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Federal and Foundation Grants, Contracts, Cooperative Agreements, Subcontracts

Columbia University Policies and Procedures

This is an overview of how sponsored projects are handled in the CTO.  For more details of Columbia University’s policies and procedures, please review these documents:

    Sponsored Project Handbook
    Columbia University’s Policy Library
    Research Administration
    Office of the IRB

Finding Funding – Federal Guidelines and Forms

Department of Health and Human Services (DHHS)

     National Institute of Health (NIH)

         NIH Guide for Grants and Contracts
         Program Announcements (PAs)
         Request for Applications (RFAs)
         Request for Proposals
         NIH Grants Policy Statement
         NIH Forms and Applications

Office of Management and Budget Circulars (OMB)

OMB Circular A-21 – Cost Principles for Educational Institutions
A-21 establishes the cost principles for allowability of costs incurred by institutions of higher education under federally-sponsored agreements.
OMB Circular A-110 – Uniform Administrative Requirements for Grants & Other Agreements with Institutions of Higher Education, Hospitals and Other Non- Profit Organizations
This circular establishes the administrative standards for grants and cooperative agreements to non-governmental organizations.
OMB Circular A-133 – Audits of States, Local Governments and Non-Profit Organizations
This circular establishes audit requirements for states, local governments, Indian tribes, and nonprofit organizations.

Deadlines

NIH Deadlines

Internal Deadlines: To ensure the pre-award officers with which you work have ample time to review a proposal prior to submission, please provide this office with the required submission five (5) business days prior to the due date.

Preparing a Sponsored Proposal – Proposal Guidelines (Federal Grant, Contract, Cooperative Agreement, Subcontract Site)

In the event that you are preparing the following documents for a Subcontract when CU is not the prime, please submit the Subcontract Proposal Facesheet and substitute the Abstract for the Statement of Work.

Facepage (PHS 398 or Subcontract Proposal Facesheet or CU Default Facepage)
Abstract or Statement of Work
Budget and Justification
Biosketch
Science and Literature Cited
Letters of Support (i.e. consortiums, drug companies, etc.)
Required Documentation / Approvals

You can find your sponsor required forms via the sponsors website.  If federal, see Federal Guidelines and Forms above.  The Subcontract Proposal Facesheet and the CU Default Facepage can be found at https://cait.cumc.columbia.edu:88/research/website/3/1, on RA’s website at the Forms Repository Page.

Frequently Requested Information can be found at RA.

Budget Preparation (Non-Modular)
The budget preparation is the same for grant & contract submissions regardless of foundation or federal sponsors.  In addition, if you are preparing a subcontract that is cost reimbursable, you will follow the same budget guidelines as outlined below.

Direct Costs:

       Salaries – salary figures should be based on the percentage of effort of each individual on the project based on his/her annual salary (base plus A1).  To calculate calendar months for NIH submissions, click here for the conversion calculator.

       Fringe – the fringe rate is a percentage of salary and does vary.  Currently our fringe rate for federal budgets is 27.1% and for foundation budgets is 31.1%.  Our fringe rate can be found on page two of our DHHS rate agreement located here.

       Equipment – is any item having a unit cost of greater than $2,000 and a useful life of two years or more.  This cost should include the shipping of said equipment.  Further information regarding CU’s policy on equipment can be found .

       Materials and Supplies – are expendable items with a useful life of less than two years and individual items that do not fall into the equipment category (above).  The costs are generally provided via a vendor quote.  If you are applying for a federal contract, please note that you may need to prepare a Small Business Plan and you can get further information here.

       Patient Care Costs – There are two types of patient care costs: inpatient and outpatient.  This category is for the cost of laboratory tests and ancillary services being performed at the hospital.  The full definition of patient care costs as defined by NIH can be found here.   These costs are NOT for tests that are Standard of Care.  All Standard of Care tests should be charged to third party insurance and not charged to the budget.  The prices for patient care laboratory tests and ancillary services can be found on our Chargemaster or by contacting our budgets group.

       Consultants – A consultant is generally an individual that CU contracts with for a specialized skill, expertise or knowledge.  List each individual and their rate of reimbursement on the project.  Further information can be found at RA’s website .  Once the the award is made, the consulting contract will be prepared by Purchasing and you can access further information at procurement.columbia.edu.

       Travel – Domestic and Foreign travel should be listed separately.  List the destination or the travel reason, and include the transportation costs, registration fees, accommodation fees and other related expenses.  You can find more information about Columbia’s travel policies at finance.columbia.edu. Funds can be requested for travel to scientific meetings, to collaborating laboratories, and for consultation with the funding agency or with colleagues concerning project research. Please note that PHS policy dictates that travel be on US carriers.

       Other Costs – This category is generally for items such as patient reimbursement, patient travel, pharmacy costs (please contact the pharmacy directly and submit a cost estimate with your budget), lab work being that is being done at an outside lab (i.e. Quest, Bendiner & Schlesinger, etc.), central computer charges, shop charges, core facility charges, publication costs, copying and telephone charges, professional fees, maintenance contracts and the rental of equipment.

       Consortium costs / Subcontracts – The budget for a subcontracting/consortium institution should be developed in the same manner as Columbia's budget. The only difference is (at least in the case of PHS grants) that the institution's indirect costs are included as part of the budget. Foreign institutions cannot submit indirect costs as part of their proposals unless they have a indirect cost rate approved by the federal government. U.S. institutions which do not have a negotiated indirect cost rate can use 10% until a rate is formally approved.  You can access further information at RA’s website .

Indirect (Facilities & Administrative Costs):

       F&A rates are negotiated with Columbia University’s cognizant federal agency, the Department of Health & Human Services (DHHS).  Currently the F&A rate for federal submissions is 61%.  The DHHS rate agreement can be found here.

       If the sponsor has policies restricting or reducing the F&A rate (i.e. foundation, etc.), the budgets should reflect those policies.

       Columbia University’s F&A rate is based on the Modified Total Direct Cost (MTDC).  To calculate the MTDC, subtract the items excludable from F&A from the Direct Costs (i.e. Patient Care, Equipment, Tuition, Consortium IC).  This calculation is the MTDC and the 61% F&A rate should be multiplied by the MTDC to calculate the federal F&A rate.

Cost Share

       The Cost Share policy at Columbia University can be found here. There are three types of cost share: Mandatory, Voluntary Committed or Voluntary Uncommitted.

       Mandatory cost share applies when the cost share is required by the sponsor as a condition of the award.

       Voluntary Committed cost share is applicable when sponsor doesn’t require it but the PI promises it to the sponsor.

       Voluntary Uncommitted cost share applies when the costs are not conditional by the sponsor and not promised by the PI but are being applied to a different funding source.

Required Documentation / Approvals:

       Rascal Proposal Tracking should be prepared for every submission.  An approver needs to be listed for each department/school, so if you have staff on your proposal from three separate departments or schools, an approver needs to be listed for each one.  The personnel listed should be everyone on the project, regardless of whether or not they are key.  If cost-share is applicable, please check the box and put in the cost-share amount.

       GCP, COI and HIPAA Training should be done by each employee that works with patients either directly or with patient data.  These courses can be done in Rascal by clicking on the Administration tab once logged in with the UNI and Password.  For NIH submissions, a GCP letter is typically required.  This should be submitted with a hard paper submission at the time of submission or at the JIT stage for an electronic submission.  This form can be found on RA’s website on the Forms Repository Page.

       Effort Reporting Certification – This is a federally mandated process that requires certification that salary charged to a sponsored project is reasonable in relationship to the effort on that project.  For more information, the ECRT policy can be found at https://effortreporting.columbia.edu/policy.html.

       IRB Approval can be pending at the time of submission but must be approved prior to an account being opened post-award or a contract ready for signature. Further IRB policy can be found at https://www.cumc.columbia.edu/dept/irb.

Submitting a Sponsored Proposal

The review and submission of all proposals must be reviewed and approved by an authorized official at Columbia University. Clinical Trial submissions will need to be reviewed and approved by one of the pre-award project officers at CTO.  The approval is generallymade by signing the application regardless of whether the application is being submitted via paper or electronically.

       Paper Submission – Although NIH and other federal agencies are moving towards electronic submissions, not all submissions are accepted in this format.  The guidelines for each specific proposal will clearly indicate how the proposal should be submitted.  In this format, once reviewed, one of CU’s authorized signatories will sign the proposal and return to you for copying and mailing to the sponsor.

       Electronic Submission – If the proposal is being submitted electronically via InfoEd, Proposal Central, Grants.gov using PureEdge or any other electronic portal, the approval is in the form of an electronic signature or by clicking the submit button. This action of submitting a proposal can only be done by an authorized signatory of the University. Some small foundations, however, might require the PI to submit directly, usually with a signed facepage or letter included in the submission.

Just In Time (JIT) Submission

Prior to receiving a Notice of Award (NoA), a JIT submission is typically requested by NIH. This request does not guarantee an award but always preceeds one. If all the information requested is prepared and there are no problems, the NoA is typically forthcoming. This request usually consists of IRB approval, Other Support pages for key personnel and GCP certification (if not already submitted), The JIT may also include a revised budget and justification if the reviewer had found an error or the PI was asked to make a change. Ultimately, the JIT request can include anything. If this is a federal contract, typically the Small Business Plan is due at this time, as well.

An Awarded Proposal

A federal award is generally made public via email to Research Administration, the Clinical Trials Office and the Principal Investigator. In addition, the notification of an award is available on the eRA Commons website, at the Status page.

       Notice of Award – When received by the PI or administrator in the department, it should be forwarded to the pre-award office for processing. Most sponsors recognize the acceptance of an award the moment that money is drawn down, meaning that expenses have been pointed to the account. Therefore, an account will be delayed if there are any problems with the terms and conditions of the award or the budget differs from the proposed. These will be addressed with the PI or administrator to resolve.

       Award Letter – An award letter is typically issued by Foundations.. The same rules apply as above in that an account will be delayed if there are any problems with the terms and conditions or if the budget differs from what was proposed. These items will be addressed with the PI and/or administrator to resolve.

Setting up a Sponsored Account

Once the NoA or the Award Letter has been accepted, the budget will be setup in OPG and an account will be created. An SPBA will be generated by the system) and will be distributed to the department along with the backup documentation (i.e. NoA, Award Letter, Amendment, etc.)

The budget will be entered into the OPG system as it appears on the NoA. The consortium line item will be for all subcontracts until they are fully executed and at that time, an individual subcode will be created for each contract and/or each PO.

If the account is for a fee-for-service subcontract, the account will be opened but no budget will be entered. As checks are received by the sponsor, they will be deposited into the account and a cost breakdown will be requested by the post-award group to determine how the budget will be disseminated (i.e. other, supplies, etc.) NOTE that IC will be calculated in the budget as each check is deposited.

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