Research Administration Forum February 3, 2009
Dec 21, 2015
What is new in Research Administration?
Dick Seligman
new Research Administration Website Yale University Settlement Audit update new Export Compliance policy Restricted Party Screening Agency updates Future Training Sessions Answering questions
Yale University$7.6 Million Settlement
Multi-year investigation by Federal agencies
DHHS OIG NSF OIG DOE OIG DOD DCAA NASA OIG FBI
Yale University$7.6 Million Settlement
Period covered:January 2000 – December 2006
$3 Billion in Federal grants
Basis of the settlement: $3.8 Million “actual damages” $3.8 Million “penalties”
Yale University$7.6 Million Settlement
Issues Improper Cost Transfers Salary charges to grants must reflect
actual time and effort spent So what?
Wake-up call for the rest of us Heightened scrutiny
Audit Update FY2008 A-133 Audit conducted by
PricewaterhouseCoopers (PwC) Cost sharing Financial reporting Payroll distribution confirmation reports
DCAA FY2007 Incurred Cost Proposal (ICP) Audit Financial reports submitted by Project Accounting Award summaries and sponsor invoicing
DCAA FY2008 Interdivisional Cost Transfer Audit Caltech expenditures and invoicing of JPL awards
Audit Update
DCAA FY2008 MAAR 5 (Mandatory Annual Audit Requirement) Refunds and credits due to JPL/NASA
Lawrence Livermore National Laboratories (LLNL) Agency Award Audit Caltech expenditures and invoicing of LLNL
contract
Other Audit Requests
Reference: http://www.whitehouse.gov/omb/circulars/a133/a133.html
Institute Policy AnnouncementTo: The Caltech Community
From: Jean-Lou Chameau
Subject: Compliance with Export Laws and Regulations
Federal laws and regulations concerning export, import and financial transactions involving sanctioned or embargoed countries have existed for many years. The events of September 11, 2001, and subsequent events around the world have pushed national security concerns to the forefront. The government has responded by tightening the export control regulations that govern the transfer of strategic technology for national security and foreign policy reasons.
Export control laws are intended to control the transfer of sensitive information or goods to individuals, entities, or countries of concern and, under certain conditions, to foreign persons. The regulations contain a fundamental research exclusion and specific university exemptions that allow most of the research activities being performed at Caltech and at other U.S. universities to be carried out without the need for government licenses or other restrictions. There are certain activities and information that are not covered by the fundamental research exclusion, however, and remain subject to the export control laws and regulations.
It is essential for all members of the Caltech Community to be aware of them. Toward that end, we have adopted a new policy, "Compliance with Export Laws and Regulations." While the policy applies to all members of the Caltech community, there are many who will not be directly affected by the requirements of this policy.
The Caltech Export Compliance Office will continue to offer export compliance awareness classes for faculty and staff on these requirements. The schedule of training programs for 2009 will be announced in January. However, if you need immediate assistance or have any questions regarding this policy, please contact Caltech's Director of Export Compliance, Adilia F. Koch, at extension 4469 or email: [email protected].
The policy can be accessed at: http://cit.hr.caltech.edu/policies/Policies/CITPolicy_ExportLaw.pdf
What is this new Institute Policy?
A clear statement of commitment by Caltech’s senior officers
Communicated to the Caltech community
To comply with US export laws and regulations
Why do we need this policy?
Recommended Best Practices
It will mitigate risk should something go wrong
It serves as the foundation of the larger Export Compliance Management Program
What are the effects of this policy?
Export Compliance Education Program for campus Faculty & Researchers Administrative Staff
International Shipments reviewed to ensure: Compliance with export/import regulations and to determine whether an export license is required.
Creation of new processes and procedures for some organizations
What else is new?
MK Denial Restricted Party Screening Tool A campus wide web-based tool vs. limited # Will ensure we are not involved with unauthorized
entities or individuals
Current Users: OSR Mail Services Shipping & Receiving Procurement Export Compliance, Other
Tool is very simple to use
When should we perform RPS?
When engaging in a financial or export transaction involving unknown individuals or entities
When a transaction raises a “red flag”
MK Denial Acquire a user name and password from
the Export Compliance Office if you have a concern about a transaction.
Contact Us
Export Compliance Office(626) 395-2641 (626) 395-3144 (fax)
Web: http://researchadministration.caltech.edu/ec
Email: [email protected]
Agency UpdatesNSF
Postdoc Mentoring Activities description: Required:
As a separate section In any proposal that includes funding for
postdocs Within 15 page limit of Project Description
Proposals will be returned by NSF if there is no section addressing this topic
(Grant Proposal Guide Chapter II, Section C.2d(i))
Agency Updates
NIH
2009 NIH Salary Cap $196,700 (up from $191,300 for 2008) Effective January 1, 2009
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-09-037.html
Career Development (K) applications Electronic submission goes electronic on
February 12 (e.g., via Grants.gov) Reference letters will be submitted directly to
NIH Commons after submission of proposal
Agency Updates
DoD
Cap on F&A has been carried into 2009 Limits F&A recovery to 35% of TC Applies to:
New/Renewal awards issued in FY2008 & FY2009
Year 2 funding of awards issued in FY2008 Standard burden schedule will apply Will not impact direct costs available to PI
Agency Updates
F&A in Proposals
Caltech F&A Rate Agreement Negotiated with the federal government Used on all federal and non-federal proposals On-campus rate (60.5%) applies by default Off-campus rate (26.0%) - proposal must
clearly demonstrate that the off-campus rate is applicable
Use of on- and off-campus rates in the same proposal requires prior discussion with OSR
Agency Updates
F&A in Proposals (cont.)
Exceptions to Caltech’s F&A Rate Agreement: Reduced or zero F&A based on sponsor policy does
not require special approval, however… Must be a federal or non-profit sponsor Must be a published policy Must be a requirement for submission Sponsor’s reduced F&A must be assessed on
all budget categories, unless a category is specifically exempted by the sponsor’s policy
All other exceptions require prior approval of the Vice Provost for Research; Research Administration does not have the authority to approve waivers
Agency Updates
F&A in Proposals (cont.)
Remember, F&A recovery lower than Caltech’s negotiated on- or off-campus rates
will negatively impact Faculty Research Pools
requires use of the higher tuition remission rate (85%) in non-federal proposals
Future Training Sessions
Fundamentals of Research AdministrationFebruary 27, 2009
9:00-11:30am202 Guggenheim
Annual Export Compliance UpdateMarch 24, 200910:00-11:30am
151 Sloan
please RSVP to [email protected]