Research Administrators Information Network (RAIN) Meeting – December 10th, 2015

  • Conflict of Interest (COI) Update:
  • What is FCOI?
  • Financial interests such as travel reimbursement, stock equity/options, full or partial ownership of a company.
  • The COI Committee will make a determination as to whether or not an individual involved in research has a financial interest in an outside entity (within the lens of a particular project).
  • Who needs to disclose?
  • Anyone considered an Investigator involved in the active conduct of research.
  • An “Investigator” is anyone involved in the design, conduct OR reporting of the research
  • When to disclose?
  • Annually and for each project through a Research Certification Form.
  • When an Investigator completes the Research Certification, it will reset the due date of the annual disclosure. Investigators only need to complete an Annual disclosure if they have not been active in the system for 12 months.
  • High-level steps for completing a Research Certification Form in eCOI, include:
  • Login to eCOI
  • Rutgers users can login to the eCOI system using their Rutgers NetID and password.
  • Non-Rutgers users, such as certain subrecipients, must request a Rutgers NetID and Guest Account for eCOI. Only applicable if the subrecipient does not have a compliant PHS Policy.
  • Research Certification is a 2-step process: (1) Creation of the Research Certification and (2) Review and Completion of the Research Certification
  • (1) Create a Research Certification–
  • Create a new research certification and add associated research team members and required information.
  • This step can be completed by any individual, including the PI and Department Administrator
  • (2) Review and Complete Certifications --
  • Review and complete all tasks requiring attention in the Disclosure Certification Workspace.
  • This step must be done by each investigator identified on the study team
  • Conflict of Interest Disclosures for Subrecipients
  • The eCOI questions related to outgoing subawards will be removed on Friday, December 11th. Conflict of Interest for subrecipients is confirmed during the contracting process, and does not need to be captured in eCOI. Additionally, the Non-Employee Attestation Form will no longer be collected
  • Q/A
  • How do I get access for other individuals?
  • Anyone can initiate and/or complete the first part of a Research Certification Form.
  • How can we see who has completed an annual disclosure?
  • ORRAhas granted access to certain Administratorsso that they can review who has disclosed for the current year.
  • Please email your NetID and Department information to Diane Ambrose for access.
  • What happens if the Investigator fails training?
  • The training needs to be completed every four years, per the PHS guidance.
  • The training is comprised of a number of informational screens followed by 10 questions. The Investigator cannot fail the quiz. Even if all questions are answered incorrectly, the Investigator is able to move on and enter his/her disclosures
  • At the start of the training, there is a note that says, “The Rutgers University fCOI training consists of 14 slides and a 10 question quiz which requires a passing score of 80% to successfully complete training and allow you to complete your disclosure.” We are removing this comment, as this is not true.
  • When does a Research Certification need to be completed?
  • For RBHS, a research certification needs to be completed for any new award or new scope of work.
  • For Rutgers N, NB and C, a research certification needs to be completed for any new award, new scope of work, and any non-competing continuation years. Once all awards are in the eCOI system, Rutgers N, NB and C will no longer need to create a research certification for non-competing continuation years.
  • When should I start a Research Certification?
  • Emails will be sent from ORSP or the Award Set-Up Unit triggering the process (those listed on the Endorsement Form as the pre-award and post-award contact will be notified).
  • What generates the questions in eCOI?
  • If the Investigator does not have any Disclosures, the system will ask the Investigator to verify nothing has changed.
  • If the Investigator has Disclosure, baseline questions will always be asked per Disclosure.
  • Clinical trials do not typically have SOWs. What should we upload instead?
  • The clinical trial agreement
  • Subrecipient Issuance and Monitoring:
  • Subcontract versus Service Contract
  • Subcontract
  • University engages an entity to perform substantive, programmatic work, such as an important or significant portion of the research program or project.
  • The entity is granted some element of programmatic control and discretion of how the work is carried out.
  • Usually, the entity’s personnel are identified as having a key role in Rutger’s proposal.
  • Subcontracts are not entered into with individuals.
  • State awards are almost always a subcontracts, even if they seem like procurement actions, so discuss with ORSP before approaching other offices.
  • Service Contract
  • Engaged when a particular unique expertise is required by an external entity. An individual or firm is retained to provide professional advice or services for a fee.
  • The entity is providing services in support of or ancillary to the research project or program.
  • The entity has little or no independent decision-making in the design and conduct of the work being completed
  • The entity provides these services in its normal business operations and markets its services to a range of customers.
  • Subrecipient Execution at Proposal Submission Time
  • At time of proposal, subrecipients should be appropriately identified in the proposal as such. Work with your grants specialist if you have issues with determining how to treat a potential collaborator.
  • Subrecipientdocumentation is required at the five day proposal submission deadline.
  • Required documents include:
  • Budget
  • Budget Justification
  • Does not qualify as a SOW.
  • SOW
  • Statement/Letter of Intent
  • Compliance (if applicable)
  • Subrecipient Commitment forms
  • Scope of Work Guidelines
  • The following questions need to be addressed in the SOW:
  • What is being done?
  • Who is going to do it?
  • How will it get done?
  • When will it be done?
  • The Subrecipient Page of the ORSP Website contains more details on writing an effective SOW.
  • Process for Newly Executed Subagreements
  • The Subrecipient Commitment Form now replaces the Subrecipient Checklist and is needed to issue a new subaward.
  • PI/Department Administrator provides subaward documents to ORSP only if an award is made.
  • ORSP Grant Specialist / OCC Contract Negotiator reviews documents for consistency with the prime award objectives and submits new documentation for Award Setup.
  • ORSP Subaward Specialist conducts a risk assessment, prepares and negotiates an appropriate subaward, and distributes the fully executed agreement to the Subrecipient, PI/Department, and DGCA.
  • Process for Amending Subawards
  • PI/Department provides a subaward modification checklist and appropriate documents to ORSP.
  • ORSP Subaward Specialist refreshes the Risk Assessment and prepares an amendment using the appropriate agreementfor execution.
  • A Purchase Order is updated for the subaward:
  • For Rutgers: The ORSP Subaward Specialist updates the PO in RIAS
  • For RBHS: The PI/Department prepares/updates PO in Marketplace and forwards related information to the ORSP Subaward Specialist
  • ORSP/OCC refreshes the internal Risk Assessment and amends the existing subagreement accordingly.
  • Subaward Monitoring
  • Carefully reviewing subaward invoices is important when monitoring subaward payments. The level of monitoring required is determined by the assessed subrecipient risk level.
  • Low Risk:
  • The following standards apply to ALL subrecipient invoices:
  • Adhere to the required format as specified in the sub-award agreement which requires inclusion of the following:
  • Rutgers PO # and Account/Fund/Index #
  • Expense line items per approved subaward budget
  • Current and cumulative totals
  • Signed certification statement from an authorized Subrecipient Institutional Official
  • Are within the allowable subaward project period start/end
  • F&A charge is calculated correctly per contractual rate
  • Amounts appear reasonable based on technical progress
  • Do not contain any unallowable charges such as alcohol, meals, postage, office supplies, etc. unless explicitly stated otherwise
  • Final Invoices are clearly marked FINAL and contain an additional certification statement from the Subrecipient PI
  • High Risk:
  • Additional standards may apply to High Risk subrecipients:
  • Backup/supporting documentation for subaward invoice line item charges such as:
  • Payroll records to support invoice personnel charges
  • Copies of receipts for specific travel charges
  • Copies of consultant agreements, including hourly rates and time charged
  • Frequent submission of subrecipient invoices and technical reports
  • Requirement to align invoice payments to technical progress
  • Mandated regularly scheduled conference calls with the Subrecipient PI and Subrecipient Institutional Representative
  • Site visits, both technical and financial
  • A subawardee invoice should never be approved for payment until all errors, discrepancies or questionable items have been adequately and fully resolved.
  • DGCA Compliance
  • Background
  • OIGs and the Government Accountability Office (GAO) play a critical role in DATA Act oversight. By examining the spending data collected under the act, OIGs can better:
  • Determine where to focus their audit and investigative resources.
  • Determine whether federal programs are effectively meeting their goals.
  • Assist agencies in identifying problem areas and work to solve them.
  • DGCA Annual Audit
  • DGCA collects A-133 audit information for all subrecipient institutions on an annual basis. The data is used in order to ensure Rutgers compliance with federal regulations under Uniform Guidance.
  • The annual process, at a high-level, involves the following:
  • Reviewing A-133 Audit information for all subrecipient entities.
  • Sending the Rutgers A133 Subrecipient Questionnaire to all subrecipient entities for which we cannot find an A-133 Audit or a Federal Audit Clearinghouse SFAC form to review.
  • Issuing a management report summarizing results of our review.
  • Sharing information from our annual review with ORSP for ongoing subcontract risk assessment.
  • Responding to requests for our A133 audit data where Rutgers is the subrecipient entity.

ANNOUNCEMENTS:

1)ORSP and DGCA are closed for the winter break, beginning Friday, December 25 through Friday, January 1. Both offices will reopen on Monday, January 4, 2016, for their regular business hours.

2)The New Brunswick offices of ORSP and DGCA are scheduled to relocate to 33 Knightsbridge Road in Piscataway in January. Moves will be staggered to reduce impact on office function.

  1. DGCA is scheduled to move on January 14-15, 2016.
  2. ORSP is scheduled to move on January 19-20, 2016.

More information about their respective moves will be posted on the ORSP and DGCA websites.

This move ONLY affects those personnel who are currently located in ASB 3 in New Brunswick. Other research administrative personnel will remain in their usual locations. Please contact your grants specialist or grant accountant if you have questions or concerns.