G.R.A.N.T.

Forum
Grant Research Administrator Network Team
Budget Development
Part II
March 29, 2019

OFFICE OF RESEARCH AND SPONSORED PROGRAMS

Agenda and Updates

Budget Development
•Budget Development Presentation: Part II
▸ Subrecipient/Contractors
▸ Cost Share
•Budget Development Q&A

Certified Research Administrator (CRA)

GRANTS Forum News, Announcement and Updates

• NIH Workshop- May 01, 2019
• Next GRANT-Forum May 14, 2019
• February survey response on Budget Development: Part I
Subrecipients &
Contractors
Subrecipients & Contractors

Objectives

•Define Subrecipient and Contractors

•OMB Guidance
•UMB Guidance
•Results of improper categorization
•Scenario Discussion
•Budget Preparation
•FAQs
Subrecipient & Contractors Defined

Subrecipient Contractor
§ 200.93 § 200.23
Subrecipient means a non-Federal Contract means a legal instrument
entity that receives a subaward from a by which a non-Federal entity
pass-through entity to carry out part purchases property or services
of a Federal program; but does not needed to carry out the project or
include an individual that is a program under a Federal award
beneficiary of such program. A Contractor means an entity that
subrecipient may also be a recipient receives a contract
of other Federal awards directly from
a Federal awarding agency
Uniform Guidance: Subrecipient

§ 200.330
(a) Subrecipients
Characteristics which support the classification of the non-Federal
entity as a subrecipient include when the non-Federal entity:
Determines who is eligible to receive what Federal assistance;
Has its performance measured in relation to whether objectives of a Federal
program were met;
Has responsibility for programmatic decision making;
Is responsible for adherence to applicable Federal program requirements
specified in the Federal award; and
In accordance with its agreement, uses the Federal funds to carry out a
program for a public purpose specified in authorizing statute, as opposed to
providing goods or services for the benefit of the pass-through entity.
Uniform Guidance: Contractor
§ 200.330
(b) Contractors. A contract is for the purpose of obtaining
goods and services for the non-Federal entity's own use and
creates a procurement relationship with the contractor.
Characteristics indicative of a procurement relationship
between the non-Federal entity and a contractor are when the
contractor:
Provides the goods and services within normal business
operations;
Provides similar goods or services to many different purchasers;
Normally operates in a competitive environment;
Provides goods or services that are ancillary to the operation of the
Federal program; and
Is not subject to compliance requirements of the Federal program
as a result of the agreement, though similar requirements may apply
for other reasons.
Contractors Exemplified

Contractors may include

•Vendor (Dealer, Distributor, Merchant)

• Individual or company who is paid a flat fee and provides
similar goods/services to various purchasers in a competitive
environment

•Consultant
• Individual or company who is paid a flat fee or rate for
providing professional advice or services
UMB Guidance

Subrecipient Contractor
A subaward is issued for the Procurement Contracts awarded
purpose of carrying out a portion for the purpose of obtaining
of an award and creates an goods and services for the entity’s
assistance relationship with the own use are not considered
subrecipient subawards for purposes of this
guidance. Such a contract creates
a procurement relationship
Indirect costs applied to the initial
$25K of each subaward when between the parties
budgeting
Full indirect costs applied to each
contractor

UMB Subrecipient Determination Checklist

Examples of Subrecipient/Contractors Activities

Subrecipient Contractor
• Project Performance • Project Performance
• Collaborates with UMB PI in • Vendors, consultants and
technical oversight of project contractors who perform discrete
scope and specific aims activities such as analysis and
evaluation on specific data sets
provided by UMB PI
• Publication
• Is author/co-author
• Publication
• • Develops work products such as
Disseminates research results at
conferences reports and evaluations which
are deliverables to UMB
• May not publish or own work
• Compliance products
• Responsible for certifying human • Compliance
and animal subject research • Limited compliance
compliance as well as award requirements and obligations
terms and conditions
Subrecipient vs. Contractor Determination
Scenario
PI, Viktor V. Doom has identified an off-site lab, Boston
National Laboratory (BNL), that will help him complete the
specific aims of his research. The lab’s scope of work
include:
•Conducting experiments focused on examining the structure,
processing and function of a plasma enzyme
•Providing a technical report that includes evaluations of
experiments and conclusions
•Publishing articles in a scientific journal in collaboration with
Dr. Doom

How would you classify this entity?

Subrecipient vs. Contractor Determination
Scenario
How would you classify this entity?
Answer: Subrecipient
Why?
Performance measured against the objectives of the award.
In this case, it is against the specific aims of the proposal
Responsible for programmatic decision making
Rights to intellectual property
Rights to publications

Adheres to OMB & UMB Guidance on Subrecipient vs.

Contractor Classification
Subrecipient/Vendor Other Considerations
What if…
A Contractor is Incorrectly Budgeted as Subrecipient
• UMB may receive proposal certifications of compliance and
subrecipient commitments that are inappropriately completed by
vendors
• UMB may not be in receipt of contractor themed statements of work
and commitment documentation such as hourly rates, works
products and milestone timelines & deliverables
• Contractors may be subjected to unnecessary compliance
requirements including inapplicable award terms and conditions and
subrecipient monitoring procedures
• UMB may issue inappropriate legal instrument (contract type) which
may delay contract negotiations and start date
Subrecipient/Vendor Other Considerations
What if…
A Subrecipient is Incorrectly Budgeted as Contactor
• UMB may not receive appropriate proposal documentation and
certifications
• UMB will need to request full subaward proposal documentation and
subrecipient commitment forms which may delay the proposal
development timeline
• If proposal has already been submitted it may receive requests for
clarifications and revisions during the review stage from sponsor
• If proposal is recommended for funding or awarded, budget revisions
may be required including a sponsor approved request to add a
subaward which may delay project timeline
• UMB may issue inappropriate legal instrument (contract type) which
may delay contract negotiations and start date
Scenario Subrecipient vs. Contractor
Junior Faculty, Tiffany Sapp of UMass Boston (UMB) is the Principle
Investigator on a large, complex proposal which will study the correlation
between sunspots and ocean temperatures. The proposal will be submitted to
the Department of Energy (DOE). The project includes collaborations with the
following colleagues, Professor Carter at Johnston University (JU) and Dr.
Strange from Cambridge National Laboratory (CNL). Further Nixxen
Oceanography Company (NOC) will collect multiple samples from around the
world.

Dr. Sapp has never directed a research project that includes a subaward to
another organization/entity. After multiple conversations Profs. Sapp, Carter,
and Strange have reached an agreement about the portions of the project that
will be carried out in each of their laboratories, as well as the approximate level
of funding required for each investigator- about $400,000 per year (Sapp),
$150,000 per year (Carter) and $125,000 per year (Strange) and Nixxen is
budgeting $110,000 per year to collect samples.

The deadline for submission is about three weeks away and Dr. Sapp has
called you in for assistance and guidance on the proposal development. What
do you tell her?
Scenario Subrecipient vs. Vendor Contracts

What must UMB collect from Johnston University, Cambridge National Labs and
Nixxen Oceanography Company?
What Who From? Why? What Next?

Scope of
Work/Services

Budget

Budget
Justification

Subrecipient
Commitment
Form
Scenario Subrecipient vs. Contractor
What must UMB collect from Johnston University, Cambridge National Labs and
Nixxen Oceanography Company?
What Who From? Why? What Next?

Detailed scope of work will provide important project

details such as:
Review with PI to
Scope of
All organizations confirm uniformity
Work/Services •Direction of the project/work to be performed and key
of understanding
constituents involved
•Milestones, deadlines, deliverables and expectations

• Review for
All organizations
• Indicated personnel needs appropriateness
Budget (contractors would provide
• Indicates project costs • Applicable rates
a rate information)
included
• Review for
consistency with
• Provides in-depth detail and justification of
Budget Johnston University & budget
proposed costs
Justification Cambridge National Labs proposed
• Incorporate into
main budget
• Indicates vital information such as key personnel,
• Review for
Subrecipient deliverables, dates etc.
Johnston University & completeness
Commitment • Confirms Institutional awareness and sign-off
Cambridge National Labs • Submit to ORSP
Form • Provides insight of compliance requirements/items
PreAward GCA
to be aware of should proposal be funded
Preparing your budget

Subrecipient Contractor
• Detailed scope of work • Detailed scope of services
• Detailed budget and budget • Budget/Estimation of Costs
justification • Rates & hours
• Completed Subrecipient • Completed Letter of Commitment
Commitment Form(s) (consultant)
• Documents (additional) specified • Documented list of deliverables &
by sponsor or UMB milestones
Preparing your budget
PI, V. Doom is submitting a proposal to the Association of
Psychological Studies with the following considerations:

Budget

Organization Personnel Determination Y1 Y2 Y3 Sum

Yale Phil Harmonic, PhD Subrecipient $25,000 $15,000 $5,000 $45,000

MIT Anne Seales, PhD Subrecipient $8,000 $8,000 $10,000 $26,000

West Diagnostic Sally McLee, PhD Consultant $5,000 $7,000 $3,500 $15,500

Total $86,500
Preparing your budget
Dr. V. Doom’s budget breakdown:

Y1 Y2 Y3 Total

Sub under $25K $ 33,000 $ 8,000 $ 1,000 $ 42,000

Sub over $25K $ 15,000 $ 14,000 $ 29,000

Consultant $ 5,000 $ 7,000 $ 3,500 $ 15,500

Direct Costs $ 38,000 $ 30,000 $ 18,500 $ 86,500

Indirect Cost Base (MTDC, 52.5%) $ 38,000 $ 15,000 $ 4,500 $ 57,500

Indirect Costs $ 19,950 $ 7,875 $ 2,363 $ 30,188

Total (DC + IDC) $ 57,950 $ 37,875 $ 20,863 $ 116,688

ORSP Budgetworkbook
FAQ’s for Subrecipients & Contractors

Q. Which F&A rate should the subrecipient use? UMB’s or their own?
A.Subrecipient’s should apply their federally negotiated indirect cost rate
to their proposed budgets. The subrecipient’s total cost is budgeted as
direct cost within UMB’s budgetworksheet

Q.The sub/consultant’s total budget is over 50% of the overall budget.

Is this allowable?
A.It depends, consider the following…
• Relationship: Based on the overall scope and activities associated with the
project, is it justifiable that UMB is the prime? Will the sponsor scrutinize
the proposed arrangement?
• Cost: Are the subrecipient’s proposed costs justifiable and necessary?
• Sponsor: Does the sponsor’s solicitation/guidelines impose budget
limitations for subrecipients and/or vendors?
FAQ’s for Subrecipients & Contractors

Q. My PI’s colleague from the English department will consult on the

project. Should s/he be budgeted as a consultant?
R. NO. The colleague’s activities on the project may be to “consult” (i.e.
advise, mentor, evaluate) but they cannot be budgeted as a consultant.
Per UMB policy, consultants are persons not employed by the
institution (procurement purchasing policies & procedures). Any project team
members with a current or future university appointment should be
budgeted as personnel not consultants.
Cost Share
Cost Share

Objectives

•Define Cost Share

•Why Cost Share?
•Sources of Cost Share
•Types of Cost Share
•Allowability and Administrative Requirements
•UMB Practice and Business Process
•Scenario Discussion
•FAQs
Cost Share Defined

Uniform Guidance Definition

200.29

Cost Share is that portion of the total cost of a sponsored

project which is not paid for by the Sponsor
Cost Share Visual Definition
Why Even Consider Cost Share?

• Sponsors may issue Program Announcements or

Requests for Proposals requiring cost share contribution

• Proposed Scope of work requires resources in excess of

funding available by sponsor

• Competition for Award – Some PI’s assume that including

cost sharing gives a competitive advantage or more
favorable review

• NOTE: Under Federal research proposals, Voluntary

Committed cost sharing is not expected. It cannot be used
as a factor during the merit review of applications or
proposals. (UG 200.306)
Types of Cost Share

• Mandatory Committed Cost Sharing: Sponsor stipulates that cost

sharing or matching funds are required as a condition of receiving the
award. A percentage or amount is specifically required and budgeted
in the award.
• Voluntary Committed Cost Sharing: Cost sharing specifically
pledged on a voluntary basis which is quantified in either the proposal
budget and/or narrative and becomes a binding requirement of the
award, must be tracked, and may require reporting.
• Voluntary Uncommitted Cost Sharing: Costs and effort that are not
included as part of the submitted proposal or upon acceptance of the
award. This does not need to be tracked or reported.
• In-Kind Cost Sharing: In-kind cost sharing are contributions wherein
the value can be readily determined, verified, documented, and
justified but where no actual cash is transacted in securing the good or
service comprising the contribution.
Cost Sharing Administrative Requirements

Must meet following criteria:

• Verifiable from recipient’s financial records (i.e. trackable in
Summit)
• Necessary and reasonable for project
• Allowable and allocable under applicable cost principles
• Source cannot be another federal award
• UG 200.306 establishes administrative standards for federal
awards
UMB General Practice on Cost Share

• Mandatory cost sharing will be considered with the

understanding that the university will share only the extent
necessary to meet the minimum specific requirements of the
sponsor

• As a general rule, voluntary cost sharing is not encouraged.

Voluntary cost sharing creates an unnecessary burden by
committing the otherwise limited resources of the university as
well as the risk and compliance obligations of tracking share
commitments

• Third ­party cost sharing is strongly discouraged due to the high

risk associated with the commitment, obligation, compliance,
certification and reporting on behalf a third party. However,
there can be exceptions. Prior approval is required
Acceptable Sources of Cost Share

At UMass Boston, cost sharing takes one of three forms:

 Unrecovered F&A. (The difference between sponsor’s limited

F&A rate and the university’s applicable F&A rate)
 Salaries, wages, and associated benefits of personnel,
paid or in-kind
 Cash contributed from unrestricted university budget
sources for committed project supplies and materials (e.g.,
office supplies, lab supplies and chemicals, travel,
communications, expendable equipment)
Unacceptable Sources of Cost Share

The following examples are typically not allowable as cost sharing:

X Costs associated with the F&A cost pool (e.g., administrative

support, utilities, library resources, value of existing university
facilities, value of equipment used by the project)*
X Costs associated with another federal award
X Costs associated with activities outside of the period of
performance of the project
X Costs that would otherwise be considered unallowable (e.g.,
alcoholic beverages)

* If the full applicable F&A rate is allowed

Remember!

A Commitment in a proposal
becomes a requirement upon
award
Cost Share Budget Development Strategy

• Review the solicitation and sponsor guidelines to determine if cost

share is explicitly required, allowed or prohibited
• If mandatory, determine the required minimum cost-share levels;
mandatory and/or allowable budget categories. Understand the risk
associated with over-commitment of resources. Cost-share may just
be an eligibility criteria with no impact to merit review or
recommendation for funding
• If unallowable or restricted understand implication of a non-compliant
application (i.e. rejected application, mandatory budget revision to
accommodate NICRA with inadvertent reduction to DC)
• Determine which costs/commitments are allowable, allocable and
reasonable pursuant to OMB and sponsor programs guidelines
• Once cost principles are met, assess compliance with UMB policies
and practices, develop budget and document commitments including
3rd party (subs and vendors)
Cost Share Commitment Life Cycle at UMB

• Proposal Stage
1. Clearly define your cost share commitment in ORSP Budget Template
using middle column.
2. Complete and submit Cost Share Request Form at time of proposal.
Must include speed types and relevant signatures:
• i.e. If tuition is included, Office of Graduate Studies must sign
• i.e. In-kind contributions, Chair needs to sign
• Once Awarded
1. Cost share items must be verifiable. Remember that all cost share items
can be reviewed by internal and external auditors.
2. Department responsible for documentation
3. Remember: specific cost share items are to be used solely for the
support of the project to which they were assigned. They cannot be used
to support any other work.
• Post award certification
1. Submitting cost share expense reporting form
2. PI must certify effort that was cost shared through UMass Boston’s
eCRT system
 Sample Cost Share Budget Using Unrecovered F&A
This example uses
the research F&A
rate. Your situation
may vary based on
the project type.

We can cost share the

Unrecovered amount shown
here in the “other” category.
(and excluded from base).

Sponsor limits F&A

At 20%, leaving 32.5% We can also cost
As unrecovered. share our full F&A
Amount.
FAQ’s
Q. How much academic time can be in-kind cost shared?
A. It depends on a variety of factors including the PI’s allocation of responsible time (teaching,
research and service), existing course or appointment buyouts and other commitments including
other in-kind effort. Any in-kind cost share greater than 10% academic effort should be explicitly
and carefully reviewed against all other commitments as well as the department’s standard
practices regarding faculty duties.

Q. Can RA tuition waivers be used for cost share? How about a TA?
A. If a RA’s effort is associated with the proposed project, the related tuition waiver for the
assistantship can be proposed as cost-share. However TA’s efforts are related to teaching duties
and generally not to specific projects therefore the associated TA tuition waiver cannot be
proposed as cost share; it is unallocable.

Q. Why do I need a detailed budget for my cost share amount?

A. For the same reasons you need a detailed budget for any proposal; cost share are proposed
costs subject to review for compliance to determine if allowable and allocable. Ultimately these
are project cost which needs to be documented, tracked, reported and certified.
FAQ’s
Q. Can you cost share unrecovered F&A if the sponsor limits the F&A?
A.Yes. if the sponsor limits F&A, you can cost share the unrecovered F&A which is the difference
between the sponsor’s limited rate and the applicable rate. For example, if F&A is limited to 20%
and the applicable rate for the proposed activity is 52.5%, the uncovered F&A is the remaining
32.5% which may be considered cost share.

Q. Is it considered cost share if we request a reduced F&A rate on a proposed budget?

A. Yes. If the budget’s F&A rate is less than the applicable rate for the proposed activities, the
reduced rate will result in a voluntary cost-share commitment which may be unallowable,
prohibited, strongly discouraged, along with other significate consequences
Scenario Cost Share
In addition to addressing Dr. Sapp’s questions about subrecipients
and vendors, she also makes you aware that she has “heard” from
colleagues that her proposal will be reviewed favorably is she includes
lots of cost share. In fact, she says the DOE will expect to see cost
share proposed in the budget. With that expectation in mind, she had
already begun drafting a budget where she proposes a 1:1 match
composed of direct costs. She would also like to request an F&A
waiver because she cannot afford to meet that commitment unless the
F&A is waived. The waived F&A can be used towards meeting the 1:1
cost share, thus gaining a competitive advantage…

What do you tell her?

Scenario Continued
Things to consider regarding Dr. Sapp’s Cost Share scenario:
•Review the solicitation together with the PI to determine if cost share
is mandatory and required by sponsor. Is it allowed?
•If cost share is mandatory, verify minimum commitment requirements
and any additional limitation related to cost share budget categories.
•If cost share is not mandatory have a conversation with PI
discouraging voluntary cost share. Voluntary Cost-share is
problematic for many reasons including:
• It may be prohibited by sponsor (e.g. NSF)
• Applying a rate other than the applicable negotiated rate may lead to
application compliance issues
• If awarded, may have to rebudget with full F&A rate and no flexibility
on awarded amount
•Develop the proposal budget with supporting commitment
documentation consistent following relevant sponsor guidelines and
UMB policies, procedures and practices
Scenarios

▸ Please see handouts for other scenarios.

▸ A link will be on the GRANT Forum website.
Research Administrators Certification
Three types:
CRA: Certified Research Administrator (covers pre and post)
CPRA: Certified Pre-Award Research Administrator
CFRA: Certified Financial Research Administrator

Offered through RACC

Research Administrators Certification Council
http://www.cra-cert.org/
Eligibility

1. Bachelor’s Degree and three (3) years of professional

experience in research or sponsored programs administration
either in a sponsoring or recipient organization or the equivalent in
a self-funded organization;
OR
2. An Associate’s Degree and five (5) years of professional
experience in research or sponsored programs administration
either in a sponsoring or recipient organization or the equivalent in
a self-funded organization;
OR
3. No degree and six (6) years of professional experience in
research or sponsored programs administration either in a
sponsoring or recipient organization or the equivalent in a self-
funded organization.
What is the Body of Knowledge?
▸ The CRA Body of Knowledge covers four areas:
– Project Development and Administration
– Legal Requirements and Sponsor Interface
– Financial Management
– General Management
▸ The CPRA Body of Knowledge covers four areas:
– Research Partnership and Funding
– Project Development and Proposal Submission
– Budget Design and Development
– Awards and Pre-award Compliance Considerations
▸ The CFRA Body of Knowledge covers four areas:
– Governing Framework
– Project Costs
– Reporting
– Fiscal Compliance examination
Why become certified?

▸ Professional recognition
▸ Personal Satisfaction
▸ An indicator of expertise
▸ Increased opportunities for employment
▸ Advancement opportunities
▸ Increased credibility with clients
▸ Serve as a role model to others
Deadlines/Exams/Cost
CRA
Application deadlines: April 15, 2019 and October 1, 2019:
Testing: May 11th – 25th and November 1st – 16th.
$485

CPRA
Application deadlines: January 18, 2019 and July 15, 2019
Testing: February 16th – March 2nd and August 17 – August 31.
$475

CFRA
Application deadlines: February 8, 2019 and August 15, 2019
Testing: March 2nd - March 16th and Sept. 14th – Sept 28th.
Next steps

• Review info online

• Set a goal for taking test – give yourself TIME
• STUDY
• Contact Lili for practice material
• Find out if it’s possible to be reimbursed if successful
• Study group?
Next Time……

Next G.R.A.N.T Forum will continue discussion on proposal

development and cover the following topic:

•Working with your PI’s- avoiding last minute submissions

Questions?
Resources

 CRA Certification-Research Administrators Cert. Council

 Cornell Law
 ECFR
 ORSP Contact by Department
 ORSP Forms
 ORSP PI Toolkit
 ORSP Research Policies A-Z
 Procurement Training Resources