:31it would be an excellent example.
- 01:17:33So that should go into your
- 01:17:34RPR so that they read it.
- 01:17:35Be very specific,
- 01:17:37be very detailed in your RPR.
- 01:17:40So that you don't get those questions
- 01:17:42that can cut your next year of funding
- 01:17:44if your carryover looks too big.
- 01:17:47So it's good to not build up a stockpile.
- 01:17:52Without a good justification.
- 01:17:57One question. With you.
- 01:18:04So you mentioned that for salaries,
- 01:18:07NIH doesn't. Allow for raises,
- 01:18:10then does that mean that
- 01:18:12we when we're budgeting,
- 01:18:13then we should just keep the salary
- 01:18:15constant from year one through 5, so that?
- 01:18:17If the grant has a maximal amount,
- 01:18:20then we can raise it out. So we are.
- 01:18:22The recommendation OSP is that you go in at
- 01:18:26your institutional base salary for year one.
- 01:18:30But you you can ask for incremental
- 01:18:33raises for for the outgoing years.
- 01:18:36However, there are some agencies
- 01:18:38that say we will not increase.
- 01:18:42I think NHLBI is one of them
- 01:18:44and there's another one I can't
- 01:18:45think off the top of my head.
- 01:18:47So it could be very agent,
- 01:18:49agency specific that says we do
- 01:18:51not give incremental increases in
- 01:18:53salaries in the outgoing years.
- 01:18:55We cannot increase fringe.
- 01:18:57We are bound by the current fringe rate.
- 01:19:00So we can't increase fringe,
- 01:19:02but we can put in when allowable increases.
- 01:19:06And their salary now are
- 01:19:08the guidance from OSP.
- 01:19:09And this comes from my executive director,
- 01:19:11who is my boss.
- 01:19:12Because salaries are often the
- 01:19:14largest part of a grant application,
- 01:19:16we should ask for that money unless
- 01:19:19we have NHLBI and they say, no,
- 01:19:21we're not giving it to you, right,
- 01:19:22because we want to make sure we
- 01:19:24have those pots of money available,
- 01:19:26right.
- 01:19:26I don't want to pour that all into
- 01:19:28materials and supplies because they're
- 01:19:29going to look at that and say you
- 01:19:32padded your materials and supplies.
- 01:19:33What are you going to do with this money,
- 01:19:35right, that we never want to pad?
- 01:19:36Budget category.
- 01:19:37So we should be asking appropriately.
- 01:19:40I would always recommend,
- 01:19:42but it becomes your tolerance threshold
- 01:19:45because if they cut a budget because of
- 01:19:48funding limitations within that agency,
- 01:19:50they likely will come after your
- 01:19:52salary increment increases.
- 01:19:54First it's low hanging fruit.
- 01:19:57So what's your tolerance level there?
- 01:19:58You have to decide how you
- 01:20:00want your budget right?
- 01:20:01So it's it's really kind
- 01:20:03of a a decision for the Pi.
- 01:20:05Definitely talk to your pre ward.
- 01:20:06People,
- 01:20:07you can talk to OSP to get a recommendation,
- 01:20:10but it really at the end of the day,
- 01:20:12it's your budget and you get to submit it.
- 01:20:15You know, based on some you know limitations,
- 01:20:18the way you see fit to support
- 01:20:20the work that you are proposing.
- 01:20:23OK.
- 01:20:26All right. Thank you so much,
- 01:20:27everyone. We appreciate your time.
- 01:20:31Family is going to share a
- 01:20:32little bit about her experience
- 01:20:34working with program officers.
- 01:20:38Yeah, you can. Yeah, you can turn around.
- 01:20:42Did you typically follow their
- 01:20:46guidance? Services GMs. Well,
- 01:20:49I wish I had heard this talk at earlier.
- 01:20:54So I'm not in the party. Neurology.
- 01:20:59By train. Started on that.
- 01:21:05A little while.
- 01:21:09I've called foundation grants. Later.
- 01:21:16Yeah, program officers.
- 01:21:22Happened to share those experiences.
- 01:21:24So I think you've heard a lot from
- 01:21:26getting about the life cycle of the grant
- 01:21:29and all the various people involved,
- 01:21:30and I did talk right from the beginning.
- 01:21:34I'm sorry about the ideas offer,
- 01:21:36get feedback about my concept,
- 01:21:38make sure there was problematic interest.
- 01:21:42Between my first and second
- 01:21:44Phase Commission going over all
- 01:21:46the comments in detail and one
- 01:21:49program officer is really helpful,
- 01:21:51not just in each corporate.
- 01:21:54But also in helping me brainstorm
- 01:21:56and strategize ways to.
- 01:21:59Really helpful. That was really helpful.
- 01:22:03Along the way I was promoted from
- 01:22:05assistant to associate to navigating
- 01:22:07some of the things like taking out
- 01:22:09of believe what to do with my brand.
- 01:22:12Ohh, John Blackman, his giant giant
- 01:22:15actually handled a lot of those.
- 01:22:21Yeah. In the morning.
- 01:22:27We had lots of conversations about
- 01:22:28how to handle some of these things.
- 01:22:30I would, you know,
- 01:22:32grateful to receive another major award.
- 01:22:35Not that long ago, the product handle won
- 01:22:38awards starting before my savings that
- 01:22:40people were going to end Sunship effort,
- 01:22:42we're going to really start date.
- 01:22:44So how to handle.
- 01:22:46Grand was another reason why I talked
- 01:22:49to my program officer fight a lot.
- 01:22:52Yeah, those are the major things.
- 01:22:54I talked to my other officer along the way,
- 01:22:56of course, questions that came up.
- 01:23:00So happy to talk about answer questions,
- 01:23:03talk about anything that would be
- 01:23:04helpful for people here. The later stage.
- 01:23:13Did you have to talk to your GMs at all or?
- 01:23:17Interesting. Mentioned the more you know. OK.
- 01:23:25So I talked to John and we would
- 01:23:27talk about program officer for some
- 01:23:29interpretation of what they were
- 01:23:30actually asking for that was separate
- 01:23:32from what was in my progress report.
- 01:23:34So I've had some limited interaction
- 01:23:37with my stage primarily.
- 01:23:41It's a USB.
- 01:23:46Now, has it been the same program officer
- 01:23:48since you first applied for your day?
- 01:23:54While some of the other
- 01:23:55staff actually have changed,
- 01:23:57the Ms is actually really helpful to
- 01:24:00have that front moving. You know,
- 01:24:04it's actually helpful to talk to
- 01:24:06my program officer about what the
- 01:24:07plans are for current officers.
- 01:24:08Directed me to, you know,
- 01:24:10funding mechanism with other
- 01:24:12program officers below.
- 01:24:20A little bit I'm trying to figure out.
- 01:24:22OK, is that somebody?
- 01:24:25Like when I, I transferred my case here,
- 01:24:27I work with the GMs person
- 01:24:29a lot in that process,
- 01:24:30and now I'm looking at a supplement
- 01:24:33that my program officer recommended.
- 01:24:35But there's a lot of confusion around the
- 01:24:37start and end dates of that supplement
- 01:24:39as it pertains to my K and so she had
- 01:24:42recommended that we reach out to the GMs.
- 01:24:44But I see that really only our
- 01:24:47AOR can reach out to that person.
- 01:24:49And so I don't know if this is like too
- 01:24:51specific, but I'm trying to figure out.
- 01:24:53So who's the GMs for something that's.
- 01:24:56Build just a posted opportunity
- 01:24:57versus a GMs that might be assigned
- 01:25:00after you're awarded.
- 01:25:04Just ask Jack, right? Yeah,
- 01:25:06I figured there would be one or two.
- 01:25:08So and so when you have a supplement,
- 01:25:12what will happen is that it's going to
- 01:25:14be an annual supplement, but it's also
- 01:25:16going to be funded on the award years.
- 01:25:18So you could if say it's applied for
- 01:25:21your grant goes from July through June,
- 01:25:23but your supplement is from
- 01:25:27September through August.
- 01:25:29So then the supplement will be awarded
- 01:25:31half on one year and the other.
- 01:25:34Section on the other year. So.
- 01:25:35So the GM, that's what the GM should say.
- 01:25:38That's how I've noticed all
- 01:25:40supplements working in my career.
- 01:25:41So I I mean it just,
- 01:25:44I get budget accordingly.
- 01:25:45That's all I'm going to say.
- 01:25:46But it's it's again,
- 01:25:48it's also treated differently in
- 01:25:50the Yale system where it's tracked
- 01:25:52separately because the funding is
- 01:25:54drawn down from the NIH separately
- 01:25:56from the actual full award.
- 01:25:58So it's really kind of two awards.
- 01:26:00Yeah.
- 01:26:01Is it that it is administrative
- 01:26:03supplement or a diversity supplement?
- 01:26:07Officers saying that.
- 01:26:13Yeah, OK.
- 01:26:18Someone.
- 01:26:21She said, Ohh, talk to the GM. SI was like,
- 01:26:24yeah, I I think we actually have a
- 01:26:26someone who did that in Pediatrics.
- 01:26:29I don't remember someone actually
- 01:26:31applied for that. You know, we,
- 01:26:32we chat after this and then yeah.
- 01:26:38We are not allowed to contact the
- 01:26:41GMs from the Business Office.
- 01:26:45Your faculty do what you want.
- 01:26:49Now that they're gone,
- 01:26:49I can say what I want to say.
- 01:26:54I will say that I've got emails
- 01:26:56from separately but in the response
- 01:26:58back I didn't run it through the
- 01:27:01business office offer letter.
- 01:27:11Does everybody know who
- 01:27:12their program officer is?
- 01:27:16We work with that program officer.
- 01:27:19It sounds like you have a great program.
- 01:27:32Not sure what to do.
- 01:27:35I I've heard that other program
- 01:27:36officers or sometimes not as
- 01:27:37helpful at all where it's sort
- 01:27:39of you're the guidelines,
- 01:27:40go ahead and follow them and come back to me.
- 01:27:42Would not happen.
- 01:27:43It sounds like more you're more of a
- 01:27:45mentorship experience in some way.
- 01:27:48He is an expert in the field.
- 01:27:51Able to offer you know probably some
- 01:27:54insight and guidance that maybe
- 01:27:56you know for other projects.
- 01:28:08Some things ahead of time.
- 01:28:12Little on the way that makes the interaction.
- 01:28:19Any other questions?
- 01:28:22Stay around.
- 01:28:26Thank you.