Tag Archives: Compliance

You must answer each of the three fiscal compliance questions in this section of the eGC1 Budget & Fiscal Compliance page.

Question F1: Will F&A costs be reimbursed at less than a federally negotiated rate for the UW?

The F&A Cost Rate is determined by the location(s) where the research is performed and is charged as a percentage of total Direct Costs. Rates can be found in GIM 13: F&A Rate Table.  Guidelines for determining split rates when projects are conducted at two or more locations are found at GIM 13: Activity at Two or More Locations.

See also GCA’s page on Facilities & Administrative Costs.

If you answer Yes:

  • Item F1a will display: Attach GIM 13 waiver in the Documents for OSP section of the attachments page, or provide documentation of sponsor F&A policy (e.g. RFP, application documents, or website URL)
  • Use the text box to enter your documentation, or upload an attachment on the Attached Documents page.

Note: for RRF applications, the answer to this question must be No.

Question F2: Will administrative or clerical support be included in the budget as direct costs? (see GIM 23)

NIH grants do not allow administrative or clerical personnel costs unless they meet the criteria in GIM 23.

If you answer Yes:

  • Explain how administrative or clerical personnel will be used in the proposed project, following the criteria in GIM 23 Appendix A (Examples of Direct Costs).  This must be appropriately justified in the sponsor application, following sponsor guidelines.

Question F3: Does this application commit funds for cost sharing or matching?

Cost Sharing, Matching or Continuation occurs when an application promises to deliver a support or service for which the research grant does not pay.

  • Cost Sharing may be mandatory (required by sponsor) or voluntary (a contribution of effort or other costs offered by the Principal Investigator which the sponsor does not require as condition of the award).  Cost sharing occurs when an application commits allowable expenses (i.e., personnel, tuition, equipment or services) for which the research grant will not pay. You must charge these costs to an alternate source (UW or third party). You need to identify all sources and they must agree (via the eGC1 approval process) to commit the necessary funds. For more information, see the GCA Cost Sharing Overview page or GIM 21: Cost Share on Sponsored Programs.
  • Matching funds occur when proposal funding is contingent on a unit’s agreement to commit a matching amount of funding ($) to a project. Matching funds may come in the form of a gift or a grant.
  • Continuation funding takes three forms:
    • (a) it provides funding from a secondary source for ongoing support of a project after the original funding is depleted
    • (b) continuation funds may also be granted if the project is unable to be completed by the original time line and the sponsor has agreed to provide supplemental funding to see the project through to completion
    • (c) continuation funding also occurs when a portion of the original funding commitment is continued and the remaining budget must be found in grant money.

If you answer Yes:

  • Identify whether you are including cost sharing, matching or program continuation.
  • Provide a brief explanation in the text box and attach the completed Addendum form on the Attached Documents page. (On the Addendum, complete all fields including faculty effort, budget number and third party contribution.)
  • Indicate the cost sharing amounts and sources in the Personnel section of the eGC1’s Cost Sharing page.

October 2017 SAGE Compliance Release 1

As part of a larger effort to improve usability and content of the eGC1 Compliance page, this release makes a number of alterations to better focus the Compliance page on non-fiscal compliance questions. This was accomplished by either removing questions or relocating them to more intuitive sections of the eGC1.

There are more changes coming to the Compliance page in a later release that will build upon these enhancements.

Compliance Page Changes

Question Change
FG-1 Cost Share Relocated to Budget & Fiscal Compliance page
FG-2 Conducted off campus Replaced by Activity Locations section
FG-3 F&A at less than federally negotiated rate Relocated to Budget & Fiscal Compliance page
FG-4 New, rental or renovation Relocated to Activity Locations page
FG-5 Compensation for overtime Removed
FG-6 Deliverables Removed
FG-7 Administrative support Relocated to Budget and Fiscal Compliance page
FG-8 Interdisciplinary facilities Relocated to the PI, Personnel & Organizations page
FG-9 Review by other organization Relocated to the PI, Personnel & Organizations page
NG-1 Advancement assistance Removed
NG-3 Originating sponsor Relocated to the Details page with other sponsor information

New Activity Locations Page

A new page has been added to the eGC1 that centralizes details related to the location of research activities in a proposal.

This page includes relocated questions, as well as more detailed tracking on each location where UW work will take place. The sections on this page are:

Activity Locations

  • Includes identification of each location where UW research activities are taking place along with details helpful for budgeting and F&A rate determination.
  • The Location Search integrates with the UW’s space tracking system GeoSIMS, allowing you to partially enter a facility name, address or facility code and populate the eGC1 with the data for that location.
  • You can also manually enter locations not found in GeoSIMS.

Space Planning

  • Includes the “construction or renovation” question formerly on the Compliance page, along with approval details when answered ‘Yes’.

International Involvement

  • Includes the international involvement question and country identification formerly on the Details page. Country is now sourced from the more comprehensive international standard ISO 3166.

This new page introduces an updated, intuitive and more modern experience for SAGE. Based on feedback from users, we will be incrementally updating SAGE to new design standards with each new release.

Fiscal Compliance Combined with Budget

The existing FG-1, FG-3, and FG-7 compliance questions related to fiscal compliance have been relocated to the top of the Budget page (now rebranded “Budget & Fiscal Compliance”), along with the useful explanations when ‘Yes’ is selected.

Details Page Updates

The existing NG-3 “originating sponsor” compliance question has been relocated to the Details page directly below the Sponsor selection.

The international involvement question has been relocated to the Activity Locations page.

PI, Personnel, & Organizations Page Updates

The existing FG-8 Compliance question on interdisciplinary facilities, service centers, etc. has been relocated to the PI, Personnel, & Organizations page. In a previous release, the FG-9 “other organizational reviewers” question was relocated to this page as well. With these two changes, you can now better manage your eGC1 approvals in one location.

SAGE Toolbar Update

The “reset form” icon on the upper SAGE toolbar has been removed. Removal of this rarely used feature will allow the application design to progress to more modern standards.

SPAERC: Intellectual Property Questions Added to FA/PAC/NAA

A new question has been added to the FAs, PACs, and NAAs in SPAERC for OSP post-award administrators to indicate when an agreement includes an upfront exclusive commercial license or ownership over the project’s intellectual property. CoMotion will receive notification when these are marked YES in order to get a jump start on IP negotiation.

SPAERC: BUG FIX – Internal OSP Notes no longer display in SAGE Subawards “Latest Update”

An issue that was causing internal OSP notes for subawards to display in SAGE under “Latest Update” for requests in process has been resolved. The “Latest Update” will now only display the most recent status update and any accompanying comments to/from campus and OSP.

March 2016 SAGE Maintenance Release

General Updates

A New OAW Compliance Question for Significant Protocol Changes

A new compliance question, AC-1-D, has been added to identify grants that will require a Significant Change at the time of submission. An answer is required if the Animal Use question AC-1 is answered “Yes”.

A few textual enhancements (for existing compliance questions) were made to allow OAW to process the grants more efficiently, and they include:

  1. Removing the facility name and location of the work to be done on the AC-1-A for UW work
  2. Requesting the 3-year approval date range
  3. Updating electronic document submission contact info.

Sub-Object Codes 05-47 and 05-48 Added to Sage Budget for Grandfathered Awards

Effective July 1, 2016, UW’s equipment capitalization threshold will increase from $2,000 to $5,000. This change applies to all competing proposals submitted to sponsors on or after May 1, 2016. The following changes were made in Sage Budget to accommodate this threshold change:

  1. Two new object codes will be added to (05) Supplies and Materials to allow grandfathered awards to continue to use the old threshold for non-capitalized equipment:
    • 05-47 Non-Capitalized Equipment ($2,000-$4,999) – Grandfathered Awards
    • 05-48 Non-Capitalized Equipment – M&E Tax Exempt ($2,000-$4,999) – Grandfathered Awards
  2. These two new object codes will be excluded from F&A calculation when using the following cost bases for budgets associated with grandfathered awards:
    • Exclude 05-47 and 05-48 form Total Direct Costs less Equipment & Tuition (TDC less E&T)
    • Exclude 05-47 and 05-48 from Modified Total Direct Costs (MTDC)
  3. The following object code descriptions will be updated as listed below to reflect the new threshold of $5,000:
    • 05-40 Non-Capitalized Equipment (less than $5,000)
    • 05-41 Non Capitalized Equipment –M&E Tax Exempt ($200 – $4,999)
  4. The following object code descriptions will be updated as listed below to reflect their INACTIVE status upon 4/1/2016:
    • 06-10 Inactive – Computing Equipment ($2,000-$4,999)
    • 06-12 Inactive – Computing Equipment – M&E Tax Exempt ($2,000-$4,999)
    • 06-90 Inactive – Other Equipment (Non-computing) ($2,000-$4,999)
    • 06-92 Inactive – Other Equipment (Non-computing) – M&E Tax Exempt ($2,000-$4,999)

Personnel with an Invalid NetID will not be selectable

With this change, all active staff in the Person Web Service will continue to show in the results on staff search, but those without NETIDs will not be selectable, and users will see a note indicating that the NETID must be established before the person can be selected.  Allowing personnel without NETIDs to be selected as personnel caused errors on the personnel list afterward.

Grant Runner Forms-D Implementation

Grants.Gov will be updating its systems to FORMS-D, for all applications submitted for due dates on or after May 25, 2016. The Grant Runner forms that will be updated to comply with FORMS-D requirements are identified below. There may be some application packages which include both a FORMS-C and a FORMS-D as options, and in this case users will be prompted in SAGE to select the appropriate one based on the due date. Per NIH, FORMS-C application packages will be set to expire after the May 7, 2016 AIDS due date.

Update of PHS 398 Cover Page Supplement to Forms-D

For Grants.Gov FORMS-D, users will notice the following changes applied to the Grant Runner Coverage Page Supplement form:

  • A new “Vertebrate Animals” section, which includes questions on euthanization and use of AVMA guidelines.
  • Removal of the PD/PI section
  • Removal of the Disclosure Permission section
  • The ability to add Program Income information for 10 budget periods (previously 5)
  • Re-ordering of fields to accommodate the new additions and removals

Update of PHS 398 Research Plan to Forms-D

For Grants.Gov FORMS-D, users will notice the following changes applied to the Grant Runner PHS 398 Research Plan form:

  • New “Data Safety Monitoring Plan” attachment
  • New “Authentication of Key Biological and/or Chemical Resources” attachment

Creation of a New PHS Inclusion Enrollment Form for Forms-D

For Grants.Gov FORMS-D, users will notice a new form called “PHS Inclusion Enrollment Report” in Grant Runner. This single form will replace the 2 separate forms in FORMS-C applications (Cumulative Inclusion and Planned Enrollment Report). With the Forms D changes, users will notice some additional fields to identify the type of reporting being done (“Delayed Onset Study?”, “Enrollment Type?”, “Existing Data Set or Resources?”) When “Delayed Onset Study” is marked YES, the remainder of the form will not be editable, per form rules.

Store activity type code for Grant Runner Applications

In order to aid in the analytics of Grant Runner usage, the SAGE system will begin to retrieve and store the Activity Type code from Grants.Gov, as we are retrieving submission status information.

Fixes

Error when Inactivating Advances

An issue that was causing users to receive an error when trying to discard advances has been fixed.

September 2015 SAGE Maintenance Release

EHS-2 Compliance Question Update

The EHS-2 question on the Compliance Questions and Explanations pages of the eGC1 has been updated on all new eGC1s created after the September 2015 release.

Updated logic for the display of the HS-1-B Compliance Question Explanation

The HS-1-B question on the Compliance Explanations page of the eGC1 will now display under the additional condition of a Contract that is utilizing Just-In-Time human subjects approval.

Compliance question HS-1-B was not displaying/hiding in real time, when Project Type = Contract

Conditional questions and instructional text in the Human Subjects section of the Compliance Explanations page of the eGC1 now update in real-time when the eGC1 is for a Contract.

 Prevent multiple RegIDs for the same person from being entered into SAGE

When a user is erroneously assigned multiple RegIDs at the University, it has caused problems with accessing their FIDS information. A change has been made to disallow multiple RegIDs for the same person in the SAGE database.  Upon logging into SAGE, the user will receive an error that is also recorded in the SAGE Suite error log. This error will alert the SAGE team to take the necessary action to resolve the issue with UW IT.

Grant Runner Validation Update on Detailed Budget

A validation was added to the Grant Runner detailed budget form to disallow zero entries in the “other” cost field. This will help mitigate submission errors.

SERA   

Older FAs in SERA have problems opening

An issue that had prevented Funding Actions that predated the creation of the Authorized Action field from being opened in SERA has been fixed.

The system adds reviewers to the approval flow when a preparer answers “Yes” to select compliance questions or to a compliance question in combination with other data.

The following table describes when a Compliance Reviewer is added, which individual or unit is added, and whether the Reviewer is an Approver or a Watcher.

Condition Reviewer Added Approver or Watcher
Environmental Health & Safety
EHS-1 – Biohazards selected EHS BioSafety Watcher
EHS-1 – Select Agents and Toxins selected EHS Select Agents Watcher
EHS-1 – Radioactive Materials selected EHS Radiation Watcher
EHS-1 -SCUBA Diving selected EHS Diving Watcher
EHS-1 – Chemical Thresholds selected EHS Fire Code Compliance Watcher
Animal Use
AU-1 = Yes AND the application is After-the-Fact (ATF)

OR

The application type is:

  • Transfer from Another Institution
  • Supplement and Extension
Animal Subjects Approver; see additional notes below
Data & Technology
D-2 = Yes: Is the project intended to assist a foreign country’s military or space activities? Export Control Watcher
D-4 = Yes: Will the project involve travel to or collaboration with a person or entity in a sanctioned country (e.g., Cuba, Iran, North Korea, Sudan, Syria)? Export Control Watcher
Historical Security Question
SEC-4 = Yes (potentially involves access to classified national security information); only appears on older eGC1s Security Reviewer Approver

Additional Animal Use Notes

  • For an application with AU-1 = Yes, and an application type other than those listed above, the review is done “just-in-time”, when the sponsor notifies the PI that the proposal has a fundable score. Upon that notification, the PI or other application owner adds Animal Subjects to the Approval Graph as an ad hoc watcher. The system then sends an email notification to the Animal Subjects reviewers and gives them access to the application.
  • On the Non-Fiscal Compliance page, if a user chooses an existing Hoverboard protocol or enters a new protocol, and the protocol indicates that the Primate Center will be used, then the Department/Center Reviewer for the Primate Center (org code 3010221000) is automatically added to the Approval Graph as an Approver.

May 2014 SAGE Release

New Features

SAGE eGC1s and Approvals Search Enhancements

Users will see a few new search features available to them, on the eGC1 and Approvals task lists.

  • Users will now be able to jump more directly to a particular eGC1 from their My eGC1s or My Approvals pages, using a new eGC1 search field located on the task lists.
  • Users can now search in My Approvals by personnel name. Search results will include all eGC1s for which they are an approver or watcher, where the chosen person is listed on the PI & Personnel page regardless of role type.
  • The PI Name field has been added back to the My eGC1s Advanced Search tool, to allow users to quickly enter all or part of a PI’s name and initiate a search. This feature was removed in January, when the Personnel Search feature was added, but by user request, both fields will now be available for those that like the speed of being able to quickly find eGC1s by PI name.
  • When a user performs an Advanced Search from the My eGC1s task list, they will be able to export their search results to Excel.

Addition of University District Building to Location List

  • The University District Building has been added to the off campus locations list found on the FG-2 compliance explanations section of the eGC1. It will now be easier for eGC1 Preparers to select that building when projects are eligible for the location designation of “off campus”, and will no longer need to enter the location address.

Suppression of HSD JIT and GIM 19 notifications for ATF and Industry Sponsored Clinical Trail eGC1s

  • Human Subjects Just-In-Time email notifications and GIM 19 deadline email notifications will no longer be sent to contacts for eGC1s that are after-the-fact or industry sponsored clinical trials.

Updated handling when users attempt to remove themselves from an eGC1 or Budget

  • When users remove themselves from an eGC1 or budget, they will now receive a warning, alerting them that their access to that eGC1 or budget may be affected. When users remove their last access to an eGC1 or budget, they will now be redirected back to their task list.

November 2013 SAGE Maintenance Release

New Features

Additional FG-3 compliance question validation for RRF eGC1s

  • eGC1s that have Royalty Research Fund (RRF) as the sponsor will display a validation error if question FG-3, the question about F&A cost reimbursement, on the Compliance Questions page is marked as ‘Yes’. RRF requires FG-3 to always be marked as ‘No’, so this validation error is intended to ensure that the eGC1 preparer selects the correct response prior to completing the eGC1.

Increase character limit in “Reason” field when adding Approvers and Watchers

  • The “Provide a reason” field when adding an Approver or Watcher on the Approval Flow Screen has been increased from 250 characters to 1000. Department and School reviewers who add additional Approvers and Watchers like to include detailed instructions in that comment box and needed a higher character limit.

We now will show all recipients on the TO line of SAGE auto-generated email notifications.

  • SAGE users will be able to see all persons who received the same Auto-generated SAGE email on the TO: line of the email. This was a frequent request from campus through our help desk and survey responses.

Fixes

Inadvertent sending of disclosure notifications

  • Fixed the system to prevent investigators from receiving disclosure notifications when an old awarded eGC1 is opened. The system will now only trigger disclosure notifications when there is an investigator change made to the eGC1 (addition of an investigator or change of personnel to an investigator role).

HSD JIT email notifications are suppressed for RRF eGC1s

  • Human Subjects Just-In-Time emails will no longer be sent to the owners of eGC1s where the Royalty Research Fund (RRF) is the sponsor. RRF is an internal UW sponsor and operates differently than external sponsors. Unique characteristics of RRF opportunities include shorter application/review/award timelines and the lack of “fundable score” notifications. These unique characteristics therefore made the Human Subjects JIT email irrelevant and confusing for the owners of the eGC1.

New clarifying message displayed when clicking on Investigator Disclosure History and FIDS Profile is not yet established

  • If an Investigator has never completed a disclosure in FIDS, or does not have any disclosure history for the past 12 months, a new user-friendly message stating there is no history will display when the Investigator Disclosure History link is clicked.

New error message displayed when you have attachment upload errors due to hidden or invalid characters in file name

  • A new error message will display in SAGE if you attempt to upload eGC1 attachments with invalid characters in the file name. To correct this issue, rename the file on your computer by directly typing in the characters before attempting to upload it in SAGE.

April 2013 SAGE Maintenance Release

New Features

SAGE Budget: Preliminary Benefit Rates are now available to users of SAGE Budget.

  • GIM 3 has been updated to display both current benefit rates and preliminary benefit rates for future budgeting as they become available.
  • SAGE Budget will use the correct rate based on the period start date and whether the user has opted to use current and preliminary rates or current-only rates.
  • Budget preparers can use a global update feature to update their budgets quickly when preliminary rates become available each year.
  • The period entry page for a given person will indicate whether the rate being used is current or preliminary for that period.

An ASTRA information page will display instead of an error message at sign in.

  • When you attempt to log in to SAGE without the required ASTRA role, SAGE will display a list of people in your unit who can authorize access to SAGE. You able to choose an authorizer and send him or her a message to request access to SAGE.

Designated Subcontract Actions (SA) attachments are viewable in SAGE.

  • Subcontracts Actions (SA) attachments will now be viewable in the Related Documents section of the Attached Documents page if the SA is in Active or Closed-Out status and if the type of attachment is not a To/From Communication.

EH&S has a new compliance question: “Will the project involve scientific diving?”

  • Anyone diving under the University of Washington’s auspices must have current certification as a University of Washington Scientific Diver and adhere to the standards set forth in the UW’s Diving Safety Manual. EH&S will contact you to assist in meeting Diving Safety Program requirements prior to diving.

May 2012 SAGE Maintenance Release

New Features

  • The Security and Export compliance questions have been revised, and a new one has been added concerning access to classified national security information. Answering “Yes” to the new question will generate a new Security Reviewer approver node on the approval graph.
  • The SAGE Budget export now contains data formatted to simplify data entry for the SF424 forms. You will find this information following the usual export data.
  • When adding an ad hoc approver or watcher, a new validation checks for any mismatch between the Role chosen and the level of the associated organization code.
  • When OSP marks an eGC1 as eligible for an Advance Budget Review, the eGC1 owners will automatically receive an email message.
  • When users look up personnel, the results will contain the employee identification number. This will allow users to quickly differentiate between personnel with similar names.
  • You may now delete an eGC1 sooner. You must have read/write access, it has been more than six months since the eGC1 has been completed, and the eGC1 is in Withdrawn or Returned status.

Fixes

  • If you create new budget and complete all of the steps until you reach the access page where you add and remove an admin/budget contact, you will see the full budget navigation instead of the wizard.
  • Hyphenated names now display properly.
  • Advance budget is marked as ineligible when a user copies an older eGC1.

January 2012 SAGE Maintenance Release

New Features in SAGE

  • The Advance Budget Form has updated instructions. We have created a new Advance Budget Job Aid which you can find on the My Advance Requests page.

Fixes

  • The SAGE Budget wizard can now handle F&A rates correctly for grants which go beyond the agreement dates.
  • On applications which use human subjects and stem cells, you cannot leave comments without choosing a Type on the Compliance Explanations page.
  • SAGE will only copy valid 4th level org codes. Incorrect and expired org codes will be removed from copied eGC1s.
  • In Grant Runner, the PHS398 cover letter Update and View links will now display correctly.
  • You will not be able to select or copy inactive sponsors on your eGC1, and SAGE will remove inactive sponsors from copied eGC1s.
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