NSF Proposal Submission Requirement for FCOI Effective 11-12-2012

*The following announcement supersedes the attached “NSF and Conflict of Interest” email of 09-17-2012.

MU Grants Community,

In light of the policy and procedure changes resulting from the 2011 Revised Federal Regulation on Financial Conflict of Interest, OSPA and the COI Office have taken a closer look at the National Science Foundation (NSF) Conflict of Interest Policies in relation to UM CCR 420.030. As a result, the following requirement, currently applicable to PHS proposals, will be in effect for NSF proposals as of Monday, November 12, 2012:

·         Proposals will not be submitted until it is confirmed that all MU Investigators have a current Outside Interest Disclosure Form (OIDF) on file and that required certifications are received for non-MU Investigators.

An Investigator Form is required for all NSF submissions. As a reminder, the Investigator Form initiates the Departmental and OSPA review for required OIDFs and so should be completed and submitted to OSPA well in advance of the submission deadline. Please watch for a separate email this afternoon announcing a revised Investigator Form.

Requirements at award, as described in the attached email, remain the same:

·         The OSPA SGCA will work with the COI Office to ensure the required reviews, which include confirmation that all NSF Investigators on the project have completed mandatory Conflict of Interest Training. Upon notification from the COI Office that the reviews are complete (and with all other approvals and certifications in place), the SGCA will set up the award and distribute the Grant Award Summary.  

Revised NSF Grant Proposal Guide (GPG) and Award & Administration Guide (AAG)

The National Science Foundation (NSF) has issued a new version of the Proposal & Award Policies & Procedures Guide (PAPPG), (NSF 13-1). The PAPPG consists of the (1) Grant Proposal Guide (GPG) for guidance on the preparation and submission of proposals to NSF and (2) Award & Administration Guide (AAG) to guide, manage, and monitor the award and administration of grants and cooperative agreements made by NSF.

This new version of the PAPPG will be effective for proposals submitted, or due, on or after January 14, 2013. In the interim, the guidelines contained in the current PAPPG (NSF 11-1) continue to apply. 

Sheryl Koenig, Grant Writing Consultant for the Bond Life Sciences Center, provided a summary (below) of the changes in the GPG.*

Additionally, please note a change in the AAG stating that “project reports must contain information on all activities of the project, including any activities to address the broader impacts criterion that are not intrinsic to the research.”

For additional information about the revisions to the merit review criteria, NSF has created a resource website for the proposer community containing presentations, fact sheets, and other important links. 

                                                                                                                                                    

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

OSPA SPPG Addition: Financial Conflict of Interest in PHS-Funded Research

The 2011 Revised Federal Regulation on Financial Conflict of Interest (FCOI) goes into effect today, Friday, August 24, 2012. Consistent with UM and MU policy changes, the OSPA Sponsored Programs Procedure Guide (SPPG) is updated to include a topic entitled Financial Conflict of Interest in PHS-Funded Research. The procedure outlines new mandatory requirements at proposal (before submission) and at award (before expenditure of funds) for PHS Investigators, including subrecipients. Please note also that a new Subrecipient Commitment Form, referenced in the FCOI procedure, is posted to the OSPA Forms page.

Thank you to so many of you for proactively turning your attention to these important changes and for your assistance and patience leading up to today. As PHS proposal submission deadlines approach, awards are received, and changes occur during the period of performance, we are here to help you. Please call me, your SGCA or Sr. Accountant, or any other member of OSPA anytime.

HHS and PHS Operating Divisions

Considering that both the HHS Salary Cap and PHS Financial Conflict of Interest (FCOI) Policy are with us for the foreseeable future, please find below for reference the lists of operating divisions that comprise each agency. 

The US Department of Health and Human Services Organizational Chart (screenshot below) illustrates that there are just a few extra HHS operating divisions that are not PHS. 

OSPA Draft Procedures on Conflict of Interest in Research

Attached please find new draft OSPA procedures pertaining to the 2011 Revised Federal Regulation on Financial Conflict of Interest (FCOI). Consistent with UM and MU policy changes, final OSPA procedures will be posted and go into effect this Friday, August 24, 2012. Please note that there are new mandatory requirements at proposal (before submission) and at award (before expenditure of funds) for PHS Investigators, including subrecipients.

Please review and reply with questions, concerns, or any other feedback by Wednesday, August 22. Similar to the uncharted territory of ARRA reporting, we expect to make adjustments as we go in the early days and months under the new regulation. I look forward to hearing from you at any point along the way. 

Attachment 1 

Attachment 2 

RE: Federal Conflict of Interest Rule Changes – OSPA procedures coming soon!

Please expect new OSPA procedures related to the revised PHS COI regulations in the next few days for a short review period before we finalize and implement for the August 24, 2012, effective date. Should you have questions in the meantime, please don’t hesitate to call me. 

                                                                                                                                                      

June 13, 2012

Research Community,

The Public Health and Services (PHS), which includes the National Institutes of Health (NIH) and the Food and Drug Administration (FDA), has revised the regulations that govern Conflict of Interest (COI).  The regulation has new requirements for both MU as a PHS-funded Institution and the Investigators who work on those projects.  Implementation of these new processes will begin on August 24, 2012.  The COI Office is taking the lead on ensuring these regulations are met. 

We will be giving a detailed presentation about these changes for all Investigators and Staff who are interested on June 26, 2012 from 1-3pm in the Monsanto Auditorium in the Bond Life Sciences Center. We encourage all to attend, especially those who currently have PHS funding.