Announcements

Looking Ahead: Winter Break Proposal Schedule (updated 10/22/20)


NASA Science Mission Directorate - COVID Flexibilities beyond 9/30/20 (10/2/20)

Per NASA Grant Notice 20-02, requests will be considered from award recipient(s) stating that they have experienced a loss of operational capacity due to the COVID-19 pandemic and that they need to charge salaries or benefits to an active NASA award consistent with their policies of paying salaries under unexpected or extraordinary circumstances. Verify this in advance with your organization's authorized organization representative (i.e., OSP Grant & Contract Administrator  or BMRA).  See this link for more information and web form. 

 

Department of Energy Office of Science - Response to Delayed Progress in Research Caused by COVID-19 (10/2/20)

The Director of DOE's Office of Science (SC) writes  "SC is committed to maximum flexibility in administering awards, recognizing potential delays in research caused by impacts of the COVID-19 pandemic.  Investigators will not be penalized for such delays.  Researchers are encouraged to make the best progress possible in their changed, and changing, situations."  Read a full copy of the statement here and visit the Dept of Energy's Responding to COVID web site here.


Upcoming Proposal Submission Deadlines for OSP/BMRA Review (9/15/20)

 

New Assistant Director, Post-Award Services Named (9/15/20)

We are delighted to announce the promotion of Robin Eubank to the Assistant Director, Post-Award Services position in the Office of Sponsored Projects.  Robin brings over 14 years of experience as an Auditor with supervisory responsibilities, Internal Control and Financial Statement analytical skills as well as technical GAAP expertise.  In addition, Robin led client engagements in non-profit and educational sectors including performance of Single Audit compliance testing on federal and federal pass-through funding.  Since arriving at Brown in 2018, Robin has led the Effort Certification process, prepared the NSF HERD Survey and the NIH Biomedical Research and Development Price Index Report submitted on behalf of the University to Brown's largest external sponsors of research.  She has also led several initiatives for the OVPR’s Diversity and Inclusion Committee. 

Please join us in congratulating Robin on her new role in the Office of Sponsored Projects. 

 

Management of Fixed Price Agreement Residual Funds (8/11/20)

To manage the audit risk of residual funds remaining on sponsored project awards that are issued to Brown as Fixed-Price Agreements and to streamline the closeout process, the Office of Sponsored Projects (OSP) is adopting the following procedures:

At award close-out, OSP will review the account to ensure that all sponsored funds have been received, all expenses related to the project are reflected in the account, all PI and personnel effort that has been charged to the project is in line with the work performed, and all award requirements (e.g., final technical reports) have been met. OSP will confirm that the terms and conditions of the award do not require the return of unspent funds. 

Funds will be defined as either small or large balances:

Small balances: A balance after award closeout <25% of the total sponsored award amount and/or <$100K. OSP will transfer the residual funds per the University’s applicable F&A revenue allocation methodology during the OSP closeout process. The School/Center/Department may determine if there will be further internal distribution (i.e., to Department or PI).   

Large balances: A balance after award closeout ≥25% of the total sponsored award amount and/or ≥$100K. The PI and Department/ Center must initiate a request for the transfer of a large balance. Justification of large unspent balances by budget line item will be completed on the Residual Funds Balance Transfer Form along with confirmation that all project deliverables have been met.

OSP will identify direct and indirect costs by applying the project’s established Facilities & Administrative (“F&A”) rate to total unspent funds using the F&A rate in effect during the final year of the project.  Once the Balance Transfer Form is accepted by OSP, direct costs funds will be distributed to an account identified by the PI and endorsed by the Department Chair.  The F&A portion of the large balance will be transferred per the University’s applicable F&A revenue allocation methodology.

For questions or concerns, please contact [email protected], Director, OSP or [email protected], Associate Vice President for Research. 

 

Use of Electronic Signatures on Proposal and Award Documents (8/7/20)

OSP is paper-free! As a reminder electronic signatures were formally adopted by OSP in 2019. OSP uses "e-signing" on outgoing subaward agreements and amendments in addition to standard grants & contract documents. For example, many foundations now require the use of the Docusign tool for award endorsement. 

At the proposal stage, we encourage electronic signature on internal forms including Investigator Certifications when a Certified Digital Signature is used. Using Adobe’s “Fill & Sign” tool is not secure or certified, so these signatures cannot not be accepted. Instead, use the Digital Signature option in the Adobe “Certificates” tool. Adobe's instructions can be found here and we've prepared our own instructions here.   

If you have questions or a digital signature isn't possible for whatever reason, please reach out to your OSP Representative and we'll find a solution.
 

New F&A (Indirect Cost) Rate Agreement is Published (7/17/20)

Important update on Brown’s negotiated F&A rate for sponsored projects. Over the next 3 years, the On-Campus Research rate will increase each year in FY22 and FY23:

FY20 62.5% (July 1, 2019 – June 30, 2020)
FY21 58.5% (July 1, 2020 – June 30, 2021)
FY22 59.0% (July 1, 2021 – June 30, 2022)
FY23 59.5% (July 1, 2022 – June 30, 2023)

“Other Sponsored Activities” will increase from 23% in FY20 to 27% in FY21-FY23.

“Off-Campus Activities” will remain the same for FY20-FY23 at 26%.

New awards beginning on or after July 1, 2019 will start at 62.5% through June 30, 2020; starting on July 1, 2020, they will decrease to 58.5% for FY21, increase to 59.0% FY22, and increase to 59.5% starting on July 1, 2022 for FY23 and forward until a new rate agreement is approved).

Note: This means that for awards that are obligated for several years at once, the account(s) may have up to four IDC effective dates and rates, as our rate changes each fiscal year.

What about Non-competing Continuations? Awards with a start date before July 1, 2019 will continue at 62.5% for the remainder of the competitive segment. Therefore, Noncompeting Continuations for awards beginning prior to FY20 (July 1, 2019) will not be affected, and we can continue using the IDC rate of 62.5% during the continuation period.

What if the Notice of Awards (NOA) lists the incorrect IDC rate? OSP will go back to the sponsor to request a correction in the IDC rate only if: (a) the error results in the overall award amount being reduced inappropriately; or (b) our old rate of 62.5% is listed for FY21 and FY22, and the NOA is received more than 30 days after our new rate agreement has been finalized.
 

NSF Proposal and Award Policy and Procedures Guide (PAPPG) effective June 1, 2020 (6/15/20)

NSF has made the decision to delay the requirement to use NSF-approved formats for the biographical sketch and current and pending support sections of NSF proposals until October 5, 2020. Proposers must continue to format these documents in accordance with PAPPG requirements (see PAPPG sections II.C.2.f and II.C.2.h).  

Webinars covering the use of NSF-approved formats as well as all of the significant changes to the PAPPG are available on the NSF Policy Outreach website.  

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ARCHIVED ANNOUNCEMENTS 

COVID-19 Related Notices

COGRNIH | NSF | COVID-19 RELATED ANNOUNCEMENTS | OPERATIONAL TRAVEL CHANGES 


On June 16, 2020, most of the administrative flexibilities described in the Office of Management and Budget (OMB) Memos M-20-17 and M-20-20  expired.  Of immediate interest please take note of the following changes:

Travel
The ability to charge cancellation fees associated with project specific travel were included in these flexibilities.  Any cancellation fees incurred on or after June 17 may no longer be charged to a sponsored project.  Please note that university travel restrictions remain in place through August 14th.

Proposal Applications and Research Performance Progress Report (RPPR)
Proposal applications and RPPR reports are due on the normal established deadline schedule unless a specific exception has been granted by the agency.

OMB Memo M-20-11 will expire on July 26, 2020,  this page will be updated as further agency implementation plans are released. 

COGR
COGR - Agency information (5/6/20)
COGR - Institutional Information (5/6/20)
COGR - FAQs​ (5/6/20)
NIH
NIH Implementation of OMB Memorandum M-20-26 "Extension of Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations" (6/29/20)
Applicant/Recipient COVID-19 Update History (4/2/20)
 
Archived NIH COVID-19 notices
 
NSF
Coronavirus Information
NSF Implementation of OMB Memorandum M-20-26 "Extension of Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations" (6/29/20)
 
Archived NSF COVID-19 notices

 

COVID-19 RELATED ANNOUNCEMENTS 

NIH FOREIGN COMPONENT NOTIFICATION | RESEARCH PERSONNEL EFFORT |
PRG 300 COVID-19 PROGRAM WORKTAG | 
EFFORT REPORTING - COVID-19 INTERIM PROCESS

NIH FOREIGN COMPONENT NOTIFICATION 

NIH Foreign Component notification requirement found in the NIH COVID Flexibilities FAQs here , please note the IMPORTANT 5/21 REVISION to the FAQ below: 

1.    If a Post-Doc  on an active NIH grant must return home to a foreign country and work remotely due to COVID-19, must this be reported to NIH as a foreign component?

For post-docs that are required to work on their originally approved work remotely from a foreign country due to COVID-19 travel restrictions, where no grant funds are going to a foreign entity, NIH has determined that this scenario does not constitute the performance of a significant scientific element or segment of the project outside the US, as outlined in the NIH Grants Policy Statement definition of a foreign component.​

This FAQ response is an update to an email message sent at the end of April to all active NIH PIs.

Should you have any questions or concerns, please contact your OSP Representative  or your BMRA Contact


RESEARCH PERSONNEL EFFORT

Through June 16, 2020 many Federal Agencies (e.g.,  NIH, NSF, NASA, ONR, DARPA) allowed grant/cooperative agreement recipients to continue to charge salaries and trainee stipends to currently active Federal awards consistent with the recipients' policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal.  This included researchers who were unable to work as a result of or related to the effects of COVID-19 in accordance with university policy.

If progress of the work has been or will be impacted, PIs should consult with their program officer to determine if a scope of work change, time extension or other action is necessary. If so, the submission of an agency notification is done through OSP or BMRA.

The extension of these emergency federal regulations beyond mid-June - is under assessment by the University. OSP will be posting further guidance as it becomes available.

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PRG 300 COVID-19 PROGRAM WORKTAG

In April Workday Communications notified the community of a new Program Worktag to track expenses related to the ongoing COVID-19 pandemic.  We encourage use of the PRG300 COVID-19 for sponsored project funds as well.  Federal Agencies allowed salaries, fringe benefits during the work remote order and the repurposing of grant funds including supplies and personnel through June 16, 2020, it is critical that Brown be able to track these and any other financial impacts on internal and external funds.

Repurposing Existing Federal Financial Assistance Programs and Awards (Grants) to Support the Emergency Response to the Novel Coronavirus (COVID-19) 
NIH, NSF and NASA Grant Recipients authorization to donate PPE and other research supplies to support COVID-19 efforts (e.g., to hospitals and local health care facilities) expired on June 16, 2020. 

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COVID-19 Effort Reporting Interim Process

The purpose of this Notice is to alert the community of administrative flexibilities that will apply/be adopted under the University's Effort Certification Policy during the Provost's Remote Work order period related to the COVID-19 crisis. 

OSP has identified the following short-term administrative flexibilities to assist our Effort Certification Partners and Certifiers in managing the monthly effort reports during the remote work order period.
 

Schedule and Deadlines

  1. Effort reports for undergraduate and non-exempt employees will be completed on a quarterly basis for the prior 90 day period, rather than on a monthly basis to reduce the administrative burden. 

  2. A 30 day extension will be granted for effort certification reporting periods impacted by the remote work order. 

The schedule for the non-exempt and undergraduate effort report will be as follows:

Effort Reporting Period

Reports Generated

Certification Deadline

 

 

 

March 1, 2020 – March 28, 2020

May 8, 2020

July 7, 2020

 

 

 

March 29, 2020 – April 25, 2020

April 26, 2020 – May 30, 2020

May 31, 2020 – June 27, 2020

August 7, 2020

October 6, 2020

 

 

 

 

June 28, 2020 – July 25, 2020

July 26, 2020 – August 29, 2020

August 30, 2020 – Sept 26, 2020

November 9, 2020

January 8, 2021

 

 

 

Sept 27, 2020 – Oct 31, 2020

Nov 1, 2020 – Nov 28, 2020

Nov 29, 2020 – Dec 26, 2020

February 9, 2021

April 10, 2021

Semi-annual effort reports will be generated on August 7, 2020 and February 9, 2021 as originally planned, with the certification deadlines coinciding with the extended schedule of October 6, 2020 and April 10, 2021, respectively.

Many Federal agencies and other sponsors have released guidance related to award management and the impacts of COVID-19. OSP will be reviewing this guidance and assessing its impact on our effort reporting processes. In the meantime, please continue to follow all relevant policies and procedures and apply those practices consistently. 

Effort Certification Statement

For a  limited period of time in 2020 many Federal Agencies (e.g.,  NIH, NSF, NASA, ONR, DARPA) are allowing grant/cooperative agreement recipients to continue to charge salaries and trainee stipends to currently active Federal awards consistent with the recipients' policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal.  This includes researchers who are unable to work, or are “idle”, as a result of or related to the effects of COVID-19 in accordance with university policy.  With Federal Agencies allowing salaries, fringe benefits during the work remote order and allowing the repurposing of grant funds, it is critical that Brown be able to track the financial impact on internal and external funds during this time. Please use the COVID-19 worktag PRG300 COVID-19 when tracking such expenses for sponsored project funds. 

Please note that the effort certification language that researchers will certify on the effort report will be modified to acknowledge that effort may include periods of little or no work, but that payroll charges will continue as allowable under sponsor guidance. 

Example:  I acknowledge that the effort report may include periods of little or no work in accordance with the University’s job continuity policy and as allowable under Federal regulations and sponsor guidance.
 

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OPERATIONAL TRAVEL CHANGES DUE TO COVID-19

For non-refundable tickets purchased prior to March 9, 2020, our current guidance is that cancellation fees on federal grant related activities can be charged to sponsored funds if the cancellation was a result of an external organization’s action, (e.g. a vendor cancelled a conference or site visit), is due to the CDC travel restrictions (see CDC Level 3 countries) or is due to Brown’s prohibition on travel.  The authority to charge cancellation fees to federal projects ended June 16, 2020, with the expiration of OMB Memo M-20-17. 

Departmental Cost Center Managers/Authorized Approvers must ensure any change or cancellation fees charged to sponsored funds are reasonable and allowable. Travelers should retain documentation of their cancellation request, change/cancellation fees and remaining vendor credits.

Please note that Trip Cancellation Insurance is not ordinarily allowed on sponsored awards. At this point in time, the preferred action is purchase of a refundable ticket. For non-federal sponsors, the award’s terms & conditions will require review as to allowability. Contact your OSP Staff Grant & Contract Administrator or Accountant with questions on non-federal awards.

Pre-Award Staff are responsible for:

Post-Award Staff are responsible for:

  • Reviewing and submitting proposals on behalf of Brown University

  • Serving as Institutional Authorized Signatory on sponsored agreements and proposals

  • Providing assistance with the interpretation of sponsor requirements and federal regulations

  • Communicating with sponsors on behalf of PIs and Departments

  • Grant and Contract award negotiation and acceptance

  • Creation and issuance of subaward agreements and Subrecipient Monitoring

  • Non-financial Post-award changes (e.g., No-cost extensions, Rebudgeting, Change of PI, Award transfer, etc.)

  • Education, outreach and training

  • Establishing and monitoring sponsored research accounts

  • Monitoring expenditure activities on sponsored research accounts to ensure compliance with federal regulations, non-federal, and University policies and procedures

  • Interpreting and applying sponsor regulations and policies

  • Preparing interim and final financial reports in a timely manner

  • Cash management of sponsored projects

  • Disseminating information to principal investigators and administrators on a range of topics related to post-award administration

  • Participating in the University's annual federal Single Audit

  • Education, outreach and training

 

About OSP 

The Office of Sponsored Projects (OSP) supports Brown University faculty, students and staff in the acquisition, performance, and administration of projects and programs funded by external sources. OSP provides the University's central coordination and oversight of research by offering a wide range of services including review and submission of proposals; award negotiation and acceptance; dissemination of research policy information to campus; issuance of subaward agreements and sub-recipient monitoring; compliance with governmental and private funding agency standards; advising on financial management of sponsored projects, financial and expense reporting; cash management; effort reporting, and monitoring of cost-share arrangements; addressing financial and administrative issues that arise during the life of a sponsored project; coordination of award close-out process; and providing education and professional development opportunities in research administration for the campus community.