A Funding Agreement or Notice of Award establishes the terms and conditions under which a sponsor authorizes funds to be used in pursuit of a research project. SIBCR signing officials in coordination with SIBCR grant administrators review and accept the terms and conditions of awards. If there are any potential concerns with the terms and conditions, the grant administrator works with the PI and sponsor to resolve any issues. Since individual PIs are not authorized to enter into funding agreements that bind SIBCR in any way, the initial award review and acceptance at the institutional level must occur. A PI may be required to sign off on the funding agreement, depending on the sponsor. The PI needs to enter into an agreement with SIBCR to abide by the policies and standards of conduct of SIBCR and the terms and conditions of the award.
SIBCR ACCOUNT SET-UP
Once an award is accepted and the study has received all required approvals, SIBCR creates an account using the VA RDIS number assigned after R&D Committee approval.
A PI may designate others to have “signature authority” to make purchases from the project using the Signature Authority Form. An authorized signer for the account must sign all Purchase Orders (POs). A signed PO authorizes SIBCR to pay vendors upon receipt of an invoice.
All purchases for sponsored research projects must be reasonable and necessary for the performance of the project; allowable and allocable under the terms and conditions set forth in the grant award; and in accordance with SIBCR polices. There is more information about purchasing in the policy section website.
MONITORING AWARD FUNDING
The SIBCR accounting department monitors expenditures in accordance with regulations and standards promulgated by applicable federal guidelines and/or SIBCR policy.
Project expenses incurred on sponsored research must benefit the project and be directly related to the project’s aims. Award documentation provides detail on rules and regulations that must be followed when making purchases on these projects. SIBCR accounting staff and grant administrators are available to assist with questions about use of funds on projects. Expenses that deviate from these rules and regulations may result in disallowance from the sponsor and/or SIBCR.
The SIBCR accounting department prepares monthly budget reports for the PI or designated appointee(s) to review for fiscal appropriateness and accuracy. PIs and their study staff are strongly encouraged to communicate frequently with SIBCR about any issues with these reports. Some areas to monitor closely include: accelerated or delayed expenditures; low or high account balances; delays in billing from outside parties; and frequent staff changes.
SIBCR sends financial reports for CRADAs on a monthly basis. Some items to review on these reports include: receipt of start-up fees (these fees will either be invoiced by SIBCR or the sponsor will send them automatically to SIBCR); reimbursement for patient visits; and reimbursement for expenses such as travel or meals, as applicable. Other items to consider include staffing for these projects and whether sufficient staff time is available to meet the goals of the study. Continuous communication between the grant administrator, the PI and the study coordinator is vital to the success of these projects.
PIs also receive reports for accounts referred to as general purpose accounts that benefit the overall goals of the PI's research program. Expenses on these accounts should be monitored in accordance with SIBCR policies.
The information provided below is a sample of some different types of expenditures that frequently occur on grants and CRADAs. Please note that ‘clinical costs’ and research-related ‘core charges’ are separate and distinguishable from one another each with independent processes.
PIs and study staff must review the SIBCR budget reports to ensure that costs are charged to the appropriate budget.
SIBCR requires PIs to complete a Research Use Agreement when using VAPSHCS medical care services such as radiology, cardiology, laboratory medicine and/or surgery. This requirement applies to all extramurally funded research projects administered by SIBCR, regardless of the funding source (e.g., private industry, voluntary health organizations, NIH and other federal agencies). PIs must notify the service line of their intent and seek agreement with them to collaborate in the study. This review and approval will ensure the service is able to provide the required study procedures and that appropriate reimbursement will be made to the medical care appropriation. The medical care appropriation must be reimbursed for services provided over and above standard medical care for an eligible veteran; or for services provided to a non-veteran participating in a research project (except those provided under 38 CFR §17.85). More information about Reimbursing the VA for Clinical Costs can be found here.
R&D Core Costs
VA R&D offers several research cores for investigators. Each core has an R&D-approved list of charges. The charges are tracked by R&D staff and, if related to an SIBCR-administered project, SIBCR is presented with a bill of collection and will direct charges to the specific grant. These charges will show up on your budget reports and should be reviewed for accuracy. Some of these cores include: histology, tissue culture and imaging/confocal microscope. Two of the cores frequently used by PIs are highlighted below.
- Animal Research Facility
The Animal Research Facility (ARF) supervisor or the Veterinary Medical Officer (VMO) must approve in advance any animal orders that are to be delivered to the VA. Approval must be obtained before the order is placed with the vendor. This requirement is to ensure that only animals for which there is an Institutional Animal Care and Use Committee (IACUC) approved protocol are ordered; that an acceptable vendor is used; that space and caging are available; and that, should an expected order not arrive, it can be immediately investigated. Grants must include approved charges for all ARF usage including per diem, surgeries, special procedures, etc. More information on animal use charges may be found in the Specialty Purchases section of this website.
- Clinical Research Unit
The Clinical Research Unit (CRU) was established in 2000 to provide VA investigators with a well-equipped, controlled and safe inpatient and outpatient setting for VA investigators to conduct clinical research studies. If a grant project requires the use of the CRU, the PI or appointee is required to complete a CRU Services Request Form. A CRU staff member will review the request with the PI. A member of the CRU committee must also approve the application. Once signed, this form serves as a formal request for services between the CRU and the PI.
Subject participation payments of $600 or more in a given calendar year are taxable income and SIBCR is required to report the payment to the IRS and send an IRS 1099-MISC form to each such recipient. SIBCR requests the Social Security Number and permanent mailing address of each individual to whom subject payments are made if this $600 threshold will be reached.
SIBCR obtains a copy of the stamped, approved consent form if the study involves human subjects. The consent form follows standards promulgated by the Common Rule 38 CFR Part 16 and VHA Handbook Number 1200.05.
SIBCR reviews the consent form for mention of the following information: participation payments, travel expenses and/or payment for services outside VAPSHCS, as applicable. If consent forms are modified during the course of the study and there are changes to any of the items listed above, copies of the new consent form(s) must be sent to the SIBCR grant administrator(s).
Travel support must be consistent with SIBCR and sponsor policies and stipulations. International travel has stringent rules under the Fly America Act. PIs and staff are encouraged to become familiar with these travel policies before travel expenses are incurred since any disallowed costs will not be reimbursed. The SIBCR travel policy contains more details.
If the travel reimbursement is for a visiting fellow or scholar, the visa status of the individual must allow for such reimbursement. SIBCR must pre-approve travel for foreign fellows or scientists.
An SIBCR Purchase Order (PO) is required for all purchases made using SIBCR accounts. An authorized signer of the account (usually the PI or an appointee) must approve and sign each PO.
The PI or appointee should keep a record of all purchases made using POs and are encouraged to keep a record system of PO numbers to safeguard against using the same PO number more than once and for monthly budget reconciliation.
SIBCR may directly employ professional and technical staff to support research projects for personnel performing services at VAPSHCS facility. Most grant mechanisms do not allow direct support of administrative staff. Exceptions to this rule may be made for large projects such as program projects or center grants where the sponsor allows support for administrative staff.
All SIBCR employees must obtain Without Compensation (WOC) status from the VA. An SIBCR HR administrator is available to help with this process.
Occasionally, a person working at UW, VA or SIBCR may need to be reimbursed from a project administered by an entity other than their employing institution. Use of a personnel agreement (either a JPA or IPA) may be appropriate in limited circumstances. Please contact your SIBCR grant administrator for details. There is more information in the personnel agreement section.
Please note that UW staff reimbursed via JPAs and located at VAPSHCS must obtain Without Compensation (WOC) status from the VA. The VA service line administrator may have more information to assist in this process.
If a grant involves consultant services, an Independent Contractor (IC) agreement may be an appropriate mechanism if it meets the criteria detailed in the 20 Points Checklist. Please note that members may not commit SIBCR to pay for services from technical, consultative, or professional individuals or groups. This may only be done by an SIBCR authorized signing official.
SIBCR recognizes the importance of scientific collaborations with outside entities and implements subawards on federal and non-federal grants. SIBCR works with subawardees and vendors directly to execute an appropriate agreement once funding and regulatory approvals are received. The determination of whether a particular arrangement is a subaward or vendor agreement is generally made at the proposal stage based on the criteria outlined in 2 CFR 200.331. For more information, see subawards.
CHANGES IN PROJECT AND BUDGET
Prior Approval Requests
Prior approval is often required by sponsors for certain items and actions. The terms and conditions of awards specify any restrictions requiring approval. Some of the many examples include a change of grantee organization, change in scope, key personnel changes and second no-cost extensions. The PI and an SIBCR authorized signing official must send the official requests to sponsors. SIBCR grant administrators are available to assist with drafting the letters/emails. Some of these items are described in more detail below. For a full summary of all actions requiring NIH Prior Approval and the process for submitting requests, please review Chapter 8, Section 8.1.2 (Prior Approval Requirements) of the NIH Grants Policy Statement.
Change of Grantee Organization
If a PI from another entity is proposing to transfer a grant to SIBCR, the PI must obtain approval from the sponsor and agreement from the original grantee to relinquish the grant. PIs who plan on transferring a grant to SIBCR are highly encouraged to contact the VA R&D office to inquire about the requirements for regulatory approvals well in advance of the transfer. SIBCR grant administrators are available to assist in this process. Chapter 8, Section 18.104.22.168 of the NIH Grants Policy Statement provides detailed information on NIH requirements to transfer a grant. Please refer to the appropriate sponsor website for non-NIH grants. SIBCR grant administrators are available to assist in this process.
For non-grant funding, such as private company and discretionary funds, institutions may have policies regarding funds transfers. PIs are advised to inquire with their institutions before taking action.
SIBCR’s funds transfer policy applies to PIs moving from SIBCR to other entities.
A supplement is requested when additional funding during a current project period is necessary to provide for an increase in costs due to an additional aim, a change in aims and for other unforeseen circumstances not originally proposed in the application. The PI contacts their SIBCR grant administrator to prepare the application for review and sign-off by an SIBCR authorized signing official. The request is either submitted directly to the program official and/or an NIH grants management official or submitted via the electronic portal in eRA Commons.
NIH No-Cost Extensions
Programmatic reasons may require the period of performance of a grant or contract to be extended with no additional funding from the sponsor. This action is called a No-Cost Extension (NCE). An NCE must be requested via eRA Commons for NIH grants. The SIBCR authorized signing official submits the request. Most NIH grant mechanisms allow a one-time automatic extension. The award notice lists any restrictions. Chapter 8, Section 8.1.1 (NIH Standard Terms of Award) and 22.214.171.124 (Extension of Final Budget Period) of the NIH Grants Policy Statement provides more specific details.
During the extension period, the PI must maintain all required approvals such as those pertaining to human subjects and animal welfare, in accordance with applicable regulations and policies. All terms and conditions of the original award continue during the extension period.
Additional No-Cost Extensions or Extensions Greater Than 12 Months
Subsequent NCEs beyond the initial twelve months require NIH prior approval. The request must include a letter co-signed by the PI and an SIBCR authorized signing official. The letter should include a description of the project activities that require support during the extension and a statement about the funds available. Additionally, the request should include a budget, budget justification, and a checklist page. SIBCR grant administrators are available to assist PIs in composing the prior approval request letters.
The PI is responsible for preparing progress reports in coordination with SIBCR grant administrators. An authorized SIBCR signing official must approve and submit the reports to the sponsor.
An annual progress report, referred to as a Non-Competing Continuation Progress Report, is a requirement of NIH. NIH has two mechanisms for progress reports: the Streamlined Noncompeting Award Process (SNAP) and awards excluded from SNAP. SNAP submissions are submitted electronically via eRA Commons using the Research Performace Progress Report (RPPR). The full user guide for submitting RPPR reports can be found here. If an award is not eligible for SNAP, the PHS 2590 guide and requisite forms are required.
Other sponsors such as the Department of Defense (DoD) require more frequent quarterly progress reports as well as an annual report. Most sponsors provide specific guidance on reporting requirements in the terms and conditions of the award.
Due dates for progress reports are dictated by the individual grant. Progress report preparation should begin approximately 3 months prior to the report due date. Grant administrators notify PIs of the due date(s) and some sponsors (such as NIH) send automated reminder messages. The grant administrator works with the PI until the report is submitted and accepted by the sponsor.
Progress report formats vary among sponsors. To ensure the proper form(s) are being utilized, contact the sponsor to verify any updates or changes to submission requirements.