It’s safe to say that this has been an unprecedented fall for the MSU community. Many of us are still working remotely and missing the familiar sights and traditions that make campus especially exciting at this time of year. While we may be working in different locations, we continue to work together in support of research.
This issue of the SPA Newsletter provides updates on several processes and requirements, including the Proposal Deadline Policy, ERA Certification requirements, PI Certification statements, and what to expect during the award processing stage.
This issue also announces the Fall 2020 Unit Research Administrator Spotlight Award recipient. We are proud to sponsor this award and I am grateful for the opportunity to recognize exceptional service. As we congratulate the winner of the Fall 2020 Unit Research Administrator Spotlight Award, I also want to extend my appreciation to all research administrators at MSU. Our collective efforts support the university’s research mission, and I truly value your contributions.
I hope you enjoy the Fall 2020 issue of our newsletter. For suggestions for future content or feedback on this issue, please contact Erin Schlicher, schlic11@osp.msu.edu or me, reighley@osp.msu.edu. Author names have been included in each article for any topic-specific questions. My appreciation is extended to the authors.
-Twila Fisher Reighley, Assistant Vice President for Research and Innovation
You are likely familiar with OSP’s proposal submission deadline policy, but did you know that it’s been in place for almost six years? That’s right, it went into effect December 1, 2014. For those of you who might not be familiar, the proposal submission deadline policy is as follows:
Complete proposals are to be submitted to the Office of Sponsored Programs (OSP) at least three (3) full business days prior to the submission deadline to be considered on-time by OSP. Unless the deadline is specifically defined as earlier than 5PM by the sponsor, the submission deadline is 5PM Eastern Time (ET) on the sponsor’s specified deadline date (even if the sponsor allows submissions beyond 5PM ET).
There are several reasons why the policy was implemented, as well as several benefits to doing so.
- Based on the above criteria, only 13% of proposals submitted in the months leading up to the policy implementation would have been considered on-time. In sharp contrast, 36% of proposals submitted in the first quarter of 2020 were on time.
- Even more impressive than the increase in on-time submissions is the decrease in last minute, or at-risk, submissions. Prior to the deadline policy 33% of proposals did not get to OSP until the day of the deadline. One third! During the first quarter of this year, however, only 5% of proposals were at-risk. To review, any PD that hasn’t fully routed to OSP by 8:00 AM on the deadline day is considered at-risk. Additionally, a proposal submitted by OSP will require an at-risk endorsement from the research dean if any of the following are true within eight business hours of the deadline:
- for System-to-System proposals - any of the proposal attachments are “incomplete”,
- any significant changes are made to the proposal or the proposal attachments
- the proposal is released to OSP for submission
- a form requiring an authorized signature is received by OSP
- A large number of last minute proposal submissions increases stress on staff, which eventually leads to burn-out. Institutions that implement and enforce proposal submission deadlines see a marked decrease in pre-award staff turnover.
- Getting your completed proposal to OSP three days in advance allows for a thorough review, as well as submission at least 24 hours before the deadline. This means that if there is any sort of error or technical hiccup with the initial submission there is time for a do-over. Mistakes can be corrected, systems can be rebooted, and the proposal can still be successfully submitted.
- A thorough OSP review also decreases the number of submissions that are returned without review, as well as reducing compliance risks to the University.
Although OSP strives to provide the best possible service to everyone submitting a proposal, late submissions are not going to receive the same level of support as their more timely counterparts. For questions or assistance with the proposal submission deadline policy, please reach out to the appropriate proposal team. https://osp.msu.edu/PL/Portal/170/OSPContactsbyCollege
Congratulations, your proposal has been funded! Shortly after the Office of Sponsored Programs (OSP) receives the award, you will be sent an email. The email will include information related to the award and inform you of outstanding compliance items, such as Conflict of Interest (COI) disclosures, Export Control and Open Research Review Worksheet (ECORRW), and IRB and IACUC approvals required for award acceptance.
As PI/co-PI you can help expedite the process by:
- Keeping your annual COI disclosure up to date and completing your project-based COI disclosure at the Proposal Development stage.
- Submitting your human or animal use application to IRB or IACUC as soon as possible. OSP cannot request account number set-up for the project until these approvals are received.
- Providing quick responses to questions from the negotiator.
- Forwarding an award sent to you to OSP right away, OSP.Awards@osp.msu.edu.
As PI/co-PI please keep in mind the following:
- If the award amount differs from the proposed amount, you may be asked to provide a revised budget. If the required cost share amount differs from the proposed amount, you will be asked to provide a revised cost share budget and route an Award Revision PD for approval of the change.
- You may be asked to confirm your agreement with the statement of work as presented in the award document.
- You may be asked to respond to questions related to specific terms and conditions of the award.
- Retaining ownership of intellectual property (IP) created under the project and preserving your right to freely publish your research results are policies of the MSU Board of Trustees. The negotiation process will become more involved when the award contains terms that conflict with these policies. OSP may need to consult with other central offices such as the Office of Export Control and Trade Sanctions (ECTS), MSU Technologies (MSUT) and/or Office of the General Counsel (OGC).
- Processing times depend on overall volume and award complexity. Our aim is to keep you updated and informed. You may track the progress of the award review in KC by using the negotiation number provided in the original award email. Your research administrator should be able to help you if you have any questions.
OSP is responsible for ensuring MSU is protected and that you are able to complete the project in accordance with the award terms. Please feel free to contact your negotiator or OSP (OSP.awards@osp.msu.edu) if you need any assistance.
by Kristy Smith, CGA
Like nearly all of campus, CGA moved to remote work as of March 16, 2020. Fortunately, we had tested full office remote work one day annually and also had several staff already working remotely one day per week. This helped our transition to be fairly smooth and we have been able to effectively maintain our responsibilities. We expect to stay remote for the near future and are available to assist campus from our new locations.
We have experienced workload changes due to COVID-19 in some areas such as award extensions and compliance and similar to many other units, have been impacted by MSU’s hiring chill. We appreciate your patience as we work with the resources we have available. The best way to contact CGA is through the group email addresses which are monitored by multiple staff members. Please see the following webpage for contact information by functional group, as well as expected turnaround times, which have not changed with our transition to remote work: https://cga.msu.edu/PL/Portal/379/CGADepartmentOrganization.
Audits are an important part of sponsored programs as they provide an opportunity for sponsors to verify that MSU is complying with the award terms and conditions. As the point of conduct for approximately 35 external audits of sponsored programs annually, CGA will use this section to update campus on some of the audit activity that we have experienced or are aware of nationally.
Recent Audit Trends and Activity
- Consistent with our colleagues, MSU experienced a decrease in audit activity due to the COVID-19 pandemic in the spring and summer, which is usually a very busy time for audits. However, we believe this will be a temporary delay in activity, as we have already been contacted about multiple upcoming audits.
- The federal government provided a large amount of funding very quickly to assist with the financial needs of students and universities. MSU received several awards from the CARES Act funding and expects that due to the environment in which it was awarded, those awards will be audited.
- Due to COVID-19, many agencies allowed flexibilities in expense charging. We expect that audits that cover the COVID-19 period will focus on these flexibilities. Please review the information provided on https://cga.msu.edu/PL/Portal/1736/COVID19InformationfromSPAOSPCGA#costRelated, as well as the information published by your award’s sponsoring agency to make sure expenses during this time are charged appropriately
- MSU’s Single Audit, which is required by the federal government, is currently underway. Please be aware that you may be contacted by CGA with questions if your award is part of the audit scope.
- There have been recent audit findings at other institutions related to several areas, including charging time to current awards for work related to proposal preparation, improper allocation of expenses, sharing of technology without appropriate export control approval, as well as harassment behavior by individuals paid on sponsored program awards . Please note that audit findings can lead to disallowances, large paybacks and possible federal debarment.
Questions and comments related to external audits of sponsored programs can be sent to Evonne Pedawi at pedawi@cga.msu.edu.
Maintaining clear and open lines of communication between the central offices of SPA/OSP/CGA, college and department research administrators, and research faculty is essential to achieving effective and efficient research administration at MSU. To facilitate communication between these groups, SPA/OSP/CGA is involved with several committees and initiatives aimed at improving research administration at MSU. One such committee is the Sponsored Programs Advisory Committee, or SPAC. SPAC was created in 2014 with guidance from the MSU Strategic Plan, with the goal of listening to those involved in providing support to SPA/OSP/CGA. SPAC is chaired by the Assistant Vice President for Research and Innovation, Twila Reighley, and is comprised of faculty members and unit research administrators representing multiple colleges. Members are nominated by their college and generally serve for a three-year term.
Feedback from the committee has led to several notable advances in RA processes and resources, including:
- Improvements to multiple policies and processes, including the OSP follow up and escalation procedures, the documentation process for internal controls for account review, communication and process related to NSF reporting on harassment, and the new travel workflow design
- Creation of various resources, including the Proposal Timeline, Roles and Responsibilities documents, and FCOI resources for faculty
- Multiple upgrades to the SPA/OSP/CGA website, including a more intuitive layout, the addition of a Welcome page, and the use of an upgraded Google-powered search feature
- Enhancements to the KC Research Administration system, as well as the development of training resources and videos to help users navigate the system
- Feedback on RA training and recruitment initiatives, including the creation of new workgroups on campus focused on enhancing administrative capacity
- Feedback on the RA Spotlight Award and process; as of Fall 2020, 15 SPAC members have served on the recommendation panel to select the RA Spotlight Award winners
We would like to thank all current and former SPAC members for their valuable insights and contributions!
More information about SPAC, including current and past members and accomplishments can be viewed at: https://www.osp.msu.edu/PL/Portal/340/SponsoredProgramsAdvisoryCommittee
In 2011, Congress passed a spending bill that restricts work between NASA and the Chinese government. The act is often referred to as the “Wolf amendment”, because it was sponsored by U.S. Congressman Frank Wolf. The act must be renewed annually, and is found in Section 1340(a) of Public Law 112-10. NASA’s policy implementation states that “In accordance with restrictions in Appropriation Acts, NASA is prohibited from funding any work that involves the bilateral participation, collaboration, or coordination with China or any Chinese-owned company or entity, whether funded or performed under a no exchange of funds arrangement.”
It is ironic that in Andy Weir’s novel, The Martian, a NASA Mars mission seeks help from the Chinese government. China offers their space probe for NASA to use to bring emergency supplies to a stranded U.S. astronaut. In reality, this may not happen due to the Restriction.
Collaborations with China are not completely unheard of. In 2019, NASA and China collaborated as indicated by Thomas Zurbuchen’s comment on Twitter, "With the required approval from Congress, NASA has been in discussions with China to explore the possibility of observing a signature of the landing plume of their lunar lander, Chang'e 4, using our @NASAMoon spacecraft's instrument." Also, as noted by Mike Gould, chairman of the Commercial Space Transportation Authority Committee, in an article in Space News, the provision allows for cooperation if there is certification from the FBI and that such efforts do not pose a national security risk, and if Congress has been notified of the plan.
This Restriction is important for researchers to understand when applying for or spending NASA funding. When OSP submits a proposal on behalf of MSU, when MSU accepts a NASA award and during the life of the NASA project, the following certification applies: By submission of its proposal, the proposer represents that the proposer [MSU and any related subrecipients] is not China or a Chinese-owned company, and that the proposer will not participate, collaborate, or coordinate bilaterally with China or any Chinese-owned company, at the prime recipient level or at any subrecipient level, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement.
MSU interprets this certification by relying on NASA’s Frequently Asked Questions clarification for ROSES 2012, which includes the following statement, "A3: The statute does not restrict individual involvement based on citizenship or nationality. Rather, individuals are subject to the restriction if they are affiliated with institutions of the People’s Republic of China or Chinese-owned companies incorporated under the laws of China. Thus, a team member who is a Chinese citizen can work on a NASA project, but an individual affiliated with an institution of the Chinese state will be subject to the statutory restriction."
Therefore, when proposal applications require an authorized signature on the NASA Assurances form, OSP will first send the Principal Investigator a certification form to sign verifying that for the purposes of this project he or she will comply with NASA’s Restriction. Once the certification form is signed by the PI, OSP will sign the Assurances form to include with the proposal submission.
For most NASA applications, the NASA Assurances form is not required. For these applications OSP will copy the Restriction language from the solicitation and paste it into an email to the Principal Investigator to make them aware of the Restriction language.
It is interesting to note that the basis for this Restriction continues to be echoed in the current concerns over foreign influence. For additional information on Foreign Influence, see the previous Newsletter Article, Federal Agencies and Foreign Influence.
Please contact your applicable OSP Proposal Team if you have any questions.
Article Sources:
Subrecipient monitoring is a hot topic in sponsored programs and is so important that NSF dedicated an entire audit plan solely to it!
At MSU, Principal Investigators (PI) are required to certify the following statement with each subaward payment.
"The services for which reimbursement is requested have been satisfactorily rendered and the costs thereof are proper and due in accordance with the terms of the agreement. If this payment is for an advance, it is in accordance with the terms of the agreement and necessary to further project objectives."
Why is this certification important? Subrecipients are performing a portion of the scope of work awarded to MSU and have programmatic responsibilities. Due to the work they are performing, sponsoring agencies want to verify that MSU is monitoring it appropriately. Only the PIs of our projects will be able to attest to the programmatic work performed by subrecipients, represented by their invoiced expenses. In an audit, sponsors will look to verify that work was performed satisfactorily, not just that expenses are appropriate. Approving an invoice for payment only covers the appropriateness of expenses noted on the invoice. Therefore, the certification statement, which covers the programmatic work must be provided by the PI in one of three methods.
- Certification statement stamped and signed by the PI on the invoice
- Certified on a separate document and attached to the Disbursement Voucher
- The Disbursement Voucher can be routed to the PI who adds the PI certification statement themselves as a note on the voucher and then approves it in KFS, MSU’s financial system.
This may seem like a minor nuance but has proven to be a focus in many audits. At times CGA sees the following scenarios which are problematic and could cause audit disallowances.
- Certification statements dated prior to the invoice date. This would indicate to an auditor that the certification statement was signed prior to receiving the invoice making it difficult to prove that the PI reviewed the invoice, considered the work performed and then certified. The same is true when the same signature is reused for certification statements (where it is obvious that the PI did not sign a new statement but an old, signed certification statement was reused).
- The PI only approves the payment or simply writes “I approve.” Although this shows that they support a payment to the subrecipient, it does not address the verification that the programmatic work was performed as expected, which is an important component.
- The certification statement is completed by a departmental administrator. Review of programmatic work is the responsibility of the PI and cannot be delegated to administrators. In the event a PI is unable to certify, the Department Chair is authorized to complete the certification on the PI’s behalf.
More information is included MSU’s Subaward Policy (https://cga.msu.edu/PL/Portal/511/SubawardPolicy), as well as in FAQs related to subaward payments (https://cga.msu.edu/PL/Portal/1515/ExpenseProcessingFAQs#subawardPICert). Questions on this topic can be sent to Kristy Smith at smith@cga.msu.edu.
FALL 2020
RESEARCH
ADMINISTRATOR
SPOTLIGHT
AWARD
The offices of Sponsored Programs Administration (SPA), Office of Sponsored Programs (OSP), and Contract and Grant Administration (CGA) are honored to recognize excellence and exemplary service through the Research Administration (RA) Spotlight Award. We received many strong nominations for excellent Research Administrators, and we are happy to announce that Lu Liu was selected by the Recommendation Panel as the Fall 2020 awardee. She will be recognized with a plaque of accomplishment along with a small financial award as a token of our appreciation. Congratulations Lu!
Lu has over six years of service at MSU, providing pre-award and post-award support to faculty in the Colleges of Human Medicine, Osteopathic Medicine, and Nursing. She assists PIs with their proposals and works with OSP to ensure that the proposal is ready to submit to the sponsor. She also assists with the post-award financial management of the research accounts. Lu is known for her attention to detail, her clear communication, and her helpful and friendly demeanor. She recognizes the importance of customer service and faculty members and colleagues have noted that Lu’s efforts often go above and beyond what is required or expected in order to make the proposal submission process go as smoothly as possible.
What do you enjoy most about your job here?
“I believe many people still are not very familiar with the Research Administration position. I never set out to be a Research Administrator and never knew about this position until I got a RA job offer at the Massachusetts Institute of Technology (MIT). What I like most about the Research Administrator role is the customer service aspect and the fact that that nothing is the same day-to-day, proposal-to-proposal or account-to-account. Research Administration is a very challenging, deadline driven, and stressful job, but I enjoy assisting brilliant people and helping them get funding to do their amazing research. I also appreciate the flexible and supportive work environment in my office.”
What advice do you have for new research administrators?
“Be organized, responsive, detail-oriented and also flexible in order to meet deadlines! Don’t hesitate to ask questions and discuss issues and ideas with your colleagues! I appreciate the free discussion and collaborative environment in my office, and I’ve learned a lot through conversations with my colleagues about solicitations, account situations, etc. Also be sure to utilize opportunities for networking and training to share and obtain information.”
Thank you, Lu, for playing an integral role in advancing MSU’s research mission and for leading by example! We truly appreciate your dedication and hard work.
Stay tuned for another chance to nominate your favorite research administrator for the RA Spotlight Award next spring! Please contact Erin Schlicher at schlic11@osp.msu.edu with any questions.
Are you interested in earning your initial certification or recertifying in the Essentials of Research Administration (ERA) program? MSU provides training and development on the ins and outs of research administration including topics on pre-award, post-award, compliance, and using the Research Administration systems. The certification requirements for the ERA Program are described below.
Initial Certification Requirements
Participants in the ERA program must complete all 5 Cores AND a minimum of 3 Electives within two calendar years to earn their initial ERA certificate.
The initial certificate is valid for two calendar years beginning in the year the participant began attending ERA training sessions. For example, attending the 5 cores and completing 3 electives held throughout 2019 and 2020 will certify you through 2020, while attending the 5 cores and 3 electives held in 2020 will certify you through 2021.
Recertification Requirements
Each calendar year following expiration of your initial certification, you must earn 2 ERA elective credits. Credits can be earned by:
- Attending ERA courses
- Attending approved conferences or training programs. Send proof of completion to Amanda Jones (ajjones@msu.edu) (3-4 hours of external training is equivalent to 1 ERA credit)
- Attend or participate in one of the following for partial credit: GRAND (1/2 credit); SPAC Membership (1/4 credit per meeting attended); SPROUT Membership (1/4 credit per meeting attended)
- It’s important to stay aware of the latest information, regulations and policies for research administration at the institutional, national and international levels. Other subject-specific courses in budgeting, grant management, conflict of interest, and sponsor or agency specific conferences are also great ways to expand the depth and breadth of your knowledge. You may be able to use your Educational Assistance benefit to reimburse conference registration and course fees that you or your department have paid.
Listed below are some of the training opportunities available each year that can also count toward your ERA recertification (external to those hosted by SPA/OSP/CGA).
SPA 360 Training & Resources
Training Videos: SPA/OSP/CGA have created several training videos to assist MSU research faculty and administrators, located on our website and on Kaltura MediaSpace.
KC Training: Job Aids & Videos (20 job aids and 24 videos available) and System Updates (tips, instructions, bug fixes, training opportunities, system outages, etc.)
April 2021 KC Upgrade: Training opportunities will be available—Stay tuned!
by Mike Wolf, SPA
At SPA/OSP/CGA, we strive to provide excellent customer service in all stages of research administration, from proposal development to the final closeout of an award. We continue to use client feedback surveys to solicit feedback on our proposal, award, and post-award processes. Ratings response details are available on the SPA Metrics section of our website (two-factor authentication required).
Essentials of Research Administration (ERA) Series
SPA/OSP/CGA, in collaboration with SPROUT and an extensive network of MSU staff involved in pre-award, post-award and compliance aspects of research administration, provide a certified training series for research administrators and other support staff with responsibilities for research proposals, grants, contracts, and pre- and post-award administration at MSU.
Certification/Recertification Requirements:
- Initial Certification – ERA participants must attend all 5 Cores plus a minimum of 3 Electives within 2 calendar years to obtain the initial ERA certificate, which will be valid for 2 calendar years (beginning in the year the participant began attending ERA classes).
- Recertification – 2 Electives (or equivalent approved research-related trainings) are required every calendar year after the initial certification period.
2020 Schedule:
Three live Zoom sessions remain, along with three eLearning courses in D2L. Please register in the Ability LMS on www.ora.msu.edu/training. To register for eLearning, please email Amanda Jones (ajjones@osp.msu.edu) to be added to the course in D2L.
2021 Schedule*:
5 Cores and 15 Electives, along with eLearning options, will be available in 2021 and are open to anyone with a valid MSU NetID. Each session name below is hyperlinked directly to the corresponding registration page in Ability.
*Core classes will take place via Zoom. Locations for 2021 electives will be determined at a later date.
¹Registration for Core 1 will automatically enroll you in both sessions. You must attend both sessions for full credit.
