External Funding Advisor
March 2017 Newsletter
In this Issue:
  1. Director's Note- Do you need to run your research proposal through the OSP?
  2. Grants.gov Update- Workspace is Coming
  3. NIH Update- eRA Enhancements & NIH Operating Under a CR
  4. Timely Topic- Research Terms and Conditions Implementing the Uniform Guidance
  5. Compliance Corner - NSF Update 
Director's Note
New Tool: Do I Need to Run My Research Proposal Through the Office of Sponsored Programs to Obtain University Approval Prior to Submission?

In most cases, the answer to this question is YES, however there are limited circumstances when the Office of Sponsored Programs (OSP) approval is not required to submit a funding application. We have recently added a decision tree to our Forms, Tools, and Resources webpage that can help principal investigators determine if a research proposal can be submitted without going through the OSP. NOTE: This also applies to student-led projects. In those cases, if the funding is to be deposited into the university's finance system for the student's use, then the project must be approved PRIOR to submission and the student must identify a faculty mentor to be the PI of record.  


If a person is receiving the funding on their own, the OSP does not need to be involved. This must mean that the employee is not representing that JMU is part of the work. If they are offering themselves as a JMU employee and/or referencing/using resources provided to them as a JMU employee then the funds should flow through the OSP and university approval must be obtained prior to the proposal submission. 

What About Concept Papers?
Some sponsors request a preliminary proposal/White Paper/Concept Paper before a full proposal is developed. If no budgetary information (i.e.: budget totals, cost sharing, etc.) is provided and there is no reference to quantified personnel effort or space, then the preliminary proposal does not need to run through the OSP. It is fine to submit just the technical information to the sponsor. 

For further information please see JMU Policy #1304 and JMU Policy #2201

When in doubt, please contact us! 8-6872 or jmu_grants@jmu.edu 
Grants.gov Update
Workspace is Coming

Grants.gov's application method of submitting a single PDF application (i.e. Legacy PDF application package) is being phased out and Grants.gov Workspace becomes the new, standard way to apply. For any funding opportunities where applicants have downloaded the legacy PDF application package, they will be able to continue to submit that package until March 31, 2018. The Office of Sponsored Programs (OSP) will be responsible for setting up the Workspace application for the chosen funding opportunity and for providing other organizational users (i.e. Principal Investigators) access. All users will need a Grants.gov user account. We recommend that PI's obtain a Workspace account now. Instructions on how to register for a Grants.gov account are available at the following URL:  https://www.grants.gov/help/html/help/Register/Create_a_Grants.gov_Account.htm

To register, users must enter JMU's Data Universal Numbering System (DUNS) #87-932-5355. After creating an account, the OSP will receive an email notification and will assign the appropriate role to the account.

For more information about Grants.gov Workspace, please visit the various Workspace resources: 

Feel free to contact OSP with questions as we navigate to this new method of submitting Grants.gov applications. 

NIH Update
eRA Enhancements: Two More Prior Approval Requests Go Electronic March 2, 2017

The ability to request a No Cost Extension requiring a prior approval and the ability to request a change of PD/PI will be available through the Prior Approval section in eRA Commons after a release schedule for Thursday, March 2, 2017. 

Features

Prior Approval Request for No Cost Extension (NCE)
Signing Officials (SOs) will be able to request an NCE electronically through eRA Commons via Prior Approval. 
When is a grant eligible for a NCE through Prior Approval?
  • When a NCE under expanded authority has already been used and the grant is within 90 days of the project end date. 
  • When the grantee is not under expanded authority and the grant is within 90 days of the project end date. 
  • When the project end date has expired and has not been closed or has not entered unilateral closeout, whichever comes first. 

When is a grant NOT eligible for a NCE through Prior Approval?

  • When a NCE under expanded authority has never been requested and the grant is within 90 days of the project end date. In this case, 
  • the NCE will be processed normally through the Extension link in Status. 
  • When the grant is closed. 
  • When the grant is a fellowship grant. 

What information will an SO need to provide?
The NCE request form includes: 

  • Request Detail - Here you will be asked such things as the number of months you wish to extend the project end date; the amount of unobligated money still available, etc. 
  • Three PDF upload fields: Progress Report, Budget Document, Justification Document 

Contact the awarding IC for details on the content of these documents. 

Prior Approval Request for Change of PD/PI
Signing Officials (SOs) can initiate the request for a Change of Program Director/Prinicpal Investigator (PD/PI) electronically through eRA Commons via Prior Approval. 
The following conditions must be met for a grant to be eligible for a Change of PD/PI Request: 

  • The grant is awarded, and the Project Period End Date has not passed 
  • The grant is not a Fellowship or Career

The details for the request require some basic information:

  • Who is being replaced, removed or added to the grant? 
  • What will their level of effort be? 
  • What is the effective start date for the requested changes?

Additionally, some files will need to be uploaded as an attachment to the request. 

  • Biosketch for any new PD/PI 
  • Other Support for any new PD/PI 
  • Justification Document 
NIH Operating Under a Continuing Resolution

The National Institutes of Health has issued (NOT-17-048). The notice states: 
The Department of Health and Human Services (HHS), including NIH, operates under the "Further Continuing Security Assistance Appropriations Act, 2017," (Public Law 114-254) signed by President Obama on December 10, 2016. The continuing resolution (CR) continues government operations through April 28, 2017 at 99.8099 percent of the FY 2016 enacted level. 

Continuing the procedures identified under NOT-OD-17-001 and NOT-OD-16-046 and consistent with NIH practices during the CRs of FY 2006 - 2016, the NIH will issue non-competing research grant awards at a level below that indicated on the most recent Notice of Award (generally up to 90% of the previously committed level). Upward adjustments to awarded levels will be considered after FY 2017 appropriations are enacted, but NIH expects institutions to monitor their expenditures carefully during this period. All legislative mandates that were in effect in FY 2016 (see NOT-OD-16-044 and NOT-OD-16-048) remain in effect under this CR. 
Timely Topic
Research Terms and Conditions Implementing the Uniform Guidance


These RTCs are the successor to the terms developed with the Federal Demonstration Partnership, and they have been written to comply with the requirements set out in the Uniform Guidance (2 CFR 200). Federal agencies are planning to implement the RTCs at different dates in 2017, see below. 

Agencies participating, with implementation dates are: 
  • Department of Agriculture / National Institute of Food and Agriculture (June 1, 2017) 
  • Department of Commerce (October 1, 2017) 
  • Department of Energy (April 3, 2017) 
  • Department of Health and Human Services / National Institutes of Health (April 3, 2017) 
  • Department of Homeland Security (to be determined) 
  • Department of Transportation (October 1, 2017) 
  • Environmental Protection Agency (December 2017) 
  • National Science Foundation (April 3, 2017) 
  • National Aeronautics and Space Administration (October 1, 2017) 

Note that the Department of Defense is not included; but will implement award terms in compliance with 2 CFR 200. 

While the Uniform Guidance outlines provisions that are specific to research, these terms and conditions: 

  • Incorporate the entire Uniform Guidance by reference, clarifying or supplementing select provisions where appropriate and consistent with government-wide research policy. 
  • Incorporate the latest version of the Frequently Asked Questions for the Office of Management and Budget's Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards at 2 CFR 200.
  • Apply to an award when included as part of the award or when incorporated in the award by reference. Use of the RTCs is envisioned as a streamlined approach that supports the implementation of the Uniform Guidance by providing clarification, supplementary guidance, and, where appropriate, selected options, while meeting the spirit and intent of a uniform implementation. 

In addition to the RTCs, three companion resources will be developed: Appendix A, Prior Approval Matrix; Appendix B, Subaward Requirements Matrix; and Appendix C, National Policy Requirements Matrix. 

Resources:

Federal-Wide Research Terms and Conditions (hosted by NSF): 

Compliance Corner
NSF Update

Human Subjects
There has long been a section in the Code of Federal Regulations (CFR) - 45 CFR 690.118 - that provides guidance for proposals that lack definite plans for human subject research. NSF did not want to be in the position of requiring and Institutional Review Board (IRB) approval for a project that, at the time of submission, did not have definite plans for use of human subjects. Such proposals do not need to be reviewed by an IRB prior to an award being made. For projects that lack definite plans for the use of human subjects, their data or their specimens, pursuant to 45 CFR 690.118, NSF will accept a determination notice that establishes a limited time period under which the Principal Investigator (PI) may conduct preliminary or conceptual work that does not involve human subjects. 

In those cases the university will provide a signed letter to the NSF program officer based on a template provided by NSF. The Office of Sponsored Programs will coordinate the approval of the letter with the Office of Research Integrity. 

Except for research exempted or waived, no human subjects may be involved in any project supported by the award until the project has received approval by an IRB. The NSF Division of Grants and Agreements will include an award clause identifying that any work with human subjects, including recruitment, may not be conducted prior to an IRB approval. The complete NSF policy regarding human subjects is contained in the PAPPG, Chapter II.D.5. 

Vertebrate Animals
With regard to vertebrate animals, additional clarity has been added to the PAPPG regarding departures from the Guide for the Care and Use of Laboratory Animals (Guide). The revised language states that any project proposing the use of vertebrate animals for research or education must comply with the provision in the Public Health Service (PHS) Assurance for Institutional Commitment that requires the submitting organization to establish and maintain a program for activities involving animals in accordance with the Guide. Taxon-specific guidelines may be used as supplemental references. Departures from the Guide must be approved by the Institutional Animal Care and Use Committee (IACUC) and be based on scientific, veterinary, medical or animal welfare issues. 
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