Managing Subcontracts and Consortium for NIH and Federal Funding

Ramadhani Abdallah Noor, M.D., M.P.H.Research Associate

Africa Academy for Public Health (AAPH)

Overview • Background• Scope—management subgrants and consortium for NIH and

federal funding• Key areas—subgrant management• Foreign Organization System (FOS) review• Common compliance pitfalls and strategies for success• Case studies with references

Background • It’s about the systems/procedures, activities, and compliance• Pre-award, during award, and post-award• NIH Grant Policy Statement (Oct. 2012)

http://grants.nih.gov/grants/policy/nihgps_2012/• NoA, institutional policies, CFRs, OMB circular, etc.• Policy requirements “flow down”

IMPORTANT!• A domestic institution administering a subcontract to a foreign

institution must assure NIH that it is holding its collaborator to the policies required for foreign institutions

Scope • General issues• Application preparation• Policies and procedures• Grant monitoring• Fiscal and scientific overlap• Standards of conduct• Consortium arrangements• Indirect costs• Records management• Local and int. requirements

• Banking arrangements• Budget preparation and

controls• Accounting systems• Personnel• Internal controls• Procurement• Property and asset

management• Travel

NIH Grant Policy Statement• Part I—NIH grants information• Part II—Terms and conditions of NIH awards– Subpart A: general– Subpart B: for specific types of grants, grantees and

activities• Part III—Points of contact [Institutes and Centers]

Make sure you have the current version

General Issues • Good organizational charts• Clear identification of responsible person/ToRs• Clear lines of delegation authority• Clear communication lines• Required registrations (e.g., eRA Commons [organization/PI];

DUNS number; CCR registration, etc.)

Policies, Procedures, and Standards of Conduct • Research misconduct, conflict of interest, confidentiality, etc.• Well documented and approved• Formulated and owned by the institutions• All staff trained • Evidence of enforcement

Application Preparation • Team work—led by PI• RFA/Call announcement requirements (eligibility, overall

impact, etc.)• Reviewed and supported by institution• If consortium: reviewed and supported by members• Peer review and scored review criteria

Application Preparation (cont.) • Budget preparation– Supported by verifiable information– Based on true costs– Reviewed by finance and accounting

• Electronic submission

Grants management and research administration support are key from the beginning—pre-award, award, and post-award

Post-Award Grant Monitoring• NoA, agreements, approved proposal, protocols, etc.• Periodic programmatic reviews (deliverables and milestones)• Financial review of actual versus budget• Assess and reassess compliance

Fiscal and Scientific Overlap • Avoid duplication of payments – Same research– Same equipment – Time of researchers (effort)

Consortium Arrangements • Steering/decision-making mechanisms • Consortium agreement• Communication plan• Application, budgets—member involvement• Performance (deliverables and milestones)• Costs and expenditure monitoring

Indirect Costs• Applicable rates• Clearly identified• How deduction is carried• Properly used

Records/Data Management • Scientific and administrative (policies and procedures; where,

how, and storage period; how disposed)• Biological samples (MTA, storage, future use)• Data management plan• Data sharing agreement

Banking and Payment Arrangements • Separate bank accounts for the grant• Maintain accounts that allow electronic transfer of funds• How payments are initiated, authorized, and approved• Authorized signatories (preferably two)• Compliance with local institution and sponsor financial

guidelines

Budget Preparation and Controls• Source (cost) information document• Review by accounts for accuracy• Once approved,– Change by authorized person with appropriate supporting

communication and approval by sponsor– Regular monitoring (burn rates), monthly/quarterly actual versus

budgets• Internal controls (accounts audited annually)– Independent accountant– Internal/government auditors– OMB A-133 requirement ($500,000 or more in federal funds during a

fiscal year)

Personnel and Payroll• Personnel – Written policy manuals– Job descriptions– Annual evaluations– Time and attendance is recorded (effort)

• Payroll– Prepared based on percentage of effort– Verified by a second person– Approved by PI – Direct deposit

Procurement and Property/Asset Management• Written institutional policies • Local/national procurement act• National procurement regulatory authorities • Three quotes for large purchases/alternative approved vendors list• Applicable in all ranges of resources, including human resources• Purchases approved by authorized manager• Property management (registry, tags, annual inventory, authorized

disposal)

Travel• Written policies• How travel is approved• How expense claims are verified• Proposed per diem is reasonable, limited to mission days and

actual travel time• Most direct route, not exceeding coach class fare• U.S. flag carriers• U.S. foreign travel restrictions

Foreign Organization System (FOS)• Review of administrative and financial systems using the

foreign organization system (FOS) review document• Ability to manage U.S. federal funds in an accountable manner• Benefits to the grantee:– Assists compliance with NIH terms and conditions– Provides a global outlook at internal procedures– Promotes understanding between PIs and administrators

• FOS is not an audit

Common Compliance Pitfalls• Unallowable costs• Misallocation of costs• Excessive cost transfers• Inaccurate effort reporting• Inadequate monitoring of subrecipients• Administrative and clerical costs• Noncompliance with assurances and special terms and

conditions of award• Delinquent closeout reporting

Questions? GrantsCompliance@nih.gov

Resources• OMB Circular A-133: This circular describes audit requirements for

organizations receiving federal funds. Sections 225 and 400, Supplement 3, part M, all include information on subrecipients/subcontracts.

• Sample Foreign Subaward Template• NIH Grants Policy Statement section on Foreign Awards, including

policy requirements• NIH Grants Policy Statement section on Consortium Agreements • Fogarty International Center (FIC) Consortium Agreement

information• NIAID tutorial on subawards