FDP Phase VI Kicks Off at Recent Meeting; New Members Are Excited to Participate

October 2014 3 4 7 In This Issue UCLA Challenges Majority Of Questioned Costs in NSF Audit HHS OIG Issues Reports Reviewing OHRP, NIH, SUPPORT Controversy Agency Developments If you re not accessing the subscriber-only website at www. ManagingFederalGrants. com, you re missing extensive content on the grants management process, Federal Agency Daily and a newsletter archive. If you don t have a Web password, call 800-521-4323 or email customerserv@aispub. com. Editorial Advisor Gunta Liders University of Rochester Contributing Editors Robert M. Lloyd Managing Editors Darla Fera Frances Fernald FDP Phase VI Kicks Off at Recent Meeting; New Members Are Excited to Participate The September meeting of the Federal Demonstration Partnership launched Phase VI of the organization. The excitement expressed by new members of the FDP at joining the organization in this new phase almost rivalled the anticipation of old and new members concerning the upcoming implementation of the uniform guidance (see story, below). Phase I of the organization was launched in 1986, when it was called the Florida Demonstration Project, and Phase II in 1988, when the organization changed its name to the Federal Demonstration Partnership; Phase III began in 1996; Phase IV in 2008; and Phase V continued until this year. During a new member orientation, FDP listed the following accomplishments over the past 25 years, which includes completion or establishment of: Expanded Authorities project FDP Subaward Agreement Standard Governmentwide Terms and Conditions Faculty Burden Survey Emerging Research Institutions Government-University-Industry Research Roundtable Partnership Workshop FDP as key sounding board for the Research Business Models Subcommittee of the Committee on Science, Grants.gov, Research.gov, and other initiatives Recovery Act Statistics project New FAQ Allows for Year Grace Period To Comply With Procurement Guidance continued on p. 4 Making good on its promise to issue a second set of frequently asked questions on the Office of Management and Budget s uniform guidance on administrative requirements, cost principles, and audits before the end of August, the Council on Federal Assistance Reform released a 30-page document on Aug. 29 containing over 60 Q&As. Perhaps the most welcome news for college and university federal fund recipients is that they will have an additional year to comply with the new procurement standards outlined in the guidance. FAQ 200.110-6 states that for procurement policies and procedures, for the non-federal entity s first full fiscal year that begins on or after December 26, 2014, the non-federal entity must document whether it is in compliance with the old or new standard, and must meet the documented standard. For example, the first full fiscal year for a non-federal entity with a June 30th year end would be the year ending June 30, 2016. The Single Audit Compliance Supplement will instruct auditors to review procurement policies and procedures based on the documented standard. For future fiscal years, all non-federal entities will be required to comply fully with the uniform guidance. continued Published by Atlantic Information Services, Inc., 1100 17th Street, NW, Washington, D.C., 20036 800-521-4323 www.aiseducation.com

2 Federal Grants News October 2014 Other administrative and cost principles requirements go into effect Dec. 26 of this year, as implemented by individual federal funding agencies. The audit guidance takes effect based on the start of a recipient s or subrecipient s fiscal year. COFAR explains upfront in the FAQ that the document is only intended to provide additional context and background for but does not change the underlying principles of the guidance. A webinar sponsored by COFAR, which will further address general compliance with the uniform guidance and the recent FAQ, is scheduled for Oct. 2 from 1:00 3:00 p.m. EDT. OMB Elaborates a Little OMB s Victoria Collin commented on her top favorite Q&As included in the August FAQ and shared them with the audience at the September meeting of the Federal Demonstration Partnership (see p. 1). Do pass-through entities have to negotiate an indirect cost rate with a subawardee? No. If the subawardee or potential subawardee has a federally negotiated rate, then it has to use it. Otherwise, the entity may negotiate a rate with the prime awardee or be awarded the 10% de minimis rate. (Question 200.331) Does the discussion in the guidance of conflicts of interest include research COIs? No. The uniform guidance includes a new provision that all agencies must FEDERAL GRANTS NEWS for Colleges And Universities is published monthly (10 times a year with combined issues in July/ August and December/January) as a part of A Guide to MANAGING FEDERAL GRANTS for Colleges and Universities. Copyright 2014 by Atlantic Information Services, Inc. All rights reserved. Click on Distributing Content Campus-wide in the left margin at www.managingfederalgrants.com to view details of campus-wide access to this subscription. Editorial Advisor, Gunta Liders; Managing Editors, Darla Fera, Frances Fernald; Contributing Editor, Robert M. Lloyd; Production Director, Andrea Gudeon; Marketing Director, Donna Lawton; Fulfillment Manager, Tracey Filar Atwood Annual subscriptions include access to the website www. ManagingFederalGrants.com, regular Web updates, federal agency news posted daily and emailed weekly, and ten issues of FEDERAL GRANTS NEWS for Colleges and Universities. Please add ManagingFederalGrants@aispub.com to the list of safe senders in your email address book, and ask your IT department to whitelist the address to receive email communications under this subscription. Annual subscriptions for NCURA and NACUBO members for A Guide to MANAGING FEDERAL GRANTS for Colleges and Universities are $486 (a $100 discount off the $586 nonmember rate). All orders must be prepaid or accompanied by a purchase order. To order or to change your address, call 800-521-4323 (in D.C., 202-775-9008. Major credit cards accepted. have a conflict of interest policy and that a nonfederal recipient of federal funds must disclose potential COIs (2 CFR 200.11-113). The FAQ clarifies that this does not pertain to scientific conflicts of interest that arise in the research context but rather how funds are expended (e.g., contracts and procurements). (Question 200.112) Do nonfederal entities have to keep separate accounts for pre-guidance and post-guidance awards or award activity? No. The application of the uniform guidance depends on how an agency awards incremental funding. The incremental funding stage may be an opportunity for an agency to change the terms and conditions and, thus, invoke the uniform guidance provisions (e.g., NSF will changes terms on an incremental award; the Department of Energy will not). Terms and conditions are always the best sources to find specific answers to specific questions. But even if an agency implements the guidance in an incremental award, separate account numbers will not be required. (Question 200.110) Can provisions in the uniform guidance be used to generate a proposal for and negotiate a new F&A rate after Dec. 26? A nonfederal entity s negotiated F&A rate will be in effect until the next negotiation period. The proposal for a new rate can be calculated using information reflected in the guidance. (Question 200.110) Does an approved DS-2 need to match actual accounting practices that have been changed in accordance with the uniform guidance? Accounting practices do not need to match the DS-2 immediately. Accounting changes should be submitted to the federal agency as soon as possible after Dec. 26. If these changes have been made in accordance with the guidance, but changes have not been approved by an institution s cognizant audit agency, it will not be penalized. If a nonfederal entity is using the principles outlined in the uniform guidance for submitting a new F&A rate proposal, then the entity needs to submit a revised DS-2 at the same time. (Question 200.110) If someone retires, are grantee institutions required to charge accrued leave (calculated as a fringe benefit rate) as indirect? No. (Question 200.431) Are nonfederal entities really allowed to eliminate time and effort reporting? Yes! COFAR wanted to eliminate the really burdensome and technical requirements found in the circulars. Instead, the uniform guidance is relying on a strong framework of internal controls. From the state and local government perspective, nonfederal entities were required to do a daily time sheet. These entities are now looking at university models for methods of certification on a monthly basis in terms of documenting salaries and wages. The guidance reiterates that estimation of compensation is allowed. The focus is on Please contact us with story ideas and news of what your college or university is doing that we should be covering. Let us know how FEDERAL GRANTS NEWS can be more useful for you. Contact Darla Fera at 800-521-4323 or dfera@aispub.com, or FAX your suggestions to 202-331-9542.

October 2014 Federal Grants News 3 flexibility. Collin further stated that there will not be any agency exceptions to this requirement. Agencies initially discussed a more prescriptive model for compensation, but none has implemented a more conservative approach. (Question 200.430) Can the procurement standards be used for strategic sourcing? Yes. COFAR encourages procurement policies that promote efficient purchasing. If strategic sourcing is used, a nonfederal entity does not have to document that it has looked at more than one rate quotation; if the strategic sourcing was competitively bid, then the entity is done documenting and getting bids. Similarly, nonfederal entities are permitted to acquire an item from a particular vendor to preserve the integrity of research to qualify as a sole source purchase. (Question 200.320) What is the grace period for implementing the procurement guidance? The grace period extends through the nonfederal entity s next fiscal year. (Questions 200.110 and 200.320) Collins noted that the FAQ can be relied upon as if it were guidance. There are a few technical corrections, she acknowledged, that will be need to be made to the guidance to align it with the interpretations set down in the FAQs sometime in the near future. Link: https://cfo.gov/cofar. UCLA Challenges Majority of Questioned Costs in NSF Audit The University of California, Los Angles, was not pleased with the National Science Foundation Office of Inspector General s audit findings, released in a recent report, which questioned more than $2 million of charges on 769 NSF awards to the university. The audit, which reviewed approximately $226 million in costs incurred from July 1, 2009, through June 30, 2012, was performed by Cotton & Company, Alexandria, Va., on behalf of OIG. The major issue swirled around the method of calculating summer salaries, which accounted for almost 90% of the total questioned costs. According to the auditors, UCLA s methodology for reimbursing the summer salaries of employees and charging awards for work performed during its summer work periods resulted in the university charging costs that exceeded the proportionate share of an employee s salary and/or the employee s base monthly salary amount. It also was inconsistent with how employees salaries are reimbursed and charged to awards during the academic year, the auditors said. UCLA countered that the auditors inappropriately used a model that focused on the number of days in a month, rather than the number of days in the summer service period, which is the university s policy. UCLA determines the summer salary rate by dividing the academic base year salary by the number of months covered by the academic year appointment, in compliance with 2 CFR Part 220 (Circular A-21), Appendix A, Section J.10.d.(2) (2012), which was applicable to the audit period. UCLA s policy allows faculty members to earn up to one-third of their nine-month annual salary during the summer period for additional services. However, as UCLA explains, the summer period is not based on calendar months, but runs from mid-june through mid- September. Any working days within the summer working period may be claimed for full summer compensation, regardless of the number of days within the month, the university explained in its response to the audit report. Auditors Were Not Persuaded Not unexpectedly, the auditors stood by their conclusion. By using the number of days in the summer period rather than the number of days in each month the auditors reiterated, UCLA overcharged NSF for summer salaries. Because they believed the methodology was wrong, they questioned all summer salary amounts greater than 100% of an employee s monthly salary, as well as the salary associated with overcharged effort percentages. The other areas of questioned costs were per diem travel costs, visa application fees, equipment purchased at the end of the grant period, retroactive salary payment, unallocable domestic travel expenses, indirect expense charges, and technology infrastructure fees. Of these, UCLA agreed to only three: the visa application fees ($73,135), indirect costs ($3,200), and the technology infrastructure charges ($2,263). It defended the per diem travel costs based on proper application of university policy and maintained that the retroactive salary payment, the equipment purchased at the end of the grant period, and the domestic travel were all proper charges necessary to complete the grant project. It also maintained that no late charges or payments Upcoming Grants Management Webinars from FFMA & AIS October 20 Rethinking Your Federal Grant Internal Controls Based on OMB s New Guidance October 27 Managing Human Resources Under Federal Grant Reform Visit www.federalfundmanagement.com/webinars Go to the subscriber-only website at www.managingfederalgrants.com for information on how subscribers can share all print, email and website content with all employees on the same campus at no additional charge. Click on Distributing Content Campus-Wide in the left margin.

4 Federal Grants News October 2014 represented cost-shifting. UCLA did agree to provide additional support for focus on improved timeliness of certifications. Link: www.nsf.gov/oig/reports/ucla.pdf. HHS OIG Issues Reports Reviewing OHRP, NIH, SUPPORT Controversy The Department of Health and Human Services Office of Inspector General has weighed in on a controversy concerning an NIH-funded Surfactant, Positive Pressure, and Oxygenation Randomized Trial (SUPPORT) and a compliance investigation of the study undertaken by the HHS Office for Human Research Protections. OIG s two reviews on the controversy were conducted at separate times but the reports were posted together on Sept. 16. SUPPORT was a randomized multisite study funded by the National Institute of Child Health and Human Development that enrolled approximately 1,300 premature infants between 2005 and 2009. The University of Alabama-Birmingham was the lead institution coordinating the project. In May 2011, OHRP received and followed up on a complaint alleging that the study design was unethical and the researchers had not obtained informed consent, according to OIG. OHRP issued a determination letter in March 2013 in which it found that the conduct of this study was in violation of the regulatory requirements for informed consent, stemming from the failure to describe the reasonably foreseeable risks of blindness, neurological damage and death. SUPPORT and OHRP s initial determination letter received significant attention in the media and in professional publications, according to OIG s report, and it triggered a public debate among prominent scholars, physicians, and bioethicists concerning informed consent requirements in research testing treatments within a standard of care, among other issues. OHRP issued a second letter to UAB in June 2013, in response to the concerns of the research community and NIH, OIG said. The goal of the second letter, according to OHRP, was to clarify several issues related to our [earlier] determination. OIG was asked to review whether NIH officials improperly intervened in the compliance oversight deliberations of OHRP by Rep. Rosa DeLauro (D-Conn.), the Public Citizen s Health Research Group and public requests, according to the report. In its report, OIG-12-14-04, the office said that OHRP followed its procedures and exercised discretion throughout its evaluation of the study and that, while officials outside OHRP commented on and suggested changes to its revised [compliance determination] letter, OIG identified no laws, rules, or policies that were violated by these actions. OIG found no evidence that NIH or other HHS officials sought to intervene in OHRP s initial determination letter regarding SUPPORT. Our review did confirm that after the initial letter was issued, NIH encouraged OHRP to reverse its determination and that NIH and others in HHS provided input on OHRP s later clarification letter. However, OIG found no legal authority that prohibits such consultation. Michael Carome, a former official with OHRP and now director of the Health Research Group, said in a statement that the report is extremely disturbing and represents a complete whitewash. He called on Congress to take action by passing legislation making OHRP an independent agency that is free of the corrupting influences of NIH and other conflicted agencies regulated by OHRP. The second report, OEI-01-14-00560, was actually completed earlier, but the results are just now being shared publicly, according to OIG. OIG conducted its review in 2013 at the request of Rep. Jack Kingston (R-Ga.) to determine whether OHRP followed its procedures in its compliance evaluation of SUPPORT. OIG found that OHRP had indeed followed its forcause compliance evaluation procedures, which are broadly drawn and provide the office with substantial discretion. Links to OIG reports: http://tinyurl.com/l2s4drr; http://tinyurl.com/m8rklqu. Link to Carome s comments: http://tinyurl.com/khwcj2k. FDP Moves Into New Phase continued from p. 1 At the plenary session, in addition to the usual assortment of informative federal agency notifications and updates, some federal representatives also briefly reiterated the agency s mission and organizational structure for the benefit of the many new FDP attendees, who for the first time were participating in this unique collaborative effort involving federal research agencies, the university community, and other research institutions. Agencies Report on Activity Debbie Rafi, from the Office of Naval Research, announced that as of Oct. 1, ONR will implement a new grants system, which she referred to as PPS, as its AwardWeb grant notification system is being phased out. As a result of the transition to the new system, some existing grants will need to be reissued. ONR, however, is committed towards continuity of research projects, Rafi said. She noted that this experience has given her a new Go to www.federalfundmanagement.com to review a calendar of upcoming webinars for federal fund managers

October 2014 Federal Grants News 5 appreciation of the challenges universities face when they implement new accounting systems, and she said that ONR hopes to lessen any impact on universities and principal investigators. Under the old system, awardees were notified of new awards via email. In the future, institutions will be notified through an electronic notification system (that works in concert with an electronic document access system, EDA). Starting in January 2015, sponsored programs offices and PIs will be alerted when an existing grant will need to transition to PPS. A new award number will be assigned, but only one closeout for the entire project will be required, Rafi said. The project scope will not be affected, and ONR will not be requesting new proposals for these grants. Grants that are fully funded (e.g., all funding has been awarded) will not be impacted, she added. An FDP attendee questioned whether ONR will be very specific on the notice of grant award with respect to re-issuance of an existing project, as institutions may assume they will need to issue new account numbers. Rafi indicated that new account numbers will not be necessary and that grant terms will be specific. An additional concern was raised with respect to reporting under the Federal Funding Transparency and Accountability Act. For certain awards, won t there be records for two different awards in two different systems, the questioner asked. Rafi responded that further instructions will be forthcoming. Guidance and updates will be posted on www.onr.navy.mil. Finally, Rafi announced that PayWeb & AdminWeb will be offline until Oct. 5 for a system refresh. BAAs Are Being Updated Susan Fuller, speaking on behalf of the Air Force Office of Sponsored Research, said that the Broad Agency Announcement 2014-001 for Research Interests was recently amended to both remove and add research areas. (Access the BAA at www.fbo.gov.) Department of Defense agencies generally use the BAA mechanism in awarding research funds. The BAA will remain open from January-March 2015 until amended. The Defense University Research Instrumentation Program and Multidisciplinary Research Program of the University Research Initiative BAAs are currently being reviewed and will be re-issued soon, Fuller said. As AFOSR representatives have done repeatedly in the past, Fuller reminded attendees that timely billing is essential and late billing jeopardizes funding on current projects and new awards. The federal fiscal 2015 budget is a big unknown, and her agency is anticipating a continuing resolution, she said. (The CR was passed on Sept. 18.) The agency will strive to get communications out on how the budget negotiations will affect funding as soon as feasible. AFOSR is committed to getting out as many new actions as possible with its current appropriation, Fuller said. The FDP welcomed back Ernie Dixon, from the Army Research Office and Army Research Laboratories, after a lengthy hiatus due to ill health. He told the audience that ARO manages $800 million of Army-focused basic research funding projects across the country and at over 200 academic institutions. Dixon described ARO as a small office with a big mission and noted its broad scientific areas of interest (see http://tinyurl. com/3vhvyfv). ARL s areas of interest can be found at http://tinyurl.com/ku9xh68. BAAs are typically updated in October, Dixon said. He highly recommended contacting the relevant program officer prior to submission of an application. He delivered the standard warning that Department of Defense disbursement rates are still problematic and could delay or impact issuance of follow-on increments/options. ARO would like to be invoiced often every 30 days if possible, Dixon said. ARO is awaiting DoD s uniform guidance implementation, which will be affective in December (as will all implementing regulations from federal funding agencies) and may result in a different format for awards. Finally, a prior approval matrix (including cost-related prior approvals) is available on ARO s site, Dixon said (see http://tinyurl.com/l4y9xad.) NASA Looks for Reviewers NASA s Paul Brundage apprised attendees that NASA has submitted its implementation of the uniform guidance to OMB and, once final, will be placing its terms and conditions in 2 CFR. A new NASA Grant and Cooperative Agreement Manual is under development, which will include a Guidebook for Proposals as an appendix to the manual, he said. NASA is also looking to increase its pool of unconflicted (those who have no conflict of interest) and qualified peer reviewers. A new Web-based voluntary review form has been developed to assist in helping NASA locate peer reviewers. The agency will be sending out an email to faculty on a quarterly basis as it mines for reviewers. Brundage said that sitting on a peer review session is especially helpful for early career scientists and urged interested faculty members to access more information about becoming a NASA reviewer at http://tinyurl.com/ nux82tu. continued Visit www.managingfederalgrants.com where 20 detailed chapters on all significant grants management topics are housed and updated.

6 Federal Grants News October 2014 Business Continues Apace at NIH The National Institutes of Health s Office of Policy for Extramural Research Administration Director Michelle Bulls had several reminders for the audience: The Oct. 1, 2015, implementation timeline for use of PMS subaccounts for continuation awards (NOT- OD-14-103). Bulls said that once this is implemented, a transitional federal financial report will be put into place; these FFRs will be allowed to contain unliquidated obligations and thus minimize burden to the grantee community. The reports and 90-day submission requirements for closeout remain the same (NOT-OD-14-084). Audience members were pleased to hear that Bulls and the National Science Foundation s Jean Feldman are co-chairing the FDP s Research Terms and Conditions Working Group. In this capacity, they will be advocating for a 120-day (as opposed to a 90-day) closeout. Both agency officials would like the other federal research agencies to consider this, and OMB is being supportive of this idea, Bulls said. Reporting on the use of individual development plans is required beginning with research performance progress reports submitted on or after Oct. 1 (NOT-OD-14-113). While creation of IDPs are not required, NIH expects that these would be in place at an institution. Bulls said that the IDP should not be included in the RPPR itself; rather, grantees should report in the RPPR whether or not IDPs are used to help manage the training for graduate students and postdocs. Effective Oct. 17, the RPPR will be required for all type 5 progress reports (SNAP and non-snap) (NOT- OD-14-092). Bulls said that the NIH s new Genomic Data Sharing Policy is intended to promote the sharing of large-scale genomic data generated by NIH research and it becomes effective with the Jan. 25, 2015, application due date (see p. 8). In response to a question on NIH s timeline for implementation of the uniform guidance, Bulls answered that the HHS regulations will be ready by Dec. 26. NSF Thanks Commenters Jean Feldman, head of NSF s Policy Office, said that the agency received 54 responses from 18 organizations and individuals to its draft Proposal and Award Policies and Procedures Guide (PAPPG) released in May for public comment, which included NSF s draft implementation. NSF published a second notice for public comment on its implementation of the uniform guidance in the August 28 Federal Register. NSF includes in the notice the various positions taken by commenters and NSF s responses. It has reviewed the comments, revised the document in light of the input received, and sent NSF s final package to OMB. Feldman said that the comments were instrumental in the process and very much appreciated. She is hopeful that the document will be finalized shortly. In addition to the implementation of the uniform guidance, the revised PAPPG will bring other changes that Feldman shared with the audience. The PAPPG includes some automated compliance checking features, which generate warnings for noncompliant sections of the application when an individual checks the proposal during submission. Feldman said that NSF will be rolling out some additional specific compliance checking features and enforcement mechanisms with respect to page count rules and for budget checks. In addition, she hopes that the automated compliance checking will be further enhanced in January 2015 to enforce checks on particular proposal sections depending on the type of funding mechanism (e.g., equipment grants will have different checks than research grants). NSF received a number of comments on its special exceptions to an application deadline due to inclement weather and natural/anthropogenic events. The PAPPG was changed to reference after-the-fact dialogue with NSF, as prior approval is not always feasible. An attendee asked Feldman if a weather-related event occurs, and the institution can document that it was shut down, is a deadline extension available? Feldman answered that she would assume so, but the institution should talk to its program director as soon as possible after the institution reopens to confirm. NSF requires that a proposal include a separate section that addresses broader impacts; going forward, the PAPPG will require that this section of the application carry a special label. The PAPPG limits the budget justification to three pages. NSF received comments from stakeholders that in those cases where there are subawards, three pages are insufficient. In response to these concerns, NSF has revised the PAPPG to state that the prime is limited to three pages and subwardees are also allowed a limit of three pages. Because of the 22 prior approval requirements in the uniform guidance, the parallel requirements in the PAPPG have changed as well. In response to a question regarding whether the research terms and conditions would remove many of these prior approvals, Feldman said that it was too early to respond with certainty. There may be multiple methods for how these prior approvals will be implemented by the 11 research agencies that use those terms and conditions, she noted. NSF will continue to be the home for the research terms and conditions. Further discussion on possible Please contact us with story ideas and news of what your college or university is doing that we should be covering. Let us know how FEDERAL GRANTS NEWS can be more useful for you. Contact Darla Fera at 800-521-4323 or dfera@aispub.com, or FAX your suggestions to 202-331-9542.

October 2014 Federal Grants News 7 changes to these may need to be done via email to FDP members, since the next FDP meeting is not until January 2015, Feldman said. Finally, she reminded the audience that the agency is preparing for NSF s transition to a new financial and accounting system (ITrack) and that the Award Cash Management $ervice (ACM$) will be down until Oct. 13. Questions on the shutdown or conversion should be directed to a grantee s NSF program office. (FastLane will also be unavailable from Oct. 10 at 8:00 p.m. until Oct. 14 at 6:00 a.m.) Beginning Oct. 12, NSF will begin making all payments using the System for Award Management s (SAM. gov) banking information and, therefore, Feldman urged research organizations and investigators to ensure that their relevant information included in SAM is current and complete. NIFA Will Offer REEport Training The U.S. Department of Agriculture s National Institute of Food and Agriculture continues to work on its new Policy Guide. The guide will apply to both capacity and competitive grants and is scheduled to be disseminated on and effective as of Oct. 1, according to USDA s Melanie Krizmanich. She cautioned the FDP audience that this version of the guide will not yet include NIFA s implementation of the uniform guidance. Krizmanich said that USDA s financial system has completed its transition to REEport. REEport s Project Financial Report will allow NIFA to report to Congress and stakeholders more comprehensively at the project level. The data elements are the same, but the functional- ity is very different from that of the former system, CRIS. NIFA is planning a series of training webinars on the new system (see http://tinyurl.com/ktkzga9). All fiscal 2014 capacity programs are required to complete Project Financial Reports by Feb. 1, 2015, Krizmanich said. Initially, NIFA officials had said that noncapacity program awardees could avoid this form, but due to requests for information, Project Financial Reports also will be required for non-capacity awards made beginning Oct. 1. NIFA will be reinstating the requirement for Project Financial Reports in the award terms and conditions. Changes Are Ahead at SAM The General Services Administration s Judith Zawatsky discussed the agency s initiative to modernize its integrated award environment through 2018. She noted that SAM.gov, managed by GSA, was a typical big government launch. GSA s goal, however, is not to create one massive system but rather one integrated environment. As announced at the June FDP meeting, GSA is starting its systems integration with the Catologue of Federal Domestic Assistance and subaward systems. Coding will be done transparently, and the public will be able to comment on the new environment. GSA will be holding focus groups and will ask users to test the new environment before it goes live. Those interested in helping in this process should email GSA at IAEoutreach@gsa.gov, Zawatsky said. Link to presentations: http://sites. nationalacademies.org/pga/fdp/pga_152105. Agency Developments The following are summaries of news items posted in Federal Agency Daily at www.managingfederalgrants.com. The date appearing in parentheses at the end of each item is the date the item, including a link, was posted. New Edition of Green Book. The Government Accountability Office has revised its Standards for Internal Control in the Federal Government, often referred to as the Green Book. The new edition has greater detail and depth, according to GAO. While it continues to address the five components of internal control control environment, risk assessment, control activities, information and communication, and monitoring the 2014 version also covers 17 new principles that enumerate management responsibilities in implementing and overseeing an effective internal control system. The September Green Book supersedes the November 1999 edition. The Green Book is one of two internal control documents referenced in the OMB uniform guidance (at 2 CFR 200.303) as containing best practices for grantees to follow in developing their own internal controls. The other document is issued by the Committee of Sponsoring Organizations of the Treadway Commission (www.coso.org). (9/11/14) DURC. On Sept. 24, the Obama Administration issued a government policy addressing Institutional Oversight of Life Sciences Dual Use Research of Concern that builds on the previous DURC policy issued in March 2012. According to the White House, the policy will ensure that our Nation s vitally important research efforts in the life sciences are carried out Go to www.managingfederalgrants.com for Federal Agency Daily, a daily update of federal agency actions. And watch your inbox on Friday afternoons for Federal Agency Weekly, an email summarizing the prior week s actions. If you re not receiving Federal Agency Weekly, please contact customer service at 800-521-4323 or customerserv@aispub.com.

8 Federal Grants News October 2014 Agency Developments (continued) safely and in ways that minimize the risk of misuse. The new policy formalizes roles and responsibilities for institutions and investigators involved in life sciences research using certain select agents and toxins. (9/25/14) Health and Human Services Research With Animals. The NIH Office of Laboratory Animal Welfare has published guidance on what is considered a significant change to an ongoing animal activity that requires Institutional Animal Care and Use Committee (IACUC) review. OLAW posted the video and transcript of an Aug. 21 special seminar featuring speakers from OLAW and the U.S. Department of Agriculture who discussed conditions and nuances of the new guidance. OLAW also published the 81 comments it received in response to the proposed guidance issued last March. (8/26/14) OLAW also is making available an archive of its Sept. 18 program, The Research Animal Coordinator. Speakers included Ron Banks, DVM, Duke University; Tracy Heenan, DVM, University of North Carolina-Chapel Hill; and Emily Hearne, MS, also from UNC-Chapel Hill. Link: http://grants.nih.gov/ grants/olaw/educational_resources.htm. RePORT(ER). In her Sept. 22 blog post, NIH s Deputy Director for Extramural Research Sally Rockey updated stakeholders on changes to the World Research Portfolio Online Reporting Tool located at WorldRePORT.NIH.gov. The tool is an online database and map of research funded by NIH and other members of the Heads of International Research Organizations, HIROs; a beta version was released last year. Since that time, one new funding organization has been added (the European & Developing Countries Clinical Trials Partnership, EDCTP), and last month we took the next step to increase the utility by updating the site with projects funded by NIH in 2013 and expanding its coverage to include South Asia and East Asia/Pacific regions of the world. The other nine funders participating in World RePORT are now in the process of updating the database with projects funded in 2013 across this expanded set of regions, Rocky wrote. In a blog entry the next day, Rockey announced that NIH is collaborating with other agencies to create Federal RePORTER, a single web portal that allows for searching on federally funded science projects across multiple agencies. The project, still in alpha testing, is part of STAR METRICS and supports the program s goal of linking the federal government s scientific research investments to outcomes and outputs (e.g., patents, citations, workforce outcomes), Rockey wrote. New SACHRP Members. The Secretary s Advisory Committee on Human Research Protections has added three new members to its complement: Executive Director Diana T. Chingos, Noreen Fraser Foundation; Executive Director Holly Fernandez- Lynch, Petrie-Flom Center for Health Law Policy, Biotechnology, and Bioethics, Harvard Law School; and Reed E. Pyeritz, professor of medicine and genetics, vice chair for academic affairs, Department of Medicine Senior Fellow, Leonard Davis Institute of Health Economics Perelman School of Medicine, University of Pennsylvania. On behalf of SACHRP, HHS s Office for Human Research Protections said it would publish an additional invitation for members in the Federal Register in approximately six months. SACHRP will next meet on Oct. 29-30. Link: www.hhs.gov/ohrp/sachrp. Genomic Data Sharing. In late August, NIH announced its final genomic data sharing policy, effective for applications submitted to NIH for due dates beginning Jan. 25, 2015, for competing grants, contract proposals, and NIH intramural research projects generating genomic data. The policy applies to all NIH-funded, large-scale human and nonhuman projects that produce such data and is an extension of and replaces the Genome-Wide Association Studies (GWAS) data sharing policy from NIH currently in effect, according to a press release on the new policy. The policy was announced in the Aug. 28 Federal Register and was accompanied by two related NIH Guide notices published a day earlier NOT- OD-14-111 and NOT-OD-14-124. The new policy finalizes a draft issued in September 2013. NIH s Deputy Director for Extramural Research Sally Rockey noted in her Aug. 27 blog entry that her office has put together important implementation guidelines for grants that support research, and these and other resources are available at the NIH genomic data sharing website, http://gds.nih.govl. (8/28/14) Go to www.federalfundmanagement.com to review a calendar of upcoming webinars for federal fund managers