FAQ

1. What is a Modified Total Direct Cost?

Modified total direct costs shall exclude equipment, capital expenditures, charges for patient care, tuition remission, rental costs of off-site facilities, scholarships, and fellowships as well as the portion of each subgrant and subaward in excess of $25,000.

2. What is Cost Sharing?

College and non-sponsor resources provided in support of sponsored programs; includes contributed effort and matching funds.

3. What are Facilities and Administrative Costs?

Facilities and administrative costs (F&A) costs are those that are incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular sponsored project, an instructional activity, or any other institutional activity. F&A costs are broad categories of costs. “Facilities” is defined as depreciation and use allowances, interest on debt associated with certain buildings, equipment and capital improvements, operation and maintenance expenses, and library expenses. “Administration” is defined as general administration and general expenses, departmental administration, sponsored projects administration, student administration and services, and all other types of expenditures not listed specifically under one of the subcategories of Facilities (including cross allocations from other pools).

4. How do I Request a Change in Key Personnel?

In order to request a Change in Key Personnel, please complete and sign the Rice Institutional Approval Form. If you have any questions, the PI or departmental administrator should contact their assigned OSP Grant Specialist or send an email to: osp@rice.edu.

5. What is a No Cost Extension (NCE)?

Provides for an additional period of performance with no additional costs to the sponsor to accomplish project goals. For NCE procedures, NCE’s may be handled internally in certain circumstances or sought externally from the sponsor. For NIH grants, No Cost Extensions can only be requested for the following reasons: – Need to provide continuity of project activities while a competing renewal is under review. – Permit orderly phase out of activities such as data analysis or compilation – Time to complete publications for submission

6. Who do I Contact to Request an NCE?

In order to request a No Cost Extension, please complete and sign the Rice Institutional Approval Form. If you have any questions, the PI or departmental administrator should contact their assigned OSP Grant Specialist or send an email to osp@rice.edu.

7. Can a Charge Be Put on an R-Fund After the End Date of the Award?

The charge has to be incurred/encumbered prior to the end date of that award for it to be allowable on the associated R Fund. Depending on the Sponsor, they will allow 30, 45, 60, or 90 days after the end date forcharges incurred prior to the end date to hit the R Fund but it must have been expended and paid for by the end of the allowable period of invoicing time.

8. What Are Typical Allowable and Unallowable Expenses on Sponsored Research Awards?

Allowable and Unallowable costs on federally funded sponsored research awards are defined in OMB Circular A-21. According to OMB Circular A-21, the cost of a sponsored agreement is comprised of the allowable direct costs incident to its performance, plus the allocable portion of the allowable facility and administrative costs of the institution, less applicable credits. The tests of allowability of costs under these principles are: - They must be reasonable. - They must be allocable to sponsored agreements under the principles and methods provided herein. - They must be given consistent treatment through application of those generally accepted accounting principles appropriate to the circumstances. - They must conform to any limitations or exclusions set forth in these principles or in the sponsored agreement as to types or amounts of cost items. The following items of cost are NOT allowable according to Section J of OMB Circular A-21: - Advertising, Public Relations - Alcoholic Beverages - Alumni Activities - Bad Debts - Certain Legal Costs - Charitable Contributions - Contingencies - Entertainment - Fines and Penalties - First Class Air Travel - Fund Raising, Investment Management - Goods and Services for Personal Use - Housing of Officers - Interest Expense for Operating Purposes - Lobbying Costs - Losses on Sponsored Research Agreements - Memberships in Civil, Community and Social Organizations - Selling and Marketing Costs - Telephone Line Costs Other items of cost may not be allowable depending on the circumstances; in these instances, the PI should discuss with their OSP Grant Specialist.

9. What is a Subaward Agreement?

Also referred to as a subcontract or subrecipient agreement. A contract issued under a prime contract, agreement, purchase order, or grant for the procurement of purchased program-related tasks. Issuance of Subaward Agreements under federal prime award is subject to compliance with federal law and all Subaward Agreements are subject to the terms and conditions of the prime award and the normal purchasing requirements of Rice University.

10. Does the Salary Cap apply to all federal grants and contracts?

No, the salary cap only applies to NIH, SAMSHA, and AHRQ (not on DOD, NSF, or NASA). Please use the institutional base salary for all other grant applications. The current cap is $187,000 effective January 8, 2017.

11. What is Just in Time (JIT)?

“JIT” is an acronym for Just-In-Time, and refers to the application timeframe requiring applicants to send information and documentation to federal agencies like NSF, NASA, NIH, and DOD only if an award is likely. This process decreases the administrative burden for the 75%-80% of the applications that will not receive funding and provides NIH with the most current information “just in time” for award. When JIT is posted in the “Action” column of your NIH eRA Commons account, it signifies that your application has completed the peer review process and has received a rank for which funding may be possible.

12. What is included in JIT?

- Other Support Report (Also referred to as Active and Pending) -Update for all Key Personnel - Do not include for Other Significant Contributors - Address any budgetary or scientific overlap concerns - IACUC Approval signed by institutional official - Human Subjects Assurance Certification - Human Subjects Education Certification Form.

13. What is the China restriction on grants?

In February 2012, NASA provided information detailing that federal appropriation bills for the past two years (NASA’s 2011 continuing resolution and NASA’s fiscal year 2012 appropriation) contain a funding restriction with respect to China. Specifically, the funding statute states that none of the funds appropriated may be used by NASA to “develop, design, plan, promulgate, implement, or execute a bilateral policy, program, order, or contract of any kind to participate, collaborate, or coordinate, bilaterally in any way with China or any Chinese-owned company unless such activities are specifically authorized [by law.]” NASA’s procurement guidance states that the terms “China” and ‘Chinese-owned company” mean the People’s Republic of China, any company owned by the People’s Republic of China, or any company incorporated under the laws of the People’s Republic of China. The statute applies to any NASA grant, cooperative agreement, or contract and applies to all subrecipients at any level. Therefore, the restriction prohibits Rice from collaborating with or issuing a subaward to the Chinese government (e.g., the China National Space Administration), a government-owned company, or a company incorporated under Chinese law. This includes using NASA funds for the U.S. side of a collaboration with these entities that is performed on a “no-exchange-of-funds” basis. The restrictions do not apply to commercial items of supply needed to perform a grant or cooperative agreement. Please note that the appropriations law does not restrict the use of NASA funds to support Chinese national students or visiting researchers.

14. What is the difference between a Subaward/Consortium and a Professional Services Agreement?

There are times when it is more appropriate to pay another entity via a professional services agreement, rather than a subaward/consortium. If the former situation applies, the institution/organization is called a vendor. In your budget and budget justification, list this payment under Other Direct Costs rather than on the line for subawards/consortium. We normally issue subawards/consortium arrangements: – if a collaborator will perform work as part of institutional appointment; or – if a collaborator will be contributing to the scientific development or execution of the project (not running lab assays); or – a collaborator will be contributing (listed as an author) to the publications; or – when a collaborator will be using institutional facilities, students and staff We would typically issue service agreements if: there is evidence that the service to be provided is essential and cannot be provided by Rice employees; and provides the services within normal business operations; and provides similar goods or services to many different purchasers in a competitive environment; and they do not direct, carry out, or implement solutions; and Rice has the right to control the end result of the service, not how the service is performed.

15. What are indirect cost and indirect rates?

Indirect costs refer to expenses of doing business or research at an organization. These expenses are necessary for the general operation of the organization and the conduct of activities it performs. Indirect cost rate is the ratio between the total indirect costs and benefiting direct costs. The indirect cost rates are approved by a federal agency (DHHS) for recipients based on an indirect cost proposal submission.

16. What is required if the indirect rate is different from the federally approved rate?

If a sponsor indicates in their guidelines a different overhead cost from what Rice is approved for, then the proposal must adhere to the proposal guidelines. If no guidelines are provided by the sponsor, then F & A Waiver Request Form must be completed and submitted for review.

17. Who is eligible to be a PI on a proposal?

According to Rice Policy 301, Principal investigator/Program Director (PI/PD) status is a privilege granted to faculty members who hold an academic appointment in the tenure-track or research ranks under Policy 201 “Faculty Appointments, Promotions, and Tenure,” (or an equivalent appointment under any successor policy). If a non-tenured track proposes to be a PI on a grant, then they will need to submit a PI Eligibility Form.

18. When is a PI required to complete the Rice Institutional Approval Form for a no cost extension (NCE)?

PIs are asked to complete the Rice Institutional Approval Form when OSP is being asked to request the NCE on behalf of the PI. If the PI receives either an approval memo via email or amendment to an agreement from the sponsor, then the Rice Institutional Approval Form is not required.

19. If a PI receives an award notice; but no proposal has been generated, what should the PI need to do?

If a PI receives an award notice for research (R-fund needed) and no proposal has been previously submitted, the PI will need to generate a new Cayuse. PIs will need to provide a statement of work (sow), budget, budget justification and proposal guidelines before the award can be processed. It is highly recommended that if a PI knows in advance that they will be receiving an award for research, the PI should begin generating a Cayuse to prevent any delays in processing their award.

20. If a supplement is being requested from the sponsor, is a new Cayuse record needed?

Yes. A supplement request is considered as new proposal. The PI will need to provide at budget, budget justification, statement of work (SOW) and proposal guidelines. Your Grant Specialist will assign the supplement to the parent proposal.

21. Faculty transfers: what do I need to process?

Departments are responsible for notifying OSP Contracts Specialist (subawards@rice.edu) of any faculty leaving or new faculty coming to Rice. To assist in a smooth transition please provide the following information:

Departing faculty

1. Date of termination
2. New location
3. Awards to be transferred

Incoming faculty

1. Official date of employment
2. Awards to be transferred in