UM Policy Change: BPM-203 F&A Cost Recovery (Grants & Contracts)

UM System has published a revision to BPM-203 Facilities and Administration Cost Recovery (Grants & Contracts), as follows:  

For Projects Supported by an Industrial or Commercial Firm or Foreign Entity Government

F&A costs must be charged at a rate not less than the predetermined approved schedule of rates developed by the Vice President for Finance and Administration.

When a commercial or industrial firm requires rights in data to the exclusion of the University and/or claims full rights to patents ownership rights to intellectual property developed by the University under such a project, F&A costs must be charged at a rate not less than 200% of total direct costs. the scheduled rate and may be charged at a higher rate through negotiation by the campus.

The President must specifically approve any waiver of such intellectual property rights.

NSF and Conflict of Interest

The COI Office and OSPA have clarified requirements and processes for National Science Foundation (NSF) proposals and awards related to conflict of interest (COI).

At Proposal

Because the NSF policy differs from the PHS regulation*, procedures as proposal will accordingly differ:

·         Following an NSF proposal submission, the COI Office will contact the PI directly (with a copy to Department and OSPA pre-award staff) to identify Investigators (as defined by NSF), confirm all required Outside Interest Disclosure Forms are current, and guide the process of completing Conflict of Interest Training. Note: Per University of Missouri policy, Conflict of Interest Training is mandatory prior to expenditure of funds, should the proposal be awarded.

     For NSF proposals currently in process: Investigator Forms and/or NIH-NSF Financial Disclosure Forms currently received or in process for upcoming NSF proposal submissions are now not required but are certainly not wasted effort. Please submit to your SGCA who will, in turn, include the information when alerting the COI Office to the proposal submission. The PI should still expect an email from the COI Office.  

Additional Organizations following 2011 PHS FCOI Regulations

The following organizations have adopted the 2011 Revised Federal Regulation on Financial Conflict of Interest (FCOI), effective August 24, 2012:

Alliance for Lupus Research

American Cancer Society

American Heart Association

Arthritis Foundation

Susan G. Komen for the Cure

Note that because these organizations have adopted the PHS FCOI rule in full, the UM and MU COI polices and OSPA procedures related to PHS FCOI (including the PHS Investigator Form*) apply without exception. Proposals will not be submitted to these organizations before confirmation that each Investigator has a current Outside Interest Disclosure Form on file.

*Reference footnote on page 2 of the PHS Investigator Form:

*Please note: It is possible that additional funding agencies or sponsors may also require the University of Missouri to ensure that PHS rules are followed.  If so, completion of this form will be required for submission to those sponsors as well.

OSPA is planning a Certificate Series FCOI Open Forum Session for the fall to review our first few months under the new rule. Please watch for more information coming soon and plan to attend if your schedule allows. In the meantime, please do not hesitate to contact me or any member of OSPA as questions arise.    

                                                                                                                                                

RE: Grant Fact Sheet Updates - New F&A rate for On Campus Research effective 7/1/2013

As a follow-up to Jennifer’s email below regarding the revised Grant Fact Sheet and the new F&A rate for On Campus Research effective 7/1/2013:

Until 7/1/2013, the PeopleSoft F&A Pricing Setup tab will continue to default to our current On Campus Research rate of 51.5%. However, budgets for proposals with a start date of 7/1/2013 or later should apply the new On Campus Research F&A rate (53.5%). This requires a manual change as follows:   

PeopleSoft →Grants→ Proposal →Maintain Proposal→ Budgets →F&A Pricing Setup