Roles & Responsibilities Matrix

In general, sponsors must approve subcontracts not identified in the original budget. Appropriate paperwork from the proposed subcontractor must be included: a Subrecipient Statement of Collaborative Intent (SSCI) form signed by the subcontractor’s authorized institutional representative, a statement of work, a budget, and a budget justification.  If the subaward was not included in the original proposal, an Add-On Subrecipient Request  must be submitted to SPA through VERA.

VU SPA is using procedures laid out through the Federal Demonstration Partnership (FDP) best practices for Risk Assessment.  Please reference the Federal Demonstration Partnership (FDP) website, specifically the Subaward Forms section and the Risk Assessment portion to learn more.  The FDP Risk Assessment Tool is what has helped inform our decisions regarding ongoing subrecipient monitoring.  The SPA process is to send a Continuing Assessment Tool REDCap survey to both the Department and Research Finance to answer questions about working with the subrecipient.  SPA will initiate this survey for non-FDP, foreign, and/or for-profit subrecipients. 

Click on the link, if you would like to learn more about the  FDP Continuing Assessment Tool document.  It is the tool that we are using to collect information from the Department/PI and Research Finance perspectives, which helps SPA assess any changes in risk on an annual basis.

We would like to offer to visit your college or department to provide training on this subject.   Please contact us at SPA.Training@vanderbilt.edu to schedule a time for us to come meet with you. 

Please review the FDP Prior Approval Matrix and read the award terms and conditions regarding equipment purchases.  If you have additional questions after reviewing the above items please contact SPA for assistance.

Agency approval is usually necessary when the PI of a federal award wishes to purchase a piece of equipment not originally identified in the budget.   Unless Prior Approval is required, you will not go through SPA.  If Agency Prior Approval is required, then contact your SPA Specialist who will help you decide what steps to take.  If it is determined that a Prior Approval Request is necessary, then the request typically requires a scientific/programmatic rationale for the purchase, a cost breakdown, and, if possible, vendor quotes.  

Prior approval is not required for a change of vendor or model for equipment included in the approved budget, nor for a change of 25% or less in the acquisition price of approved equipment.  Purchasing equipment at the end of a project period is difficult to justify and will not normally be permitted.

SPA's Revew - Is the request reasonable, allowable, allocable?

1.  Why does the PI need the equipment?
2. Is the grant excluded from Expanded Authority related to re-budgeting? Does the equipment cost exceed $25,000? http://grants2.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part7.htm
3. Verify the re-budget does not affect the budget by more than 25%.
   1. On the request letter from the PI, write the NOGA project and current dates and award funding (Direct and Indirect Costs). Add a breakdown of the current re-budget based on direct and indirect costs.
   2. Document on the request letter any previous re-budgets for equipment and foreign travel.
4. Have there been other requests during the current budget period that when added to this request would exceed the 25% re-budget limit?
5. Total the amount of previous re-budgets for the overall project period. Verify that previous plus current re-budget does not exceed the 25% limit.
6. Is the correct center number being used?
7. If there are multiple centers, make sure a usage percentage is listed for each center. 
8. Make sure the request indicates what account category is being re-budgeted for the funds.  (Ex: Transferring from Lab Supplies.)
9. Verify the correct IDC amount is being deducted. (Example: Direct Costs of $1,340 & Indirect Costs of $717 for a total of $2057 transferred to Equipment for purchase.)

After an award is made, changes resulting from circumstances not anticipated in the planning stages of the project are sometimes necessary. These changes can be programmatic or financial in nature. Some changes require the sponsor’s prior written approval, others may be authorized internally by Vanderbilt. See below for examples.

Refer to the sponsor’s regulations and award documents and contact your SPA representative with specific questions regarding such changes. Requests to sponsors must be authorized by SPA prior to submission to the sponsor.

Examples of programmatic and financial changes during the life of an award:

• Changes in the scope of work (SOW)
• Change of Principal Investigator or significant reduction of effort
• Changes/additions to collaborating institutions/subcontractors responsible for carrying out a portion of the SOW
• No cost extension of the budget or project period (extension of time without additional funds)
• Re-budgeting. 
• For federal awards, the OMB Unified Guidance  grants permission to an awardee to re-budget, except where there is a change in the SOW or the need for additional funding
• Non-federal awards may provide different thresholds for re-budgeting, for example by percentage or amount of deviation by budget category or line item, or stipulate that “substantial” deviation requires prior approval
• Carry-forward of funds from one budget period into the next within a project period

Changes under Federal Demonstration Partnership (FDP) Awards                    

The Federal Demonstration Partnership (FDP) is a cooperative initiative among certain federal agencies and institutional recipients of research funds. The FDP developed standard Research Terms and Conditions (RTC) now in use by several federal sponsoring agencies. Visit the Research Terms and Conditions page on the NSF website for an explanation of each of the Research Terms and Conditions as well as a link to each participating federal agency’s specific RTC.

See the Prior Approval Matrix to identify how various federal agencies have implemented these Research Terms and Conditions and the need for prior sponsor approval. 

Vanderbilt utilizes VERA to review changes that may be institutionally authorized.  See VERA Guides on Award Modifications for further details.

ORACLE Analytics Cloud (OAC) is a reporting tool which allows users to access VERA data through a web browser. There are several reports to provide proposals and award data in various forms to suit different user needs.

Resource

Link to VERA Reporting Tool

PIs are responsible for submitting the technical reports to the sponsor.  When the report is submitted to the sponsor, SPA is to be copied on the email that submits the report so that proof of submission can be documented in the grant record, or it can be uploaded in the record as an attachment in VERA.  

NOTE: Failure to submit technical reports in a timely manner can delay payment of an invoice, delay closeout of the grant, cause an audit finding, or could result in loss of future funding.

All fiscal reports are to be submitted by Research Finance and are based on the information that is documented in Oracle, the system of record.

NIH Research Performance Progress Report (RPPR)

**New Requirements for Other Support Documents**

Types of RPPRs

Progress reports document grantee recipient accomplishments and compliance with terms of the award. There are three types of RPPRs, all of which use the NIH RPPR Instruction Guide.

1. Annual RPPR – Use to describe a grant’s scientific progress, identify significant changes, report on personnel, and describe plans for the subsequent budget period or year.
2. Final RPPR – Use as part of the grant closeout process to submit project outcomes in addition to the information submitted on the annual RPPR, except budget and plans for the upcoming year. Only the PI and Signing Official have access to the Final RPPR.
3. Interim RPPR – Use when submitting a renewal (Type 2) application. If the Type 2 is not funded, the Interim RPPR will serve as the Final RPPR for the project. If the Type 2 is funded, the Interim RPPR will serve as the annual RPPR for the final year of the previous competitive segment. The data elements collected on the Interim RPPR are the same as for the Final RPPR, including project outcomes.

Purpose

NIH began implementing the Federal-wide Research Performance Progress Report (RPPR) in the Fall of 2012. NIH now requires the use of the RPPR module in eRA Commons to submit ALL annual progress reports. As you may already know, the progress report is where the PI reports his accomplishments on the award. The RPPR was initiated to promote consistency across federal agencies and in e-commons. Some agencies may have their own requirements, please adhere to specific agency terms and conditions of the award. Please note, the areas below are highlighted to assist the Principal Investigator, Department Administrator & SPA representative to provide the requirements but are not inclusive of all the RPPR’s requirements.

NIH Annual RPPR Due Date

The due date of the annual progress report for awards issued under the SNAP (Streamlined Non-competing Award Process) provisions is the 15th of the month preceding the month in which the budget period ends (e.g., if the budget period ends 11/30, the due date is 10/15). If the award is not issued under SNAP provisions, the progress report is due the first of the month preceding the month in which the budget period ends (e.g., if the budget period ends 11/30, the due date is 10/1). If the due date falls on a weekend or federal holiday, the due date is automatically extended to the next business day. Progress reports for Fellowships are due two months before the beginning date of the next budget period. Occasionally the Notice of Award (NoA) will indicate a different due date which will supersede these dates. Grantees should consult the NoA to determine when SNAP procedures apply.

**Final FFR, RPPR & Final Invention Statement and Certification**
Please note, submission deadlines for the Final Federal Financial Report, Final Progress Report, and Final Invention Statement and Certification requires that all final reports be submitted within 120 calendar days of the end of the period of performance, unless otherwise specified. This change applies to any projects with a period of performance end date on or after October 1, 2014; for projects with a project period end date before that date, the original 90-day deadline still applies

NOTE: Before you begin with the initiation of the RPPR in e-commons, please ensure that all participants have an e-commons user ID and that the e-commons profiles are updated accordingly.

Cover Page – Self Explanatory.

B. Accomplishments
NIH requires up to two pages of accomplishments exclusive of graphs and charts. NIH requires a substantial accomplishment even if the period of performance is less than one year. Please note, publications are considered part of the accomplishments.

C. Products – Self Explanatory.

D. Participants
“The RPPR Section D. allows the agency to know who has worked on the project to gauge and report performance in promoting partnerships and collaborations.”

Senior Key Personnel Effort
“Senior/key personnel are defined as individuals who contribute in a substantive measurable way to the scientific development or execution of the project, whether or not a salary is requested.” NIH specifically requires measurable effort for PD/PI.

• The PD/PI effort should be listed on the Participant’s Section D, whether it’s is less than 1.0 calendar month.
• Effort should be rounded to the nearest calendar months. For example, if PI/PD is less than 0.4 Calendar month it should be round to “0” or if its 2.5 calendar months, it should be rounded to “3” calendar months. Please note, rounding to “0” is allowable. This is different from the instructions we’ve received from NIH in the past. NIH may require additional verification of measurable effort after the RPPR has been submitted. 
• The Effort reported on the personnel page is retrospective while the effort reported on the Other Support is prospective. The Senior Key Personnel effort needs to match what was certified on e-cert. Please note, you are reporting on actual effort on the Senior Key Personnel effort spent on the current year.
• Other Senior Key Personnel whose effort is less than 1.0 calendar month does not need to be listed on the Personnel page.

Please refer to your latest JIT or report to ensure that effort is being captured consistently and appropriately throughout the life cycle of the award.

Bio Sketch – Senior Key Personnel
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-15-032.html

If you have new Senior Key personnel please submit a new biosketch.

*Please note that NIH is recommending the use SciENcv to create their biosketch.*

Other Support
Please note, if there is a change in the Senior Key Personnel’s Other Support, NIH requires updated other support with active awards listed only. Please note, this is a change to what we used to submit to NIH. Also, NIH wants to know what changed in the Other Support (see below.)

Excerpt from RPPR Guidance

D.2.c Changes in other support.
Has there been a change in the active other support of senior/key personnel since the last reporting period?
If yes, upload active other support for senior/key personnel whose support has changed and indicate what the change has been. List the award for which the progress report is being submitted and include the effort that will be devoted in the next reporting period.

Select Yes only if active support has changed for the PD/PI(s) or senior/key personnel.
If a previously active grant has terminated and/or if a previously pending grant is now active, submit complete Other Support information using the suggested format and instructions found at http://grants.nih.gov/grants/funding/2590/Non-competing_othersupport.docx. Annotate this information so it is clear what has changed from the previous submission.

[Please note, that you would annotate the changes in section D.2.c of the RPPR.]

Submission of other support information is not necessary if support is pending or for changes in the level of effort for active support reported previously.

Other support information should be submitted only for the PD/PI and for those individuals considered by the grantee to be key to the project for whom there has been a change in other support. Senior/key personnel are defined as individuals who contribute in a substantive measurable way to the scientific development or execution of the project, whether or not a salary is requested. Do not include other support information for Other Significant Contributors; e.g., those that may contribute to the scientific development or execution of the project, but are not committing any specified measurable effort to the project.

Statement on Individual Development Plan
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-13-093.html

“For all projects reporting graduate students and/or postdoctoral participants in Section D., describe whether your institution has established Individual Development Plans (IDPs) for those participants. Do not include the actual IDP, instead include information to describe how IDPs are used, if they are used, to help manage the training for those individuals.”

NIH annual progress reports received on/after October 1, 2014, must include a section to describe how individual development plans (IDPs) are used to identify and promote the career goals of graduate students and postdoctoral researchers associated with the award. Please note, this was optional last fiscal year, but this year it’s required. As you’ll see in the Notice, you don’t have to describe the individual cases, just whether or how IDPs are implemented at Vanderbilt in your graduate program, or in your lab, depending on where these decisions are made (e.g., Template: NIH Research Performance Progress Report). NIH generically needs to know whether you include formal IDPs in the training of your students or post-docs and if so, what the IDPs are like.

E. Impact – Self Explanatory.

F. Changes – Self Explanatory.

G. Special Reporting Requirements – Self Explanatory.
http://grants.nih.gov/grants/rppr/rppr_instruction_guide.pdf

H. Budget - [Applicable to non-SNAP awards only.]

Prior Approvals

The RPPR may not be used for prior approval requests, except for requesting prior approval for a reduction in the level of effort of the PD/PI or other senior/key personnel named in the Notice of Award under D.2 of the RPPR. All other prior approval requests must be submitted directly to the Grants Management Officer of the awarding component in accord with the Grants Policy Statement, 8.1.2.”

Prior approvals must be sought during the current period of the award at the time of the change and/or before the RPPR is submitted. 

Internal Process

All RPPR's are to be processed through our systems of record (VERA) through submitting a Continuation Funding Proposal (Create Continuation through the Active Award).  Once routed in VERA the SPA Specialist is responsible for reviewing and addressing any component that may not comply following the RPPR guidelines.  Please make sure that all approval and regulatory approvals are in compliance and up-to-date.  The RPPR will not be submitted until all these areas of the RPPR comply with RPPR guidance and internal policies and procedures.

VERA Requirements for RPPR Submission of continuation awards

1. Carryforward/Unobligated Balance Spreadsheet Report 
2. IACUC Approval (if applicable)
3. IRB Approval (if applicable)
4. Effort Report from eCert

**The VERA budget should match the reporting year award.**

**DEPT - Continuation Funding Proposal & Award Modification Guide

Other

Please refer to specific agencies' guidelines on different award mechanisms. Please contact your SPA Specialist if you have any questions or concerns regarding your RPPR.

NIH is moving toward electronic submission of all Prior Approval Requests**, which include:

• No Cost Extension requests

• Withdrawal requests

• Carryover requests

• Change PD/PI requests

**Although current information states that either letter or electronic submission is available, If a link is available to submit Prior Approval Requests electronically, then SPA will make every effort to comply with NIH requirements in preparation for when electronic submission is mandatory.  This may mean that your SPA Specialist will require additional information or alternate formats for this information to be submitted via eRA Commons.  Your SPA Specialist will guide you in preparing documents for electronic submission.

Check this link for NIH specific information on submitting Prior Approval Requests electronically through eRA Commons.

Sponsors require that the award be properly closed out at the PI’s prior institution before giving approval to transfer the award to the new institution.  The prior institution must provide a final financial accounting with which the sponsor concurs and then formally relinquish the grant.  The receiving institution may need to provide a revised budget. If Vanderbilt is the receiving institution then the Department should initiate the COEUS proposal for a "new" grant. The award balance is then transferred to the new institution.  It is the PI’s responsibility to notify his/her Program Officer as soon as possible to alert them to any changes of this nature.  No transfers will be made until the PI has completed all reporting requirements.

A transfer of a grant may involve the transfer of equipment purchased with sponsor funds.  The transfer of equipment may be accomplished as part of the relinquishment of the grant, subject to sponsor approval.

In many cases, grants to be transferred to Vanderbilt from other institutions will have a lower Facilities and Administrative (F&A) rate than Vanderbilt's negotiated federal rate.  In some circumstances Vanderbilt may choose to accept the previously approved F&A rate, with the understanding that this lower rate will be allowed only until the next competing continuation or renewal phase.  

For more information on the NSF & NIH Relinquishment processes at Vanderbilt, please reference the VERA Guide for NSF & NIH Relinquishments.

NOTE:  Pending proposals require formal transfer of ownership when the PI moves from one institution to another before a funding decision has been made.  In this situation, the PI’s previous institution also relinquishes ownership of the proposal to the sponsor.  The new institution then submits a revised budget (using its F&A rate), budget justification, and other pertinent forms as requested by the sponsor.  In some cases the agency may require the PI to resubmit the proposal in its entirety. 

Regardless if you need Prior Approval for a No-Cost-Extension (NCE) from the granting agency, SPA is involved. 
Read the Sponsor’s guidelines for NCEs to determine if prior approval is needed.

Please reference the two following VERA Guides for SPA details on the Vanderbilt No-Cost-Extension process:

DEPT - NCE - Converted Data

DEPT - NCE - Natively-created Data

**If you have any questions, please contact your SPA Specialist.

Anything related to Clinical Trials is a shared service with VUMC.  VU doesn’t have many clinical trials.  VUMC is the expert in Clinical Trials, and they have access to the Vanderbilt ClinicalTrials.gov account so you can communicate with them at ctgov@vumc.org for next steps on how to register.

There is a difference in “invention disclosure” and “invention reporting.” An invention disclosure, or invention disclosure report, is a confidential document written by a scientist or engineer for use by a company's patent department, or by an external patent attorney, to determine whether patent protection should be sought for the described invention. It may follow a standardized form established within a company.  An invention disclosure within a company may go through the following stages:

1. Submission of the invention disclosure details by the inventor.
2. Review of the disclosure by business and technical reviewers. The reviewers grade the idea as 'pursue' or 'do not pursue' based on its perceived novelty or business importance. They might also decide to publish it as a defensive publication if the idea is novel but not aligned with the business interests.
3. If the disclosure is accepted to be pursued further, a patent attorney is assigned for preparing a patent application.

For more information, please contact the Center For Technology Transfer And Commercialization.