Updates from the Sponsored Programs Administration

Important Notice: Proposal Submission Deadline Adjustment for the Week of September 23

Dear Research Community,

We are pleased to announce that the Sponsored Programs Administration team (SPA) will be participating in a key team-building onsite event on September 24 and 25. This event is essential for enhancing our team’s collaboration and capabilities, ultimately enabling us to provide even better support for your research needs.

*If you plan to submit any grant proposals during the week of September 23rd, we kindly request that you work with SPA to have your proposal ready for submission by Friday, September 20th. If meeting this deadline is not feasible, we are happy to collaborate on an alternative solution.

Due to our involvement in this important event, we will have limited availability during the week of September 23. To ensure that we can process and review your proposals in a timely manner, we kindly request that you notify your Grant and Contract Administrator (GCA) no later than Monday, September 16, if you plan on any submissions the week of September 23. This will allow us to submit all proposals by the revised deadline of Friday, September 20.

We appreciate your understanding and cooperation in adhering to this adjusted deadline. Your timely submission will help us maintain the high level of support and service you expect from Sponsored Programs, even as we focus on strengthening our team.

Thank you for your attention to this matter. We look forward to continuing to support your research endeavors.

Best regards,  
The Sponsored Programs Team
                             

NIHs Adoption of Common Forms for Biographical Sketch and Current and Pending (Other) Support by May 25, 2025

 (NOT-OD-24-163)
 National Institutes of Health

NIH Guide for Grants and Contracts (Web Version) 

Weekly NIH Funding Opportunities and Notices for August 02, 2024 

Policy Notices

NIHs Adoption of Common Forms for Biographical Sketch and Current and Pending (Other) Support by May 25, 2025
(NOT-OD-24-163)
National Institutes of Health

Release Date:

July 31, 2024

Related Announcements

April 4, 2024 - Overview of Grant Application and Review Changes for Due Dates on or after January 25, 2025.  See Notice NOT-OD-24-084.

Issued by

NATIONAL INSTITUTES OF HEALTH (NIH)

Purpose

This Guide Notice informs the extramural community of NIH’s adoption of Common Forms for Biographical Sketch and Current and Pending (Other) Support to be used with all applications and Research Performance Progress Report(s) (RPPRs) by May 25, 2025.

Background

The Common Forms represent a collaborative effort between federal research agencies to ensure standard disclosure requirements as outlined in the National Security Presidential Memorandum - 33. The approved Common Forms for Biographical Sketch and Current and Pending (Other) Support (OMB Number 3145-0279 managed by the U.S. National Science Foundation (NSF)), can be accessed at NSF’s website at NSTC Research Security Subcommittee NSPM-33 Implementation Guidance Disclosure Requirements & Standardization.

NIH Common Forms Implementation

NIH will implement the Common Forms without change to any collection fields. However, in accordance with NIH’s Peer Review Regulations at 42 Code of Federal Regulations Part 52h, NIH currently plans to continue collecting three required agency specific data elements (i.e., Personal Statement, Contributions to Science, and Honors) to assess qualifications. These data elements will be collected separately from the Common Forms on a new NIH Biographical Sketch Supplement.

A high-level summary of NIH specific updates are as follows:

General Information

• NIH will require the use of Science Experts Network Curriculum Vitae (SciENcv) to complete Common Forms (i.e., Biographical Sketch, Current and Pending (Other) Support) and the NIH Biographical Sketch Supplement to produce digitally certified PDF(s) for use in application submission.
• NIH will require all Senior/Key Personnel to enter their ORCID ID into SciENcv in the Persistent Identifier (PID) section of the Common Forms.
  • NIH will require all Senior/Key Personnel to link their ORCID ID to their eRA Commons Personal Profile. For information on linking an ORCID ID to the eRA Commons Personal Profile see the ORCID ID topic in the eRA Commons online help.

Biographical Sketch

• NIH will no longer accept the NIH Biographical Sketch format page.
• NIH will require the use of the Common Form for Biographical Sketch.
• NIH will require the use of a new NIH Biographical Sketch Supplement to collect the “Personal Statement,” “Contributions to Science,” and “Honors” statements.

Current and Pending (Other) Support

• NIH will no longer accept the NIH Other Support format page.
• NIH will require the use of the Common Form for Current and Pending (Other) Support.

Failure to use the required forms or format pages may cause NIH to withdraw your application from consideration.

Please direct all inquiries to:

NIH Office of Policy for Extramural Research Administration (OPERA)
Division of Grant Systems Integration (DGSI)

Systems Policy Branch
nihosbiosketch@nih.gov

COGR Updates

Updated: COGR Matrix of Science & Security Laws, Regulations, and Policies:https://www.cogr.edu/cogr-matrix-science-security-laws-regulations-and-policies

New RCR Requirements for NSF Proposals & Awards

The CHIPS and Science Act of 2022 changed the National Science Foundation’s (NSF) required training for the responsible conduct of research (RCR). While RCR training is not new, there are two significant changes that became effective July 31, 2023 when NSF published its updated Proposal & Awards Policies Guide.

First, any personnel listed on proposals submitted to NSF must complete RCR training. This means training is no longer limited to undergraduate/graduate students and postdoctoral fellows but now includes faculty and senior personnel. Additionally, now RCR training must include mentorship, mitigation of foreign influence on research outcomes, and federal export control.

With each NSF proposal, BMC must certify that it has a plan in place to provide appropriate training and oversight in the responsible and ethical conduct of research. To ensure compliance, BMC’s Sponsored Programs Administration (SPA) and Research Compliance office recommend that all NSF faculty and senior personnel complete training at their earliest opportunity. 

Training Courses Offered

BMC partners with Boston University (BU) to provide BMC researchers with the appropriate training through a suite of online courses available through Collaborative Institutional Training Initiative (CITI) and in-person trainings. See course offerings and how to access them via the links directly below.

RCR for Undergraduates and Masters Degree Candidates (bu.edu) 

RCR for Faculty and Key Personnel | Office of Research (bu.edu)

RCR for Doctoral and Postdoctoral Researchers | Office of Research (bu.edu)

CITI courses:

1. Sign up for a CITI Account.
2. Affiliate with Boston University (please note that if you affiliate with Boston University Medical Campus through CITI, you will not be able to access the RCR course).
3. Select “Add a Course or Update Learner Groups”
4. Select the courses you need:
   1. RCR Basic (Note: Faculty and research staff should either complete the basic course or sign up to be part of the EK800 instructor team by emailing burcr@bu.edu)
   2. Undue Foreign Influence: Risks and Mitigations
   3. Export Compliance

Mentorship training:

Effective mentor training is aligned with individuals’ career stage and their specific interests, growth areas or skill needs. As such, there is not a singular program or approach for faculty and staff to meet this required topic. Below are a range of options for the mentoring requirement.

1. Provost Mentor Fellows, an in-person training program offered annually
2. Mentoring workshops through BU’s Clinical and Translational Science Institute (CTSI)
3. Programs and departments may request tailored mentoring workshops for faculty and research staff by emailing sch1@bu.edu
4. Faculty on the Medical Campus can participate in mentoring workshops offered by Faculty Development & Diversity

Additionally, other online resources available for mentor training include:

1. The Postdoc Academy (a BU-based initiative) has developed productive conversation frameworks to help faculty prepare for and have effective mentoring conversations with their trainees.
2. The University of Minnesota has also developed several online courses through their CTSI program.

Compliance is Everyone’s Responsibility

Please ensure that personnel (undergraduate students, graduate students, postdoctoral researchers, faculty, and other senior personnel) in your departments that are on NSF proposals submitted on or after July 31 are aware of and complete these requirements. SPA will contact department directors and principal investigators to identify trainees and assign appropriate training, and Research Compliance will track training completion with department leaders. Please note that these trainings do not need to be completed in any specific order, and that Principal Investigators are responsible for maintaining training records for their federally funded projects. Individuals who completed their RCR requirement through the original four (4) workshops can check their training status by emailing burcr@bu.edu, for those who have completed their RCR requirement by attending the 10-week 1 credit course (ENG EK 800), you can present your transcript as proof of completion.

Thank you in advance for your time and attention to these new requirements. Please don't hesitate to reach out with questions.

Jennifer Kennedy, Director, Sponsored Programs Administration, jennifer.kennedy@bmc.org   

Jami Wood, Research Compliance Officer, jami.wood@bmc.org                                    

Important Reminder

For PIs and departments that communicate directly with their sponsors or their sponsor contacts, please be reminded that all agreement, award and other sponsored programs related documents should be sent to Grants.Admin@bmc.org. If such communication(s) require(s) the PI(s) and sponsor(s) to communicate directly, please at least cc: Grants.Admin@bmc.org for awareness, particularly if the communication involves matters that may require any action from SPA.

Reminder: SPA Proposal Submission Process

To support your research, please follow these guidelines for proposal submission through Sponsored Programs Administration (SPA):

• Review Policy: SPA reviews all proposals before submission. Proposals must be fully routed and approved by the PI and Chief/Chair at least five (5) business days before the sponsor's deadline.
• Proposal Development: PIs should work with their department support staff or the FRGG team to prepare applications and InfoEd records. SPA does not support proposal development directly.
• Submission Process: Upload final proposal documents to InfoEd, route for final review (signed off by PI and Chief). SPA will then review, request any revisions, and upon approval, the assigned SPA Grants and Contracts Administrator (GCA) will coordinate the submission.
• Non-Federal Portals: For non-federal submissions, upload your portal login information to InfoEd as part of the supporting documents.

Resources:

1. InfoEd Generic Project Record Guide: This guide provides detailed instructions on creating an InfoEd record, the primary platform for proposal preparation.  
2. InfoEd Preparer Proposal Routing: This guide offers valuable insights into initiating the routing process within InfoEd for departmental approvals.  
3. Proposal Submission Work Guide: This comprehensive guide offers assistance with proposal development, including timelines, data entry in InfoEd, required documents, and more.  

Late submissions impact the review process and follow the Proposal Review Matrix in the Proposal Submission Work Guide.

By adhering to these guidelines, we can streamline the proposal submission process and maximize research success. Thank you for your cooperation!

Important Reminder

For PIs and departments that communicate directly with their sponsors or their sponsor contacts, please be reminded that all agreement, award and other sponsored programs related documents should be sent to Grants.Admin@bmc.org. If such communication(s) require(s) the PI(s) and sponsor(s) to communicate directly, please at least cc: Grants.Admin@bmc.org for awareness, particularly if the communication involves matters that may require any action from SPA.

SPA Proposal Submission Deadlines 

As part of our ongoing commitment to support your research endeavors, we want to remind you of the process for proposal submission through Sponsored Programs Administration (SPA). Effective collaboration and adherence to deadlines are crucial to ensuring smooth and successful submissions.

Per BMC policy, SPA is responsible for reviewing all proposals prior to submission. At SPA, we operate under a (5) five-business-day policy for proposal submissions. This means that all proposals must be fully routed and approved by the Principal Investigator (PI) and Chief/Chair at least five business days before the sponsor's deadline. Adhering to this policy allows us to conduct a thorough review and ensure compliance with both institutional and sponsor requirements.

It's important to note that SPA does not directly support proposal development. We expect the PI to collaborate with their department support staff (or Foundation Relations and Government Grants – FRGG team) to prepare the application and develop the InfoEd record.

Once the final proposal documents are uploaded to InfoEd and the InfoEd record is routed to SPA for final review (signed off by the PI and Chief), we will initiate our review process. Any requests for revisions will be communicated via email. Upon SPA's final approval, your assigned SPA Grants and Contracts Administrator (GCA) will coordinate the submission of the proposal to the sponsor with you.

If your application is submitted through a non-federal portal (e.g. foundation, industry portal), we require that your portal login information is uploaded to InfoEd as part of your supporting documents.

To facilitate this process, we've developed the following resources to aid in preparing and routing an InfoEd record to SPA:

1. InfoEd Generic Project Record Guide: This guide provides detailed instructions on creating an InfoEd record, the primary platform for proposal preparation. 

2. InfoEd Preparer Proposal Routing: This guide offers valuable insights into initiating the routing process within InfoEd for departmental approvals. 

3. Proposal Submission Work Guide: This comprehensive guide offers assistance with proposal development, including timelines, data entry in InfoEd, required documents, and more. 

Please remember that late submissions impact the review process. If a proposal is received later than the (5) five-business-day deadline, we refer to the Proposal Review Matrix outlined in the Proposal Submission Work Guide to guide our review. 

Thank you for your attention to these important guidelines. By working together, we can streamline the proposal submission process and maximize the success of your research endeavors.

The RPPR Preparation and Submission Process

The Research Performance Progress Report (RPPR) serves as the official progress report document for grantees to submit progress updates to NIH. It documents the accomplishments of grantees and compliance with the terms of the award. This article provides an overview of important reminders to ensure a complete and compliant report, and how to navigate the BMC submission process. 

Communications

• Two months before the deadline, eRA Commons will send an automated reminder. This is the ideal time to begin preparing the report. Note that only the PI or their official delegate can initiate an RPPR in eRA Commons.
• Your SPA GCA will also send courtesy reminders one month and two weeks before the deadline.

Special Instructions on Required Elements

• Consult the RPPR Guide for current instructions on developing your RPPR: https://grants.nih.gov/grants/rppr/rppr_instruction_guide.pdf
• Section A: You can list Christopher Garcia or Gina Nadler as Administrative Official. Your department’s assigned SPA GCA should be listed as the Signing Official.
• Section C: Ensure publications comply with the NIH Public Access Policy before submitting to SPA.
• Section D: If Other Support documents are needed, please confirm they are in the current format and include all four required sections (Active, Pending, In Kind, Overlap). Effort can not exceed 12 calendar months; please address overlap if it does. All Other Support documents must be electronically signed (Docusign, Adobe sign, etc.). Instructions, templates, and FAQs can be found here: https://grants.nih.gov/grants/forms/othersupport.htm
• Section G.4/ASSIST Human Subjects Section: For awards including clinical trials, updates to clinicaltrials.gov must be submitted at least two weeks before the RPPR deadline. Contact Karla Damus (damusk@bu.edu) for assistance.
• Section G.10: Confirm the unobligated balance projection with Sponsored Programs Finance before sending the report to SPA. Forward the confirmation email to your SPA GCA. 

Submission Process

• Submit your final, error-free report to SPA at least five business days before the deadline. The department will route the RPPR in eRA Commons to the SPA GCA assigned to your department when it is ready for review. 
• The SPA GCA will review the RPPR. If revisions are needed, the RPPR will be routed back to you with notes about the required changes. Once finalized and approved, the SPA GCA will submit the RPPR to the NIH in eRA Commons as the Signing Official. 

SPA Portfolio Assignments  

Our current portfolio distribution can be found on the Research Operations website (link below): 

Portfolio Assignment and Directory | Boston Medical Center (bmc.org) 

Escalation Contacts: 

1. Your SPA GCA is your 1st point of contact for SPA inquiries.  
2. For proposal submissions your secondary SPA contact is: Gina.Nadler@bmc.org 
3. For Non-Financial Post-Award matters your secondary SPA contact is: Christopher.Garcia@bmc.org 
4. For all other matters please reach out to Jennifer.Kennedy@bmc.org 

As a reminder, SPA oversees the non-financial administration of all sponsored awards at BMC, supporting the submission of proposals, negotiating agreements and accepting awards, and managing non-financial post award tasks. The "May 2024" section has an extensive compilation of SPA's duties.

SPA Proposal Submission Deadlines 

As part of our ongoing commitment to support your research endeavors, we want to remind you of the process for proposal submission through Sponsored Programs Administration (SPA). Effective collaboration and adherence to deadlines are crucial to ensuring smooth and successful submissions.

Per BMC policy, SPA is responsible for reviewing all proposals prior to submission. At SPA, we operate under a (5) five-business-day policy for proposal submissions. This means that all proposals must be fully routed and approved by the Principal Investigator (PI) and Chief/Chair at least five business days before the sponsor's deadline. Adhering to this policy allows us to conduct a thorough review and ensure compliance with both institutional and sponsor requirements.

It's important to note that SPA does not directly support proposal development. We expect the PI to collaborate with their department support staff (or Foundation Relations and Government Grants – FRGG team) to prepare the application and develop the InfoEd record.

Once the final proposal documents are uploaded to InfoEd and the InfoEd record is routed to SPA for final review (signed off by the PI and Chief), we will initiate our review process. Any requests for revisions will be communicated via email. Upon SPA's final approval, your assigned SPA Grants and Contracts Administrator (GCA) will coordinate the submission of the proposal to the sponsor with you.

If your application is submitted through a non-federal portal (e.g. foundation, industry portal), we require that your portal login information is uploaded to InfoEd as part of your supporting documents.

To facilitate this process, we've developed the following resources to aid in preparing and routing an InfoEd record to SPA:

1. InfoEd Generic Project Record Guide: This guide provides detailed instructions on creating an InfoEd record, the primary platform for proposal preparation. 

2. InfoEd Preparer Proposal Routing: This guide offers valuable insights into initiating the routing process within InfoEd for departmental approvals. 

3. Proposal Submission Work Guide: This comprehensive guide offers assistance with proposal development, including timelines, data entry in InfoEd, required documents, and more. 

Please remember that late submissions impact the review process. If a proposal is received later than the (5) five-business-day deadline, we refer to the Proposal Review Matrix outlined in the Proposal Submission Work Guide to guide our review. 

Thank you for your attention to these important guidelines. By working together, we can streamline the proposal submission process and maximize the success of your research endeavors.

Chief/Chair Proposal Approval Delegation in InfoEd

As summer approaches, we want to ensure that there is adequate coverage for proposal submission approvals for Chiefs and Chairs. If you expect to be out of the office during grant deadlines, we are able to set a delegate to approve submissions to avoid proposal submission delays. 

BMC uses InfoEd to track and capture proposals. All proposals must be approved by a department Chief or Chair prior to submission. InfoEd allows you to appoint a delegate to be included in your department’s proposal routing communications to approve proposals in the Chief or Chair’s absence. A delegate is a member on your team that carries equivalent or higher authority.

To appoint a delegate, please fill out the required e-form accessible at https://bmc.tfaforms.net/323

Upon submission of the form, the designated RIS@bmc.org team member will process the request and set up the delegate accordingly in InfoEd.

Please let us know if you have any questions.

Discretionary Account Setup Guide

SPA is sharing a new resource for the community: an InfoEd Record Creation Guide for Discretionary Accounts. 

To facilitate the setup of Discretionary Accounts, SPA requires two important components:

1. A completed and signed Discretionary Account Request Form
2. An InfoEd record to process the account setup

Discretionary accounts do not require the entire InfoEd record to be fully developed. Our new guide presents a detailed step-by-step procedure for setting up a discretionary account InfoEd record and what fields are required.

When the record is completed and the signed request form is uploaded to the record, kindly notify the SPA Award Administrator at grants.admin@bmc.org that the Discretionary Account InfoEd record is prepared and ready for processing. 

If you have any questions about this process, do not hesitate to reach out to Lula Mwamba at grants.admin@bmc.org. 

Process for Independent Contractors/Consultants on Sponsored Programs

SPA is pleased to announce the availability of the updated process for engaging Independent Contractors/Consultants (ICC) on Sponsored Programs. 

Proposal Preparation and Submission Phase:

During proposal preparation, departments intending to collaborate with an ICC on a sponsored project are required to upload the Subrecipient vs Contractor Guidance and Determination Form to the project’s InfoEd record. This form assists in determining the relationship between BMC and the external party. Sponsored Programs Administration (SPA) will review this form and make the final determination. If classified as a subcontractor, necessary documentation must be uploaded. If identified as an ICC, further steps are outlined.

Award Acceptance or Management Phase:

Should the determination form not be completed during proposal submission, the department must submit it to SPA for review and approval. Delays may occur if determinations are made during the award acceptance phase. For ICCs, the department follows specific steps, including completing the IC Request Form and submitting it accordingly.

For detailed instructions, please visit the SPA website at the link provided below:

https://www.bmc.org/research-operations/sponsored-programs-administration/subrecipients-v-contractors

Policy Updates- From the NIH Policy Corner

NIH has recently released the following Policy Updates. Please click on the links provided below for more information:

1. Fiscal Policies for FY 2024 (NIH NOT-OD-24-109) – went into effect after the Further Consolidated Appropriations Act, 2024 (Public Law 118-47), was signed into law on March 23, 2024. The specific policies addressed were:
   • FY 2024 Funding Levels
   • Kirschstein/NRSA Award adjustments
   • The NIH salary cap for 2024 was confirmed at $221,900 beginning January 1, 2024.
2. Legislative Mandates in Effect for FY 2024 (NIH NOT-OD-24-110) – With the signing of the Further Consolidated Appropriations Act, 2024, the following mandates went into effect:
   • Division D, Title II - Department of Health and Human Services
     • Salary Limitation (Section 202) 
     • Gun Control (Section 210) 
     • Indirect Costs (Section 224)
   • Division D, Title V - General Provisions, Departments of Labor, Health and Human Services, and Education
     • Anti-Lobbying (Section 503)
     • Acknowledgment of Federal Funding (Section 505)
     • Restriction on Abortions (Section 506)
     • Exceptions to Restriction on Abortions (Section 507)
     • Ban on Funding Human Embryo Research (Section 508)
     • Limitation on Use of Funds for Promotion of Legalization of Controlled Substances (Section 509)
     • Restriction on Disclosure of Political Affiliation for Federal Scientific Advisory Committee Candidates (Section 515(a))
     • Restriction on Dissemination of False or Misleading Information (Section (515(b))
     • Restriction of Pornography on Computer Networks (Section 520)
     • Restriction on Distribution of Sterile Needles (Section 526)
   • Please review the notice for further information regarding the topics addressed above.
3. Revision of the NIH Grants Policy Statement (Rev. April 2024) (NIH NOT-OD-24-115) – As you may be aware, the NIH Grants Policy Statement (NIH GPS), along with Uniform Guidance (2 CFR 200), provide guidelines and outline requirements and restrictions applicable to federal grant submissions, particularly for NIH/DHHS applications. This update of the NIH GPS provides updates, policy clarifications, changes in statutes and appropriate legal processes in effect for NIH grants and cooperative agreements issued on or after October 1, 2023. The 2024 version of the NIH GPS supersedes the entire December 2022 version of the NIH GPS.

Please feel free to contact Sponsored Programs Administration at Grants.Admin@bmc.org with any policy or clarification questions you may have, or please be in touch with your department’s assigned Grant and Contract Administrator (GCA) for other grant-related questions.

SPA Portfolio Assignments 

The SPA team recently welcomed a new Senior Grants & Contracts Administrator (GCA), Nicole Buchenholz, to our team. As Nicole completes her onboarding and training, we are in the process of redistributing portfolios among all GCAs. The updated portfolio distribution list is posted on the Research Operations website. 

SPA is actively facilitating the transition process for any departments that will be shifting to a different GCA. If your department will be reassigned and you have not yet been contacted by SPA, please feel free to reach out to your current GCA and Gina Nadler at Gina.Nadler@bmc.org. 

Our current portfolio distribution can be found on the Research Operations website: Portfolio Assignment and Directory | Boston Medical Center (bmc.org)

Escalation Contacts:

1. Your SPA GCA is your 1st point of contact for SPA inquiries. 
2. For proposal submissions your secondary SPA contact is: Gina.Nadler@bmc.org
3. For Non-Financial Post-Award matters your secondary SPA contact is: Christopher.Garcia@bmc.org
4. For all other matters please reach out to Jennifer.Kennedy@bmc.org

As a reminder, SPA oversees the non-financial administration of all sponsored awards at BMC, supporting the submission of proposals, negotiating agreements and accepting awards, and managing non-financial post award tasks. Below is an extensive compilation of SPA's duties:

Update to NIH Guidance on Making Changes in Resubmission Applications

Effective May 25, 2024, NOT-OD-24-061 replaces previous guidance on marking changes in Resubmission applications. The use of markups such as bracketing, indenting, highlighting, bolding, italicizing, underlining, margin lines, change in typography, font, or font color, or any other type of markup should not be used to identify changes in Resubmission applications.

Changes made to a Resubmission application should only be outlined in the Introduction attachment. The Introduction must include a summary of substantial additions, deletions, and changes to the application. It must also include a response to weaknesses raised in the Summary Statement. Unless otherwise indicated in the Table of Page Limits, the Introduction may not exceed one page.

Submit Copies of Progress Reports to SPA

As part of our ongoing efforts to streamline grant administration processes, we would like to kindly remind all Principal Investigators (PIs) to submit copies of their progress reports directly to grants.admin@bmc.org.

This reminder pertains to instances where an institutional signature is not required upon progress report submission. In such cases, we ask that you include grants.admin@bmc.org in your distribution list when sending progress reports to the relevant funding agencies.

Maintaining copies of your progress reports ensures that we have accurate records and can provide necessary support throughout the lifecycle of your projects. 

For progress reports requiring institutional signature, including all federal RPPRs, please ensure that the final version of your report is complete and sent to your SPA GCA for review at least five (5) business days prior to the deadline. 

Should you have any questions or encounter any challenges during the submission process, please don't hesitate to reach out to our team at grants.admin@bmc.org for assistance.

Reminders

Salary Cap Increase for NIH Awards

Guidance for Salary Limitation for Grants & Cooperative Agreements FY2024 (NOT-24-057)

The Office of Personnel Management recently released the new salary levels for the Executive Level Pay. Effective January 1, 2024, the salary limitation for Executive Level II is $221,900.

The new salary cap has been updated in Workday and awards will automatically be charged at this rate effective with February payroll. A Payroll Accounting Adjustment (PAA) to update January payroll to the new rate is optional unless not completing a PAA would result in non-compliance with the terms and conditions of the award (e.g., effort would be effectively reduced by 25% or more, etc.).

Read the full NIH Notice for more details.

Looking Forward – Upcoming Policy Changes for the remainder of 2024 and beginning 2025

NIH recently released several policy announcements notifying institutions and applicants that beginning January 25, 2025, new application forms (“Forms-I” – we are currently using “Forms-H”) for submitting proposals. In addition, please check out the following links regarding updates to the review framework for NIH Research Project Grants (RPGs – i.e., R01s). Please check the links below for upcoming submissions and policy changes after 2024:

1. Overview of Grant Application and Review Changes for Due Dates on or after January 25, 2025 (NOT-OD-24-084)
2. Simplified Review Framework for NIH Research Project Grant Applications - Update and Implementation Plans (NOT-OD-24-085)
3. New NIH "FORMS-I" Grant Application Forms and Instructions Coming for Due Dates on or after January 25, 2025 (NOT-24-086)
4. For NIAMS (National Institute of Arthritis and Musculoskeletal and Skin Diseases) Awardees or Potential Applicants: NIAMS Announces a New Funding Policy (NOT-AR-24-013)

New team member in Sponsored Programs Administration

SPA is thrilled to welcome Nicole Buchenholz to our team!

Nicole joins us as a Senior Grants and Contracts Administrator, bringing with her a wealth of knowledge and experience in scientific and clinical trial research operations and administration across various sectors, including large hospital systems, academic medicine, non-profit organizations, and industry. Nicole started her career at Dana-Farber Cancer Institute as research program coordinator in molecular and cellular biology in the Brown and Sellers labs and most recently held the position of project manager working on clinical trials at the Tisch Cancer Institute in the Icahn School of Medicine at Mount Sinai in New York. While at Mount Sinai, she also worked for ConduITS, Mount Sinai’s CTSA, as a system-wide liaison for guidance to facilitate the acceleration of translational research across an expanding research enterprise, which included research orientations, research resources, systems, regulations, guidance and education.

Contact Nicole at Nicole.Buchenholz@BMC.org or 617-414-2846.

With Nicole's addition to the team, SPA will be reallocating portfolios among all Grants and Contracts Administrators (GCAs) to ensure equitable distribution of tasks. Over the coming months, as Nicole undergoes onboarding and training, SPA will transition towards the new portfolio distribution. If your department will be supported by a different GCA moving forward, your current GCA or the SPA Manager will be in touch to introduce your new point of contact and discuss the transition process. The updated portfolio distribution list will be available on the Research Operations website once Nicole is further into her training.

Notice about using BMC emails in Proposals  

We want to remind Principal Investigators (PIs) about the importance of using your BMC email address for all proposals submitted through FRGG/SPA. 

Please remember that all proposals and other submissions certified by SPA are considered BMC business. BMC’s IT cybersecurity team has advised that any communication involving BMC business may contain PHI (Protected Health Information) or PII (Personally Identifiable Information). Such information, if sent to or forwarded to personal/non-BMC email addresses, such as Gmail, could potentially breach HIPAA regulations, resulting in fines for both the hospital and individuals involved, as commercial e-mail domains have not been vetted for HIPAA compliance.

When submitting proposals through BMC, please remember to use your BMC e-mail address as your contact address to ensure the security and integrity of BMC’s proposal submissions. If you have any questions or need further clarification, please feel free to contact your SPA Representative.

Updated NIH Requirements for Foreign Subaward Agreements

Subaward Agreements, particularly Foreign Subcontracts (NOT-OD-23-182)

NIH Final Updated Policy Guidance for Subaward/Consortium Written Agreements): This updates the requirements outlined in the NIH Grants Policy Statement (GPS) Section 15.2: Administrative Requirements and became effective on January 2, 2024:

NIH will not support any agreement that does not meet the minimum requirements outlined in the written agreement section below (15.2.1). NIH reserves the right to request copies of the written agreement and relevant supporting documentation as needed, as part of its oversight responsibilities. Failure to provide requested documentation may lead to remedies for noncompliance and potential enforcement actions (see NIH GPS Section 8.5, Specific award conditions and remedies for noncompliance).

Attention PIs and Proposal Developers

At the application stage, NIH expects Prime recipients (e.g., BMC) to ask potential subrecipients to include language in their letters of support indicating their awareness of these requirements and the subrecipient’s willingness to abide by all requirements should an award be issued.

Recommended Language to include in the Support Letter:

By agreeing to enter into and signing a subrecipient agreement with Boston Medical Center (BMC), [Subrecipient name] agrees to provide BMC PI(s) and project staff access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, to BMC with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report (RPPR) described in the subaward agreement issued to [Recipient name], should this application be selected for funding. [Subrecipient name] will make such data available via [insert recipient’s preferred method here (e.g., Sharepoint, Teams, Box, etc.)].

If a potential subrecipient chooses not to provide a letter of support that contains the language recommended above, the subrecipient site can instead submit a certification letter signed by the subrecipient PI and the subrecipient authorized official. The letter must be printed on the subrecipient institution’s letterhead and may be downloaded from: https://hub.bmc.org/doc/foreign-reporting-certification-form. 

Requirement:

15.2.1 Written Agreement

The recipient must enter into a formal written agreement, signed, and agreed to by both parties, with each consortium participant/subrecipient that addresses the negotiated arrangements for meeting the scientific, administrative, financial, and reporting requirements of the grant, including those necessary to ensure compliance with all applicable Federal regulations and policies and facilitate an efficient collaborative venture. If a subrecipient is unwilling to accept the requirements outlined in this section, by signing a written agreement, then an agreement cannot be issued. At a minimum, this agreement must include the following:

Note: All current requirements remain in place, with the addition of:

For foreign subrecipients, a provision requiring the foreign subrecipient to provide access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, to the primary recipient with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report submission. Such access may be entirely electronic.

This additional reporting requirement will be included in the subaward agreement issued to foreign subawards, as will a separate written agreement to be signed by both parties.

PIs and other investigators, this is a guidance and reminder for you as you contemplate entering into a consortium agreement with foreign institutions and requesting support letters from such institutions to include the assurance requirements outlined above. The administrative requirements will be included in agreement documents issued by SPA.

Revision to NIH Guidance on Marking Changes in Resubmission Applications

On February 13, 2024, NIH released Notice NOT-OD-24-061 rescinding its prior instructions for marking significant changes to Resubmission applications. Effective May 25, 2024, “The use of markups such as [bracketing], indenting, highlighting, bolding, italicizing, underlining, |margin lines, change in typography, font, or font color, or any other type of markup should not be used to identify changes in Resubmission applications.”

Changes made to a Resubmission application should only be outlined in the Introduction attachment. The Introduction must include a summary of substantial additions, deletions, and changes to the application. It must also include a response to weaknesses raised in the Summary Statement. Unless otherwise indicated in the Table of Page Limits, the Introduction may not exceed one page.

Post Submission Materials 

As we approach NIH scientific review season, it's crucial to address post-submission materials (PSMs). While generally accepted, their approval rests with the Program Officer (PO). PSMs are typically due 30 days before the Scientific Review Committee (SRC) review.

For upcoming proposals, if you haven't received an invite to submit PSMs, contact your PO to confirm acceptance. Note that some POs may not accept PSMs. PSMs, except for multi-component awards, are limited to one page and must strictly adhere to guidelines (NOT-OD-23-106 and NOT-OD-19-083). Deviations can lead to automatic rejection. PSMs must be submitted by your SPA Grants & Contracts Administrator.

Thank you for your attention to these vital details in navigating the NIH review process.

Just In Time (JIT) Materials 

As we navigate Just-in-Time (JIT) materials, remember there are two types of JIT requests:

1. Auto-Generated JIT Request:

This notification is sent to applicants whose proposals scored at or below the 50th percentile of the reviewed proposals. It's important to note that this is a courtesy JIT and not necessarily an indicator of potential funding. We recommend against responding to these auto-generated notices. Instead, we advise PIs to use this time to ensure compliance with regulations:

• For proposals involving human subjects research, IRB approval or exemptions should be secured.
• Similarly, for proposals involving animal research, IACUC approvals should be obtained or in progress.
• In rare cases, additional compliance requirements like biohazard/biosafety certifications may be necessary, requiring submission of proposals and IBC plans to the IBC committee for review and approval.
• Additionally, we propose implementing a new process for first-tier subcontractors:
  • Regardless of whether their Letters of Intent indicate human or animal subjects research, subcontractors should provide institutional IRB rulings/certifications regarding proposed work. This streamlines documentation for subcontract paperwork.

In summary, auto-generated JITs serve as a reminder to ensure certifications are in order, including refreshing RCR certification if necessary.

2. Personalized JIT Request:

The second type of JIT request comes directly from an individual at the funding agency/Grants Management Specialist. We advise PIs to wait for this personalized invitation before responding with requested materials. This request typically occurs a few months after the initial auto-JIT request. Waiting for the personalized JIT helps avoid submitting potentially outdated materials and indicates a stronger possibility of funding. This request also allows for final adjustments to certain elements, such as Other Support documents, Data Management and Sharing Plans, Resource Sharing Plans, and Multiple PI Leadership Plans.

Thank you for your attention to these JIT procedures, which help facilitate smoother proposal processing.

Project Closeout Requirements

A quick reminder regarding project closeouts: NIH is enforcing submission of three essential items outlined in NOT-OD-24-055. While Final Financial Reports and Final Invention Statement submissions have been relatively smooth and are submitted automatically by Sponsored Programs Finance and SPA, respectively, it's important to emphasize the requirement for final RPPR (fRPPR) submission within 120 days from project end. Completion and submission of the final RPPR is the responsibility of the PI, who can submit the final report directly to NIH via eRA Commons or can ask their SPA Grants Administrator to submit on your behalf. Failure to comply may jeopardize future funding considerations.

For those awarded competitive renewals, instead of fRPPRs, an interim RPPR (iRPPR) will be expected just before or soon after the renewal award is issued. This interim report should cover activities from the last year preceding renewal. Importantly, only the PI (or designee) can initiate fRPPRs or iRPPRs, so it's imperative for PIs to ensure this third closeout requirement is met.

Thank you for your attention to these critical details in project closeout procedures.

Protecting Your Interests and Compliance with NIH Requirements – Inventions and Patent Filings

A friendly reminder regarding inventions or patent filings: It's crucial to promptly report them to the BU Office of Technology Development (OTD) for submission to iEdison, a federal requirement for all inventions, patents and developments funded by federal grants and contracts.

While BMC doesn't directly access iEdison, collaboration with BU's shared IP service ensures compliance with NIH grants policy. Disclosure to OTD also helps secure any potentially commercializable inventions or patents, especially those arising from industry funding. Such developments should be reported to OTD as soon as practicable, in order for the PI to be assigned a case manager to initiate protection measures for potential discoveries.

Engaging with OTD, even if an invention may not ultimately be patentable, is a valuable step. Alternatively, PIs may consider consulting with Asa Lopatin in Research Contracts & Industry Agreements before involving OTD if they prefer an initial in-house consultation.

Thank you for your attention to these important procedures for protecting and managing intellectual property.

NIH Operates Under a Continuing Resolution

While NIH continues to operate under a continuing resolution, SPA wishes to advise PIs that, consistent with existing NIH practices since 2006, non-competing continuation awards (Type 5) may be issued at levels lower than previously committed in prior Notices of Award. This may necessitate some adjustments to the project’s next budget period projections. Once FY24 appropriations are enacted, NIH Institutes and Centers (ICs) may, at their discretion, adjust award levels on reduced awarded amounts to their original commitments, but this is not guaranteed. NIH recommends that institutions (and by extension, PIs and their project and financial teams) carefully monitor their expenditures during this period. These reductions in award levels may affect subawards issued and it is the responsibility of the PI and/or project team to inform the subcontract site of the need to reduce their award levels, if necessary. (Note: this does not affect NIH’s recent salary cap adjustment and does not change BMC’s established fringe benefit rates or recoverable F&A costs and is not an acceptable justification for any IDC rate reduction/waiver request on existing/continuing awards.)

General Reminders - Award Notices, Subaward Requests, DUA/DTA, and MTA  Requests

• If you are in touch with sponsors or funders who wish to fund your projects/research, please direct them to send all questions, correspondence and award materials to Grants.Admin@bmc.org.
• To initiate a request a new subaward or a modification to an existing subaward, please remember to complete the Subaward Request Form at https://bmc.tfaforms.net/170.
• To initiate or request a Data Use/Data Transfer Agreement (DUA/DTA) or Material Transfer Agreement (MTA), please first complete the intake form found at https://hub.bmc.org/doc/bmc-mta-dtua-intake-questionnaire and e-mail your completed form, along with any attachments to DUA.MTARequest@bmc.org. 

New Director of Sponsored Programs Administration

SPA is happy to welcome Jennifer Kennedy!

She is the new Director of Sponsored Programs Administration. She comes to us with an extensive body of knowledge and experience in research administration, which include operational management roles in grants and contracts, pre and post award, research finance, clinical trials, and billing compliance functions. Most recently, Jennifer held the position of Director, Office for Sponsored Programs at Boston College. Prior to that, Jennifer was the Director for Research Operations and Finance at Dartmouth Health, and previously an Associate Director at Duke University in the Office of Sponsored Programs. She began her research administration career at the University of Miami where she held the positon of Director, Sponsored Programs. Her strong background in both pre and post award will be an asset to lead the SPA team through existing and new initiatives. Jennifer holds a Black Belt Certification in Six Sigma, a management methodology for advanced statistical data analysis, and process improvement.

Contact Jennifer at Jennifer.Kennedy@BMC.org or 617-414-2852.

From the Policy Corner

Welcome to 2024! As each new calendar year begins, so do several federal (and non-federal) sponsor policy revisions or new requirements come into effect. This is to remind PIs and faculty that beginning in January 2024, the following policies will be enforced by NIH:

1. Subaward Agreements, particularly Foreign Subcontracts (NOT-OD-23-182)

NIH Final Updated Policy Guidance for Subaward/Consortium Written Agreements): This updates the requirements outlined in the NIH Grants Policy Statement (GPS) Section 15.2: Administrative Requirements and became effective on January 2, 2024:

NIH will not support any agreement that does not meet the minimum requirements outlined in the written agreement section below (15.2.1). NIH reserves the right to request copies of the written agreement and relevant supporting documentation as needed, as part of its oversight responsibilities. Failure to provide requested documentation may lead to remedies for noncompliance and potential enforcement actions (see NIH GPS Section 8.5, Specific award conditions and remedies for noncompliance).

Requirement:

15.2.1 Written Agreement

The recipient must enter into a formal written agreement, signed, and agreed to by both parties, with each consortium participant/subrecipient that addresses the negotiated arrangements for meeting the scientific, administrative, financial, and reporting requirements of the grant, including those necessary to ensure compliance with all applicable Federal regulations and policies and facilitate an efficient collaborative venture. If a subrecipient is unwilling to accept the requirements outlined in this section, by signing a written agreement, then an agreement cannot be issued. At a minimum, this agreement must include the following:

Note: All current requirements remain in place, with the addition of:

For foreign subrecipients, a provision requiring the foreign subrecipient to provide access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, to the primary recipient with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report submission. Such access may be entirely electronic.

This additional reporting requirement will be included in the subaward agreement issued to foreign subawards, as will a separate written agreement to be signed by both parties.

PIs and other investigators, this is a guidance and reminder for you as you contemplate entering into a consortium agreement with foreign institutions and requesting support letters from such institutions to include the assurance requirements outlined above. The administrative requirements will be included in agreement documents issued by SPA.

2.    Requirement to include eRA Commons ID Requirement for All Personnel on the R&R Senior/Key Person Profile Form on Proposals (NOT-OD-24-042)

Attention PIs and Proposal Developers

Currently applications submitted with missing eRA Commons credentials (i.e., eRA Commons Username), only receive a “Warning” during validation before submission of the proposal. However, effective January 25, 2024, proposals submitted on and after this this date with missing or incorrect/unmatched eRA Usernames for any individuals identified as a Senior/Key Personnel (S/KP) will generate an “ERROR” upon validation, which will prevent the submission of the proposal. At the time of proposal preparation, please ensure that all individuals that will be included in the S/KP section have valid eRA Usernames issued by BMC or their respective institutions (in cases of external collaborators) entered into the appropriate proposal fields. For BMC S/KP without an eRA Username, you may request one by completing the form found here and submitting it to Grants.Admin@bmc.org. Please allow 1-2 business days for the creation of a new eRA Username. 

NIH Increases Salary Limitation for FY 2024 to $221,900, effective January 1, 2024

Please note that the Federal Executive Level II salary cap for 2024 has increased to $221,900 effective January 1, 2024 and should now be used for proposals going to sponsors for which the salary cap is applicable.  These sponsors include NIH agencies, the FDA, and Department of Justice agencies. This does not include other agencies which do not enforce the salary cap, such as DOD and NSF. PCORI remains at a $200,000 salary cap. 

For active awards, including awards that have been issued in FY 2024 (continuation and new) that were restricted to Executive Level II, if adequate funds are available and if the salary cap increase is consistent with the institutional base salary, recipients may rebudget funds to accommodate the current Executive Level II salary level.

Here is a link to the official notice: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-24-057.html 

Please contact your SPA representative if you have any questions about this.