Managing Subcontracts and Consortium for NIH and Federal Funding

Managing Subcontracts and Consortium for NIH and Federal Funding

Ramadhani Abdallah Noor, and I am a medical doctor and a research
associate for an organization — working with an organization
called Africa Academy for Public Health, based in Tanzania. I’m going to talk to you on managing
subcontracts and consortiums for NIH and federal funding. So, to start with this talk, I will start by
giving you a bit of a background as far as managing subcontracts
and consortiums for NIH and federal funding. We’ll touch on some of the key areas in
terms of sub-grant management. We’ll touch on a bit on different
organizations system review, and then the common compliance pitfalls and
strategies to overcome them, or success, and then lead you through on
where you could find some more case studies as far as this subject is
concerned. So, as a background, really, managing
subcontracts and consortiums for NIH and federal funding, it matters a
lot. And it’s mainly about having systems in
place, and procedures, as well as activities and compliances towards
those international requirements, or the donor funding, the
funding organization requirements. These should cover the whole spectrum,
starting with the pre-award, during award phase, as well as the
post-award. Now to be able to have a good guidance
throughout the whole cycle, the grant management cycle, on what things
to do and what things not to do, there are some guidelines that exist,
and I would like to bring this forefront for your attention to
be aware of where you could access some of these resources that
would be very useful in terms of guiding you. The first thing that it’s important to be
aware of is that NIH, as a funding organization, has a Grant Policy
Statement that is usually oftentimes updated on annual basis, and this
will give you guidance on some of the micro details related to the
activities pertaining to grant management. You will also receive with every grant award
a notice of award that also speculates some of the guidance useful
for your grant management. We expect that you also have — at your
level of the institution, you’ll have institutional policies. And in addition, there will always be some
reference that will be done from Code of Federal Regulations;
you’ll hear about CFRs as well as from some circulars from Office of
Management and Budget. As a prime administering a subcontract, you
have to assure NIH that you will hold all your subcontractors to the
policies required to comply with the funding regulations. Now the scope of issues that relate to
grants management and consortium, management for NIH and federal
regulation, is so wide. It ranges from general issues, but also it
goes to very specific issues. Let’s say some guidance as how you will
develop and submit your application, what kind of procedures you
need to have in place or policies at your own institutions, how you
should go about monitoring your grant, how the scientific and the
fiscal systems and operations will overlap, the standards of contact, the
agreements, different types of costs that are involved, allowable
and unallowable, how you manage your records — to the very specific
procedures or activities, like travel, procurement, personnel, time
and effort. So the scope is really wide. And that’s why it’s very important to be
aware of where exactly you can receive some guidance on how you should
go about whenever you are implementing some of these grant-related
activities. Since, when I started, I touched on the NIH
Grant Policy Statement as one of the key documents that is
available for guidance, I’d better talk a little bit about this
document. So this document, you will have access to it
through the NIH Web site, and this document again takes you step
by step and gives you guidance. It is divided mainly on three main parts,
and the first part is really to give you the NIH grant
information, and this is the general
information. The second part of this document goes in
detail to tell you more about the terms and conditions that are tied
to the NIH awards. And it’s also divided into two subparts,
with the subpart A, which is very general, and the subpart B, which will
go into very specific details on that particular type of a grant
or different types of grants, different types of grantees, as well
as activities. And the last part in this document is the
third part, which really gives you various points of contacts within
the NIH. The most important thing to remember, as far
as the NIH Grant Policy Statement is concerned, is that this
document is updated on annual basis, so you have to be sure that, whenever
you’re consulting or you’re seeking guidance from this document,
you are actually doing it from the updated version or the most current
version. In terms of general issues, when you talk
about general issues, really we are looking into issues such as
the good organizational charts, how you should organize the
organograms for your organizations, how they should be presented,
the clear identification of the responsible person within that grant
as a team, as well as the very specific terms of reference for your
various key members that are actually involved in that grant. It will guide you on how to present the
clear lines of sort of delegation authorities, how you should
structure your communication, clear communication lines, as well as the
very essential required registrations that are needed for your
organization as well as for your principal investigators who are
actually leading those types of grants. When it comes to policies, procedures, as
well as the standard of conduct, we expect and actually the
guidance, you will receive guidance in terms of what types of policies
you need to have in place at the institutional level. For example, you will find policies for
research misconducts, there will be policies and guidance in terms — or
guidelines in terms of conflict of interest, confidentiality
agreements, and so forth. These various types of policies or
guidelines, institutional policies need to be well-documented, need to be
approved by agents. Then, after having these policies in place,
the next level is really to make sure that all staff to whom these
policies apply are sufficiently trained, but also you
demonstrate some evidence in terms of different ways of enforcing these kind of
policies at the institutional level. In terms of preparing your application, it’s
important from the beginning to realize that this is a
teamwork, and you will have a lead person who will be the principal
investigator, but the whole team needs to be coordinated from the very
beginning in terms of understanding first from the first place,
understanding the RFA, the call announcement requirements, and be able
to think together in terms of how you as a team or the
institution is eligible to that particular RFA, but also what will be the
overall impact of what you’re trying to submit for funding. It needs, when you work out with your team
and you are developing your application, it’s important to make
sure that it’s reviewed sufficiently and it’s supported by the
institution. If an application is being developed in a
consortium sort of an arrangement, it’s important to make sure
that all members, or different entities that belong to that
consortium, have adequately participated. They have reviewed, they’ve made their
inputs, and they all support that application before it’s been submitted
for funding to NIH or for any other federal entity that has released
that RFA. It’s important also to think ahead in terms
of what sort of peer review you will seek, you will go through,
and also to relate that sort of review with the structure and how
the scoring is done or is going to be done, the scoring for your
application is going to be done, when it’s being submitted at the
funder’s office, in this case, let’s say
NIH. It’s important to run these things and to
work with your finance and accounts team because, again, as you develop
your activities, deliverables, and milestones, you also want
to tie that very closely with your team that will develop the
budgets. The team that works on the budgets will have
to make sure that really whatever inputs they make on the budgets are
supported sufficiently by the verifiable information. The budgets that are being presented or
brought in place are based on true costs and they’ve sufficiently been
reviewed by the whole team within the finance unit, or the
accounting unit. Again, together as a team, you have to think
of the mode of submission, and in this case nowadays it’s
electronic submission, which needs to be well understood and
thought about ahead of time. Again, this is to avoid the last-minute
surprises — when it comes to electronic submissions sometimes, and
especially when it’s the first time that you’ve not had people who have
experience to go through that procedure, it may be technically
difficult and it may require some support. So, you have worked very well with your
team, and you have been successful. You have received a grant. You will typically receive what they call a
notice of award and then you will go ahead with various other
different types of agreements that may be applicable for that
particular type of grant. You’ll have your approved proposals or
protocols, depending on the nature of the grant itself. What is key, then, is really to be able to
have a system in place that will allow you to do periodic, sort of
programmatic reviews in terms of how you implement that particular
grant. You’ll need to reflect on your deliverables. You need to review your deliverables and the
milestones frequently to see whether you’re on track, that’s the
first thing, but also to see whether not only that you’re in the right
direction but also those deliverables and milestones are being
achieved as planned on the initial approved application. And again, this review should also be not
only on the scientific aspects of the grant but also on the
financial aspects, the management aspects. For example, you need to review in terms of
your actual and your actual expenditures vis-à-vis the budgets
that you had in place from the first place. It’s important to be also very vigilant in
terms of how your fiscal as well as scientific operations overlap,
and especially in this case, it’s very, very important for your
team, particularly your grants management team, to help the
scientists or the team that takes lead in that particular project in terms of
avoiding any duplication of payments. And in this case, I could give you example
that you might have payments that are done, either they’ve been
duplicated within the same research, for example, within the same
equipment in different grants or time of research, which is a very
common example — the effort, what we call the effort being sort
of duplicated within the two different grants. So avoiding these types of things will help
you to be able to justify but also report your grant progress much
better as you go along. When you are implementing your grant, or you
are managing your grant in a consortium arrangement, then there are
a few things that are important from the beginning to think about. One of it is, it’s important from the word
“go,” from the start, to think adequately as a consortium and agree
on mechanisms that you have in place to steer the whole
team forward, so that you could move as one consortium, because a
consortium can have three, four, five, or sometimes even more
institutions involved, and in those kinds of arrangement, it’s not
uncommon to have one institution lagging behind or disagreeing on something,
or a few of the institutions that are involved in the
consortium making much more steps forward — I mean, making progress
much faster than the rest of the members. So to avoid that, it is important to have an
agreeable way to steer all members forward. You need to agree on how you’re going to
have decision-making mechanisms within your work. You will need to think about having things
like communication plans, which will sort of guide each member of that
consortium on how to communicate, when to communicate, so that
you could harmonize and pretty much standardize the way you
communicate as one team and rather than communicating as differently and
you might be perceived as sort of having different or sub-teams
within one bigger team. Some of the things that are key to touch on,
an important area as far as grant management and consortium
management, in particular for grant management, I think you will hear a
lot about the indirect costs. And as far as indirect cost concerns, I will
say a few things. One, I think it’s very important to have a
very good understanding on what is the allowable rate for the indirect. What are the policies concerning indirect
costs for that particular funding and, in this case, NIH? What rate is allowable to deduct as indirect
costs? How should you go about it? How are those costs — what are those costs? Are they clearly identified? And again, if you go to your NIH Grant
Policy Statement, it will give you a very good guidance on how you should
go about your indirect costs. But what is key here, again, is to note that
the indirect costs should not be — and in some cases, some
institutions will make that mistake — should not be deducted ahead of
time. So, suppose you receive your grant today,
and you receive an installment. You may not go ahead and deduct your
indirect costs, but rather you should end those indirect costs after you
have sort of gone through some of the activities and expenditures. Then you’ll be able to end that particular
percentage from the money that has been spent. As far as records management, I think it’s
important to have the right policies in place, and this will guide
you how you should go about collecting your data, store your data,
archive your data, but also dispose it. This should cover a whole range. It’s not just the data from the field but
including the biological samples, and here you should also look at
the material transfer agreements and data management plans, what
sort of data-sharing agreements that you need to have in place. In terms of banking and payment, usually you
will need to have separate bank accounts for the grant. It may not be possible to have in practice
really different bank accounts, but you might come up with an
arrangement that within one account that — let’s say it’s an account
for NIH funds — you might have different projects or different grants,
different codes, so sort of having some accounts in it. You need to maintain accounts that allow
electronic transfer of funds. You need to have systems in place that sort
of guide how you can initiate how the payments are authorized,
how are they approved, and usually the authorization is expected at
least to be preferably coming from two authorities within the
institution. As far as budget preparation and controls,
the most important thing here is to make sure that you keep
monitoring your burn rates on monthly basis, on quarterly basis vis-à-vis
the actions that you had on your budgets. You need to have internal control mechanisms
that can be in the form of an independent accountant, or it can be
done through the internal government auditors. And what we need to also be mindful here, if your institution receives in aggregate a
total of $500,000 or more federal funding, then you need to
have a special type of audit that has been actually in accordance to the — a particular
circular, which is an OMB A133, and this special award, you receive guidance
from the NIH policy statement on how you should go about it. As far as personnel and payroll concerns for
personnel, you need to have written policies, manuals in place, job
descriptions for all your staff, annual evaluations being done,
the time and attendance. This is the effort, well reviewed and
updated every quarterly or every month. The payroll needs to be generated based on
the percentage effort each of the staff is put in various projects that
they are involved in, needs to be verified by a second person and
approved by the PI, and the payments should be in the form of direct
deposit. When it comes to procurement, property
assets management, you need also to have written policies at the
institutional level. You need also to be mindful of the local
applicable or the national procurement acts that actually you might
need to comply. For some large expenditures or large
processes, you might need to have three quotations, or you might need to
find out what sort of guidance you have in place on your
procurement act as how you should go about it in a manner that is most
compliant. These procurement laws, again, are
applicable in a whole range, not only just the procurement of your capital
infrastructure or assets, but sometimes some of these laws are
translated into how you should hire your staff, how you should go about the
hiring, and so forth. As far as property management concerns, all
that belongs or has been obtained through these grants needs to be
registered, needs to be recorded, the appropriate inventory needs to
be maintained, as well as how you should go about it. As far as travel, again you will notice with
everything you need institutional policies in place, how the
travel is being approved, how the claims are being verified, the per
diems are being sort of arranged, how you should organize your
travel. Again, the most direct rules: you will not
be able to exceed the coach class fare. The guidance from the NIH policy statement
will guide you to travel with U.S. flag carriers, and in place where you don’t
have the U.S. flag carriers in place, usually you’ll find
some airlines which are partner airlines, and those will be
compliant. You should also be mindful of any U.S. foreign travel restrictions that may be
existing by then. You may, at one point or another, be
involved or required to participate in a financial system review,
which is called a Foreign Organization System Review. This is really not an audit, but usually
it’s an assessment or a review that is done to sort of assess the
ability to manage U.S. federal funds in an accountable manner and usually to be contracted with third
party by the funder. They’ll come and work with you to assist
your compliance in terms of NIH conditions, provide a global outlook in
terms of the internal procedures that you have in place, what
needs to be improved, and really it focuses on promoting the
understanding between your team to the different or various type of guidelines
that you need to comply. Now, in terms of the common compliance
pitfalls, as you would see the scope from the beginning it was so wide,
but some of the common pitfalls that most teams have
experienced is that they might find it tricky to deal with what is
allowable, an allowable cost. Sometimes you might find that the
misallocation of cost, excessive cost transfers, inaccurate effort reporting,
or inadequate sub-recipient or sub-grantee monitoring. Sometimes you might have issues with how you
go about the closeout, so these are some of the common pitfalls. If you go to the NIH site, you will find
additional resources that will guide you beyond the policy statement,
and I think one of the things that you might find is there is a
collection of case studies, which have been collected and generated from
experiences that different grantees have had in terms of
compliance, pitfalls, as well as strategies to avoid them. And I think, as you see, this slide will
provide you the information that can allow you to search for those case
studies, which will be a very good way forward for those who are
interested to learn more about NIH grant management as well as
consortium administration. Thank you very much.

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