Designating Proprietary Information in Federal Grant Applications

In general, disclosing proprietary information in a grant application should occur only when needed to present information that is critical to the review of the grant proposal.   If a proposal is funded, most grant-related information in the proposal is considered public information and may be made public, so if  proprietary information is included it is important to indicate it appropriately on the forms pages and in the body of the application or cover page.   Doing so ensures that the federal agency will only use the information for the evaluation of the application, and aids in the identification of what may be exempt from disclosure to the public.     

Funding agencies may have a required question or field on their standard forms to capture whether proprietary information is included.  An affirmative to the question indicates that patentable ideas, trade secrets, or privileged information is included.  Consulting the agency specific grant application guidelines will advise on how to identify such information in the body of the application materials.

For example, the National Science Foundation (NSF) requires the “Proprietary or Privileged Information” box on the Cover Sheet to be marked, in addition to clearly marking the information in the proposal with an appropriate label or legend.  [NSF Proposal and Award Policies and Procedures Guide (PAPPG) Chapter II.D.1]   

Similarly, to identify proprietary information on a National Institutes of Health (NIH) grant proposal, check “Yes” to Question 3 on the “Other Project Information” page on the application forms pages, and clearly mark each line or paragraph containing the proprietary information.

[General Instructions for NIH and Other PHS Agencies (Section G. 220)]

Other federal agencies may have similar application requirements, please read your grant solicitation or guidelines carefully.

Federal Demonstration Partnership September 2019 Meeting Updates

The University of Missouri-Columbia is a member of the Federal Demonstration Partnership (FDP). FDP is an association of federal agencies, academic and nonprofit research institutions, and research policy organizations that work together to streamline the administration of federally sponsored research. FDP meets three times a year in which faculty and administrators talk face-to-face with decision-makers from agencies that sponsor and regulate research. Member institutions have an administrative representative and a faculty representative. MU’s representatives are Jeremy Cox, OSPA (Administrative Representative) and Sara Gable, Office of Research Faculty Fellow (Faculty Representative).

Presentation slides from the September 2019 meeting can be found here, including the Federal Agency Updates, linked below.

One item of interest from NSF is that their annual update to the Proposal & Award Policy & Procedures Guide (PAPPG) will be delayed.  In a typical year,  the PAPPG is posted in October, with a January implementation date.  Due to comments received in response to the draft PAPPG, many related to coverage on Current and Pending Support, the actual dates of posting & implementation remain TBD.  OSPA will keep the Grants community apprised of the status of this important guide.

Another hot topic discussed, and can be found in the presentation slides, is Foreign Influence, what various Institutions are doing to stay compliant, and what our federal FDP partners are doing to address this topic.  Here at Mizzou, this website has been dedicated, containing a plethora of information useful to the grant community, including best practices to follow, FAQ’s, and who to contact for questions.

• NIH Update
• NSF Update
• OSTP Update
• AFOSR Update
• USDA Update
• EPA Update
• GUIRR Update
• Grants.gov Update

Staff Spotlight - New Post-Award Analysts

Post-Award Analysts Cathrine Rivas [Left], Marissa Stealey [Right]

We are happy to introduce two of our new Post-Award Analysts that joined the OSPA team over the summer. A graduate of Saint Louis University, Marissa Stealey worked at a small accounting firm in Fenton, MO prior to coming to MU. She moved to Columbia when her husband was accepted into the medical school, and she says that she really enjoys the culture of staff development at OSPA. In her free time, she enjoys playing sand volleyball at the Deuce and spending time with her dog on the city’s beautiful MKT Trail.

Cathrine Rivas has traveled around quite a bit as a military spouse, but she has found a welcome home at OSPA. She says the work environment has been a breath of fresh air compared to past jobs, and everyone has been eager to support her as she learns the ropes. As an added bonus, it has been great working within a university research office, Cathrine says, because she gets to see firsthand the research being done on creating a more sustainable and eco-conscious society, such as the much-anticipated Missouri Hyperloop. When she is not busy being a mom to three kids, she tries to get outside and garden, hike, or play sports.

MU Grants & Contracts at NCURA 61

In August, staff members from OSPA and MU-Extension attended the 61st Annual Meeting of the National Council of University Research Administrators, held in Washington, D.C. The four-day conference included educational sessions on a variety of research administration topics, including updates from major federal sponsors, as well as a variety of networking opportunities that helped connect people who face the same daily challenges from across the nation and even the world.

The conference was abuzz with the challenges of working in a global research atmosphere. Institutions have been strongly urged by a number of federal sponsors to ensure that all foreign collaborations are properly disclosed, and many of these sponsors are working to issue formal guidance and best practices to assist. A number of sessions highlighted the importance of data security in a day and age when it can be commonplace for researchers to present their research at international conferences, bringing along with them laptops, tablets, and other electronic devices with the potential to be hacked by sophisticated foreign parties. At the same time, everyone in the MU delegation found that interacting with and hearing from the diverse attendees at the conference enriched their experience. The conference included many global participants who gave insight on issues like how to work with international sponsors and the problems that Brexit is causing for university research in the U.K.

There were also a number of helpful updates from major federal sponsors. The National Science Foundation (NSF) reminds investigators and research administrators that conference proposals must include codes of conduct with clear means of reporting violations of the policy before and during the conference. Our university’s Sponsored Programs Procedure Guide that covers this topic can be found here. In addition, unless otherwise stated in the guidelines, conference costs should not be listed as participant support, but rather under other direct costs in grant budgets.

Investigators and staff should become more familiar with online tools and portals like Research.gov, SciENcv, and ORCID IDs. While there is no firm date on when FastLane will be phased out, current solicitations that allow for submission through Research.gov should be done through that portal. Similarly, NSF encourages investigators to begin using the SciENcv template for biographical information on all proposals, even if it is not yet required.

On the other hand, many NIH award categories are now requiring ORCID IDs for awards received on or after 01/25/2020. Also from the NIH: the sponsor is working to expand request options for their automated “Prior Approval” process in eRA Commons. This would supplement their successful approach to approvals for No Cost Extension Requests and Change of PD/PI.

The keynote address at the conference was delivered by Freeman A. Hrabowski, III, President of University of Maryland, Baltimore County. Dr. Hrabowski, who in 2012 was selected to chair President Obama’s Advisory Commission on Educational Excellence for African Americans, spoke of the many challenges faced by minorities in university education and research. Growing up in Birmingham, Alabama in the 1950s and 60s, he saw hatred and racism everyday, and he pointed out how far our nation has come since then. But he challenged conference attendees to see the work done at UMBC over the years as an example of how integrating a commitment to diversity and inclusion can actually drive research forward. He left attendees with the following observation: "Your thoughts, become your words, your words become actions, your actions become habits, these habits build your character, and your character leads you to your destiny."

Staff Spotlight - New Associate Director

We are pleased to announce the appointment of Jeremy Cox as Associate Director of the Office of Sponsored Programs Administration (OSPA).  Jeremy holds a Bachelor of Science in Accounting and a Masters of Business Administration degree with an emphasis in Management.  His professional career began in the field of public accounting where he continued to work for many years with his expertise including audits of local governments & not-for-profit entities, including conducting A-133 audits.  Previously, Jeremy served in OSPA as a Compliance Manager and a Senior Accountant, before moving to the MU Office of Finance where he was a Fiscal Officer supporting five divisions.   We welcome Jeremy back to OSPA and look forward to our continued collaborative work together to advance the research mission of the University of Missouri.  

Research Administrators Certification Council (RACC)

A private group with developed certification programs for the education and training in research administration, the Research Administrators Certification Council (RACC) has been certifying research administrators on their professional knowledge since 1993.  Programs exist to certify your education and knowledge as a Certified Research Administrator (CRA), a Certified Pre-Award Research Administrator (CPRA), and a Certified Financial Research Administrator (CFRA); each with varying required experience, education, and knowledge requirements.  According to the RACC, the benefits of becoming certified include professional development, credibility in research administration, demonstrated expertise, and professional recognition.   There are educational and experience requirements for candidates wishing to take an exam and there is a cost to do so.  For more information visit the RACC site.   The RACC provides a directory of Research Administrators who maintain an active certification in CRA, CPRA, or CFRA.

Grants Searchable Database

Did you know that there is a new searchable grants database available in MIS Web Applications? The database is a tool for discovering who within the UM System is doing research in a given area and can be used to help identify potential collaborators. Anyone with PeopleSoft Grants Module access can use the database. Instructions can be found here.

In order for a project to return in the search results, an abstract must be added in the PeopleSoft Grants Module at the time the proposal is entered (PSRS). This database is being used by the MU Office of Research, the Research Development Network, and various campus committees to identify who is doing research in a given field. We strongly encourage research administrators to enter abstracts in the PeopleSoft Grants Module whenever possible to ensure that projects are included in the searchable database.

SPPG: Sexual Harassment, Other Forms of Harassment, and Sexual Assault – Compliance with Federal Granting Agency Requirements

Published in March 2019, this topic addresses federal policies related to the obligations of the research community on investigation of sexual or other harassment complaints and advises how the University of Missouri will comply with federal nondiscrimination law as directed by the federal granting agencies, National Science Foundation (NSF) and National Institutes of Health (NIH).  

In collaboration with the Office for Civil Rights and Title IX, OSPA developed this policy to assist Principal Investigators and Departmental Research Administrators, as well as the Office of Sponsored Programs Administration, with their obligations for compliance.  Guidance includes Institutional Requirements for NSF (e.g. recipients of funding must maintain workplaces free of discrimination and harassment, and will report to NSF if a violation occurs when the award terms indicate applicability; and for conference awards to provide participants a copy of the institutions code of conduct policy in advance, and to also make it available at the conference itself) and for NIH (e.g. provide assurance upon submission of grant proposals and at award to comply with a number of public policies which include EEO, Civil Rights Protections, Age Discrimination Act, among others; and for all training grants to include appropriate Letter of Support to address the institutions commitment to required areas of compliance).   The topic includes samples for NSF funded conference code-of-conduct policy hand-out, as well as sample language for the required NIH Letter of Support.    

The Office of Sponsored Programs Administration provides a public resource covering this and other topics of significant interest to research administrators – in the Sponsored Programs Procedure Guide (SPPG). This is provided to support our administrators who need a thorough understanding of University policies and procedures and how they interact, enforce, and integrate with government regulations and sponsor requirements. Included in the SPPG are a range of topics, policies, or procedures for submitting proposals, requesting advance spending accounts, recovering F&A, participant support costs, the Fly America Act, and more.  The material included in each topic provides a solid foundation in support of the administration of sponsored projects at the University of Missouri. 

Registration for Fall Certificate Series Sessions Open

This fall, we continue our trek through the Post-Award Track of courses, beginning with a timely session on EVRs, Cost Transfers, and PCEs on August 1. The OPSA Certificate Series for Specialized Grants Training was developed to enhance your technical expertise in sponsored programs administration. Beginning in 2011, the program has been providing education and training that follows both a Pre-Award Track and a Post-Award Track. Topics include Budget Development, Facilities and Administrative (F&A) Rate, Proposal Development and Submission, Closeout of Award, and Cost Share among others. During the Regulatory Track, participants hear directly from campus leadership on topics related to Animal Welfare, Export Controls, Human Subjects Research Protections Program, and Conflict of Interest.   180 Certificates have been issued to attendees, with course attendees exceeding 600.  Past attendees who have completed session surveys agree that the training provides a positive benefit - more than 95% agreeing or strongly agreeing that what they have learned will be useful in their job.  Join us for a training session soon to see what the buzz is all about.  For more information and to register visit the grants training page on the OSPA website.   

The current schedule for fall courses: 

EVR, Cost Transfers, and PCEs
Thu, Aug 01, 2019

Subawards and Consulting Agreements
Thu, Sep 12, 2019

Salary Cap, EVR and Effort Tracking*
Tue, Sep 17, 2019

Federal Contracts*
TBA

Cost Sharing
Tue, Oct 15, 2019

Audit
Thu, Oct 31, 2019

Closeout of Award
Thu, Nov 14, 2019

*advanced course

May 2019 Grant Connections Notes

Minutes from the Grant Connections meeting on May 22 are now available.  Please follow the links below to access the materials.

Meeting notes can be found here. 

Our next meeting will be June 26, 2019.