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Post Award Procedures
VB. FEDERAL DEMONSTRATION PROJECT AWARDS
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Since October 1, 1988, the University has been participating in the Federal Demonstration Project (FDP) which provides greater flexibility to faculty in managing grant resources, simplifies grant administration procedures, and eliminates unnecessary administrative procedures.
The purpose of the Federal Demonstration Project is to increase research productivity at academic institutions by standardizing and simplifying Federal terms for the support of academic research.
Copies of the FDP General Terms and Conditions and Federal Agency-Specific Requirements are available in the Office of Research Administration. The Sponsored Projects Officer assigned to your department can assist you in utilizing the special features selected for the demonstration and advise you on agency-specific requirements applicable to each agency's awards.
- Air Force Office of Scientific Research (AFOSR)
(Only new awards as of November 30, 1988)
- Army Research Office
(Active and new grants as of October 1, 1989)
- Army Medical Research & Development Command
(Active and new grants as of October 1, 1989)
- Department of Agriculture (USDA)
- Department of Energy (DOE)
(Also includes cooperative agreements)
- Environmental Protection Agency (EPA)
- National Aeronautics and Space Administration (NASA)
(Research grants and cooperative agreements as of April 1, 1989)
- National Institutes of Health (NIH)
(Includes Program Project Grants (PO1s), Research Career Awards (K series), Minority High School Student Research Apprenticeship Program Awards (SO3s) and all R series grants except Phase I Small Business Innovation Research (R43) and Small Business Technology Transfer (R41) awards.)
- National Science Foundation (NSF)
- Office of Naval Research (ONR)
(Only new awards as of October 1, 1988)
2. Special Features:
The major features of FDP include: 1) the elimination of federal requirements for prior approvals to project changes other than change of scope and change of P.I.; 2) providing the University with unilateral authority to issue a one-time 12-month no cost extension; 3) allowing carryover of unobligated balances between budget periods; 4) allowing the University to authorize pre-award costs up to 90 days prior to award.
On NIH grants, the Notice of Grant Award will include "the dates of the budget period or other specified funding period and the amount of funds authorized for obligation by the grantee during the period indicated. If applicable, the Notice of Grant Award will also indicate the dates of the approved project period and the amount of support recommended for each subsequent budget period of the approved project."
The REMARKS section on the award notice also contains special terms and conditions, restrictions, and grants management/program contacts. In addition, each NIH award which is included in FDP will carry an explanatory footnote on the Notice of Award.
However, an awarding component may specifically exclude a grant award from the FDP when considered necessary by programmatic and/or administrative reasons. It is also important to remember that exceptions to any policy can be stated in the "Remarks" section on award notices.
Investigators should consult the ORA for additional assistance in FDP General Terms and Conditions, or NIH agency-specific requirements which are necessary to supplement the pertinent award.
See Section V.F.4.c. for NIH continuation application requirements for grants under the Federal Demonstration Project.
For other participating agencies under the Federal Demonstration Project (FDP), review the notice of grant award for mechanism of support and terms of the award. Consult the ORA for additional assistance regarding agency-specific terms and conditions.
The Department of Energy and components of the Department of Defense are participating in an FDP Contract Demonstration Pilot Project which became effective May 1, 1991. Please consult the ORA for information describing this demonstration. For other federal agencies, the Principal Investigator must obtain prior approval from the awarding agency's representative contracting officer.
PRIOR APPROVALS FOR FEDERAL DEMONSTRATION PROJECT AWARDS ITEM
A. Rebudgeting P.I./Dept.3
B. Carryover4 See Footnote5
C. No-Cost Extension (Up to 12 months) Dept./Sponsored Projects Office6
Dept./Sponsored Projects Office6
D. Absence or Change in P.I.7 Awarding Agency
E. Substantive Change in Objective or Scope8 Awarding Agency
F. Pre-award Costs (Up to 90 days) Dept/Sponsored Projects Office9
Dept/Sponsored Projects Office9
G. Renovation/Alteration Institutional Procedures
H. Relatedness Awarding Agency10
1 Prior Approval - For items requiring agency prior approval, the Principal Investigator needs to write a letter to the agency that includes spaces for ORA signature. This letter is forwarded to ORA along with written certification of Departmental approval.
2 FDP Grants - active or new awards as of October 1, 1988 of the agencies specified on page 61 and 62.
3 Rebudgeting for FDP Awards - is at the discretion of the Principal Investigator with departmental approval as long as costs are allowable. It is important to note that when the rebudgeting option is used, the P.I. must stay within the total award dollar amount and that full indirect cost recovery must be maintained.
4 Carryover - is the transfer of any unobligated balance or over expenditure of funds which remains at the end of a budget period, to the next budget period except in the final year of a grant. (NIH allows carryover between competing awards.) Funds that are carried forward are expended using the indirect cost rate(s) in effect at the time of the expenditure (the date the check is cut). Overexpenditures carried forward are a debit (including the prior year's indirect cost rate) from the total funds available for the current year.
5 FDP Carryover - Automatic cumulative carryover is allowed up to 25% of the current year's total budget. Any estimated unobligated balance (including prior year carryover) that is greater than 25% of the current year's total budget on more than $250,000 must be explained in the non-competing continuation applications. To ensure carryover, the Financial Status Report (FSR) must be received by the agency no later than 90 days after the close of the budget period. This means that the Principal Investigator must work with Research Accounting to ensure that the FSR is received by the agency within the 90-day period.
6 No-Cost Extension for FDP Awards - The University has unilateral authority to issue a one-time 12-month no-cost extension to the expiration date of the project. Department and ORA approval is needed for a no-cost extension. The Awarding Agency must be notified of this extension 15 days prior to the grant termination date. The Principal Investigator should originate the letter to the Awarding Agency, notifying the Grants Management Specialist that under the terms of the Federal Demonstration Project the University is extending the termination date of the grant. In the letter, the P.I. should specify the number of months the grant is being extended, as well as the new termination date. This letter is forwarded to ORA for signature by the Assistant Dean for Research Administration. Please note that agency approval is still required for no-cost extension for Air Force and Office of Naval Research grant awards.
7 Absence of P.I. - NIH defines absence of P.I. as any continuous period of more than three months.
8 Substantive Rebudgeting or Change of Workscope or Research Objectives - The Principal Investigator is required to seek approval from the PHS awarding component when there is a change in the scope or research objectives of the project. Actions likely to be considered a change in the scope or objectives include, but are not limited to, the following:
- A change in the specific aims approved at the time of award;
- Substitution of one animal model for another;
- Any change from the approved use of animals or human subjects;
- Shifting the emphasis of the research from one disease area to another;
- Applying a new technology, i.e., changing assays from those approved to use of a different type of assay;
- Transferring the performance of substantive programmatic work to a third party by contract or any other means;
- Change in key personnel or significant change in their level of effort from what was approved for this project. A significant change in the level of effort is defined in federal regulations as a 25% reduction in time devoted to the project;
- Significant rebudgeting, whether or not it requires approval under rules governing budget changes, including key personnel, salary, equipment, etc.. Significant rebudgeting occurs when the cumulative amount of transfers among direct cost categories for the current budget period exceeds 25% of the total amount awarded, or $250,000, whichever is less;
- Incurrence of patient care costs where the need has not previously been approved by PHS and/or when a P.I. desires to rebudget funds OUT OF the patient care category.
9 Pre-Award Costs for FDP Awards - The Principal Investigator must send a written request to the Department Chair specifying or requesting the account number that will be responsible for pre-award expenditures. This is the account that will be charged if no award is made or if the charges are not allowable. The Department Chair must sign off on any request for pre-award costs before it is sent to the Office of Research Administration.
10 Relatedness - Faculty may request that related research projects be treated as a single award for cost allocation purposes. This may apply to separate grants of one or more P.I.s from one or more participating federal agencies. Consult with the ORA for further information.
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