University of California

Office of the President

 

Senior Vice President—

Business and Finance

Memo

Operating

Guidance

 

Research Administration Office

No. 04-01


March 31, 2004

 


CONTRACT AND GRANT OFFICERS

Subject: Federal Demonstration Partnership Phase IV - Revised Prior Approval Matrix 1/04

The Federal Demonstration Partnership has revised its "Prior Approval and Other Requirements Matrix" as of January, 2004. http://www.nsf.gov/pubs/fdp/fdpmatrix.xls or http://www.nsf.gov/home/grants/grants_fdp.htm. A table of the January 2004 Prior Approval Requirements is attached to this Memo. The changes are summarized below.

Summary of Changes:

General Requirements:

Subaward of "significant part": DOE has changed to "Waived." However, DOE's agency-specific terms (2) require notification to "the Contracting Officer of the transfer of a significant part of the research or substantive programmatic effort only when the transfer represents more than 25 percent of the effort or a change of scope." Footnote 2. under NIH is changed to: " Waived unless change in scope or when subawardee is foreign" which adds "change in scope of work" to NIH prior approval requirement for subawards.

Initial no-cost extension changed to read: "Initial no-cost extension of up to 12 months (per competitive segment)" and DOE changed to "Waived."

Carry-forward of unexpended balances: DOE changed to "Waived." The new footnote 7. under NIH reads: "Waived except when award indicates prior approval is required" rather than requiring NIH prior approval for carry forward greater than 25%.

Cost-related Requirements:

Rebudgeting among budget categories:
NIH has changed to "Waived unless change in scope." The new footnote 8. reads: "Waived unless change in scope" from NIH prior approval requirement for rebudgeting more than 25%.



Rebudgeting between direct and F&A costs:
NIH has changed to "Waived unless change in scope." The new footnote 8. reads: "Waived unless change in scope" from NIH prior approval requirement for rebudgeting more than 25%.
Rebudgeting of funds allotted for training:
NIH has changed to "Waived except for Kirschstein-NSRA grants." A new footnote 9 reads: "Waived except for Kirschstein-NRSA grants."

Equipment not in approved budget:
NIH has changed to "Waived unless change in scope."

Foreign travel:
EPA has changed to "Prior approval required."

Restrictions on costs not explicitly unallowable:
NSF has changed to "Prior approval required to modify the amount of cost sharing reflected in Line M of the award budget." (New footnote 15.) Footnote 14. under NIH is revised to add: "if change on scope" to now state: "Prior approval required for patient care costs if change in scope."

Project Management Requirements:

Use of sponsor budget forms:
NSF has changed to: "Must be submitted electronically via the NSF FastLane system at https://www.fastlane.nsf.gov." (A new footnote 20.)
USDA has changed to "Not required" from "Required."

FDP Agency-Specific Terms and Conditions:

Two FDP member agencies have modified their agency-specific terms and conditions since their previous publication in October, 2002. National Institutes of Health (NIH) agency-specific terms and conditions were modified in May, 2003. NASA agency-specific terms and conditions were modified in October, 2003. However, both agencies have indicated that these changes are corrections or clarifications and can, therefore, apply to current FDP grants.

Agency changes are summarized below:

NASA: http://www.nsf.gov/pubs/fdp/nasa03.pdf
Article 1 - Modified to include education and training grants.
Article 17 (b) "The Recipient will observe property standards and provisions set forth in §§ 1260.131 through 1260.137" is deleted. Property standards are already covered in the FDP implementation of OMB Circular A-110, Sections 31 through 37.

National Institutes of Health: http://www.nsf.gov/pubs/fdp/nih03.pdf
Article I. B. - Adds SNAP explanation.
Article II. A. - Modified to reflect current implementation of carryover authority.
Deleted paragraph in this section regarding patient care costs since this is covered under "Change in Scope" in "Prior Approval Matrix."
Deleted "NIH will review carryforward estimates that exceed 25% of the total award."
Deleted paragraph on "allowability of direct costs" as duplicative of next article.
Article III. Renamed to "Allowable Direct Costs…."
Article IX. - Adds links to various sections of the NIH Grants Policy Statement.

Refer: Samuela A. Evans Subject Index: 02, 19
(510) 987-9849 Organization Index: U-115
Samuela.Evans@ucop.edu



David F. Mears
Director - Research Administration

Attachments

Cc: Extramural Accounting Managers

FDP IV AGENCY-SPECIFIC PRIOR APPROVAL REQUIREMENTS
Is agency prior approval required if action/cost is not in the approved budget?

ITEM ARTICLE AGENCY REQUIREMENTS

1. Relatedness 27. (a) (2) NO - All Agencies
2. Change in Scope 25. (b) (1) YES - All Agencies
3. Absence or Change of PI 25. (b) (2) YES - All Agencies
4. Preaward costs up to 90 days 25. (c) (1)
NO - All Agencies
5. No-cost extension up to one year 25. (c) (2) NO - EPA; NASA; NSF; AMR; DOE; & USDA. However, EPA requires prior approval if project period would exceed 5 yrs. with extension. NIH except on specified grant mechanisms.
DOE requires prior approval for no-cost time extension & carry forward of unobligated balances when award indicates funding is restricted to one year money.
YES - AFOSR; ARO; ONR;
6. Equip > $5,000 threshold 27. (a) (1) NO - All Agencies except ARO
YES - ARO

7. Substantial contracting out of work 25. (b) (4) YES - All Agencies except DOE, NIH, & USDA.
DOE - Notify CO "only when transfer represents more than 25% of effort or a change of scope. (Article 2.)
NIH - Required only a change of scope or to a foreign entity.
USDA - Required if more than 50% of total dollars is subcontracted.
8. Contracting out to Federal Agency NO - All Agencies except USDA.
YES - USDA. Any subcontract to federal agency must have prior written approval.
9. Foreign Travel NO - All Agencies except ARO and EPA.
YES - ARO and EPA
10. Alteration/ Renovation > $25,000 27. (a) (1) (v)
USDA Agency Specifics YES - All Agencies
ARO requires approval even if source is funds is cost-sharing.
NIH > $300,000.
USDA - No funds may be used for renovations.

11. Budget carryforwards > 25% of total award NIH & DOE Agency Specifics NO - All Agencies except NIH. However, DOE requires prior agency approval if award funds are restricted to one year. (Art.2)
NIH - If stated in specified grant mechanisms.
12. Rebudgeting to patient care costs NIH Agency Specific NO - All Agencies except NIH.
YES - NIH - Prior approval required if change in scope.

13. Rebudgeting of participant/trainee support allowances Article 25. (c) (7) NO - All Agencies except NSF and NIH.
YES - NSF - Requires written prior approval for reallocation of any participant/trainee support costs. NIH required for Kirschstein-NRSA grants.


FDP IV AGENCY-SPECIFIC SPECIAL RESTRICTIONS ON EXPENDITURES
In addition to costs specifically unallowable under A-21

Is the cost allowable without specific approval of the granting agency if the cost benefits the project?

ITEM ARTICLE AGENCY REQUIREMENTS
1. Use of non-U.S. flag air travel. Appendix B - Page 9 NO - All Agencies unless specific conditions in Appendix B, Page 9 are met.
2. Purchase of real property Article 32. NO - All Agencies
3. Interest for late payment to contractor YES - All Agencies except DOE.
NO - DOE
4. Payment of consultant fee > Fed. Exec. Level IV Appendix B. - Page 9 YES - All Agencies except EPA, NASA, and NSF.
NO - EPA, NASA, & NSF
5. Salary payment > salary cap. NIHGPS - Part II. YES - All Agencies except NIH.
NO - NIH
6. Purchase of dogs/cats for research Appendix B. p. 14 YES - All Agencies except AMR.
NO - AMR Article 13. If restricted in award document.