PI Advisories

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Research Compliance & Reporting

PI Advisories brought to you by the CS Grants Team and the Office of Research Costing Compliance.

2012

SEPTEMBER 2012

PHS Financial Conflict of Interest Reporting Guidance
Awards issued on or after August 24, 2012 are subject to the revised 2011 Financial Conflict of Interest regulations, including additional reporting requirements. Typically, the Annual FCOI Report will be due when the annual progress report is submitted for noncompeting continuations and multi-year funded projects. Due to the timing of the revised FCOI implementation date, reporting may be out of sync for the FY 2012 annual FCOI reporting. Therefore, FY 2012 noncompeting awards issued on or after August 24, 2012 will not be required to submit FCOI report until requested by NIH staff. The new regulations are intentionally stricter than previous policies, and may require additional disclosure on the part of federally funded personnel at all levels. Please take a few moments to become familiar with the new requirements. Read more.
New FCOI Institutional Clearinghouse Website
Prime awardee institutions are responsible for ensuring compliance with the PHS FCOI regulations by sub-recipient institutions. The Federal Demonstration Partnership (FDP) established a website where institutions can post that they are compliant with the PHS 2011 Financial Conflict of Interest regulations. The intent of the FDP Institutional Clearinghouse is to provide a quick and easy way for institutions to verify that a proposed sub-recipient has an institutional FCOI policy that is compliant with the PHS FCOI regulations. Participating institutions then reduce the administrative burden of submitting forms to verify they have an updated PHS-compliance FCOI policy. Read more. Or view the Frequently Asked Questions.
Changes Involving Human Subjects in Active Awards
NIH has issued guidance regarding the need to obtain NIH approval prior to implementing certain changes to active awards involving human subjects. For active awards, NIH requires prior approval for changes made to research procedures that will increase the risk to human subjects. The NIH guidance states specific types of changes that require approval prior to implementation. Read more.

MARCH 2012

NIH Discontinues Inflationary Increases
The National Institutes of Health (NIH) Fiscal Policy for Grant Awards – FY 2012 has discontinued inflationary increases for future year commitments for all competing and non-competing awards issued in FY 2012. Revised awards will be issued to adjust future year commitments for this change in fiscal policy. Read more.
Further Details Regarding Salary Cap
The National Institutes of Health (NIH) and Agency for Healthcare Research and Quality (AHRQ) have issued more detailed guidance regarding how to apply the revised salary cap of $179,700. The guidance distinguishes between competing and non-competing awards issued in FY 2012 on or before December 22, 2011 and those issued on or after December 23, 2011. Read more.

FEBRUARY 2012

Guidance on Reduced Salary Cap
The reduced salary cap will now be applicable to all Department of Health & Human Services agencies (HHS), according to HR 2055 (2012 Consolidated Appropriations Act). The National Institutes of Health (NIH) has issued guidance regarding the reduced salary cap to the Federal Executive Level II, $179,700. The new Executive II salary level is applicable to FY2012 NIH funds awarded on or after December 23, 2011. The new Executive II salary limitation will not be applicable to FY2012 NIH funds awarded on or between October 1, 2011 and December 22, 2011. However, if these awards continue into FY2013, the new Executive II salary limitation will become applicable. The new Executive II salary limitation will not be applicable to NIH funds awarded in prior fiscal years (FY2011, FY2010, etc.) that have been carried over into FY2012. Read more.

JANUARY 2012

Salary Cap Reduced in FY2012 Consolidated Appropriations Act
The 2012 Consolidated Appropriations Act includes a reduction of the salary cap applicable to grants, cooperative agreements and contracts issued by the National Institutes of Health (NIH), Agency for Healthcare Research and Quality (AHRQ) and Substance Abuse and Mental Health Services Administration (SAMHSA). The salary cap for these Federal agencies has been set at the Federal Executive Level II ($179,700). It is unclear what timeframe this reduction will effect. Further details and guidance will be communicated as soon as possible to the grant management community through deans, directors and management centers.
ARRA Funds Must Be Spent by September 30, 2013
Although the majority (85 percent) of the grant funds provided through the American Recovery and Reinvestment Act (ARRA) have been spent, the Office of Management and Budget (OMB) wants to expedite the spending of remaining funds. The OMB issued a memorandum stating that remaining grant funds received from the Recovery Act must be spent by Sept. 30, 2013. Funds not spent by this date may be reclaimed by the agencies. In response to the OMB memorandum, agencies are now issuing policy notices providing further guidance. Read more.

2011

NIH Inflation Rate Reduction
Beginning August 1, 2011, in accordance with a change in NIH guidelines due to budget restraints, Duke will use a 2% inflationary adjustment on all NIH applications.This covers recurring costs on non-competing and competing research grants for Fiscal Year 2012 and beyond. NIH salary cap restrictions are still applicable. ORS recommends referring to NIH Notice NOT-OD-11-068 for the specific details on inflationary adjustments. Since NIH has already returned an application that included an inflation rate of 3% moving forward, ORS will begin returning to the initiating department any NIH proposals and subcontract proposals with an NIH prime using an inflation rate greater than 2%.

NSF Data Management Plan Requirement
As of January 15, 2011, NSF requires all proposals to have a data management plan or a justification for why one is not required. The plan must detail the actions the researcher will undertake to share data and related supporting materials at modest cost to the researcher. Cost associated with implementing the data management plan are allowable in accordance with federal and Duke’s cost principles.

The plan will be reviewed during the proposal review, and will be evaluated based on the basis of the practices of the field. Evaluation will also take place as a part of the annual review process and following project completion. Proposals submitted without plans will not be reviewed by NSF.

See http://guides.library.duke.edu/content.php?pid=129303&sid=1398416 for resources prepared by the Duke Libraries to assist with data management plan preparation.

For more on the NSF data sharing policy and FAQ:
http://www.nsf.gov/bfa/dias/policy/dmp.jsp
http://www.nsf.gov/bfa/dias/policy/dmpfaqs.jsp

Updates will also be posted at: www.ors.duke.edu

Registering International Travel Plans
Duke’s new International Travel Policy urges, and sometimes requires, all faculty and students to register their international travel plans in advance with the Duke Travel Registry. Be sure to review the relevant policies when planning your travel, and please also encourage your students to review relevant policies at https://eruditio.aas.duke.edu/international/

SPS Web Awards Expands
The online proposal and awards tracking tool now has a new link to allow PIs to track the contract negotiation process. See https://adgapps.duhs.duke.edu/sb. Click on the contract status link and SPS Web Awards will generate a summary page to see where your research contract stands in ORS.

NIH Offers ‘All About Grants’ Podcast
The National Institutes of Health (NIH) has recently posted an “All About Grants” podcast featuring a variety of topics, such as “Navigating a Funding Opportunity Announcement” and “Getting Ready to Submit.” This valuable tool allows you to download episodes, listen to the MP3 version, view the transcript or subscribe via iTunes. Read more: http://tinyurl.com/6gbb754
New PI Continuing Education Required for Faculty
This is a reminder that all PIs with active federal grant awards need to complete the PI Continuing Education Module by May 1, 2011. You can find the link to the training module at: http://tinyurl.com/67z3fte
Early Bird Check-in Fee Discouraged
This optional fee may soon become unallowable. Check-in beginning 24 hours prior to flight departure is available for no fee. Duke travelers are encouraged to use the no cost option to obtain their preferred boarding status.
Fly America Act and Open Skies
Consistent with the “Fly America Act,” Duke University generally requires travelers who will be reimbursed from federal grants or contracts to use U.S. flag air carrier service. “Open Skies” agreements offer a key exception. Read more: http://tinyurl.com/4pdod9s
ORI Releases Responsible Conduct of Research Video
The HHS Office of Research Integrity (ORI) has produced an “interactive movie” called “The Lab: Avoiding Research Misconduct.” According to ORI, in the video simulation viewers become the lead characters. Responsible-conduct-of-research topics which are addressed include avoiding research misconduct, mentorship responsibilities, handling of data, responsible authorship, and questionable research practices. Read more: http://tinyurl.com/4of9otb