Beginning in September 2023, a faculty or staff member who is planning to submit an application for external funding must first complete and submit a Pre-Approval request using ORCS’s new ORCS Pre-Approval Form. A PDF containing step-by-step instructions on how to do this can be found here.
Developed in collaboration with IT using BP Logix, the new ORCS Pre-Approval Form will replace the hard copy forms that were used for years, as well as the K2 web-based version that many found cumbersome.
The Pre-Approval Form is used to ensure that all relevant administrative leaders are aware of and approve of your intent to submit a proposal, and is required for all grants or contracts which the College will manage and administer, if awarded.
To ensure that ORCS has sufficient time to provide you with the best possible service, it is recommended that you complete the Pre-Approval Form as early as possible, or at least ten business days before the sponsor’s submission deadline.
The 5-Day Rule For Proposals
To effectively manage the review and submission process on behalf of our faculty, the Office of Research & Creative Scholarship will now be adhering to the following proposal submission policy:
A complete proposal, accompanied by the necessary department and school-level approvals –as well as any other attachments or approvals required by the sponsor or the College– must be received by the ORCS office at least five (5) full business days prior to the sponsor’s due date. The proposal components must be in close to final form with the exception of the narrative, which may be submitted in draft form subject to revision.
Proposals received after this date cannot be guaranteed approval and submission. If ORCS does not have sufficient time for a thorough review, the proposal will not be submitted. In cases of extenuating circumstances, a request for exception to this policy must be made to the Executive Director of ORCS. A proposal submitted to ORCS less than 1 business day prior to the sponsor’s due date will not be submitted, and there will be no exceptions granted for same-day submissions.
Thank you in advance for your collaboration on this new system. Should you have any questions or concerns, please do not hesitate to Eric Asetta, Executive Director of ORCS (eric_asetta@emerson.edu).
Every few years, Emerson College is required to negotiate the Facilities and Administrative (F&A) rates it uses in grants and contracts with the Federal Government. This month, Emerson received our new Rate Agreement from the Department of Health and Human Services for the period of July 1, 2023 through June 30, 2027, or until amended.
Effective immediately, the revised rates must be used for all federal sponsored project proposals with anticipated start dates of July 1, 2023 or later.
The new rates are as follows:
Indirect Costs/Overhead
From
To
Rate
Location
Applicable To
07/01/2023
06/30/2027
56%
On campus
All programs
07/01/2023
06/30/2027
26%
Off campus
All programs
07/01/2027
Until amended
56%
On campus
All programs
07/01/2027
Until amended
26%
Off campus
All programs
Fringe Benefit Rates
From
To
Rate
Applicable To
07/01/2023
06/30/2027
32%
Full-time employees
07/01/2023
06/30/2027
7.65%
Part-time employees
07/01/2027
Until amended
32%
Full-time employees
07/01/2027
Until amended
7.65%
Part-time employees
These rates will apply to all new or new-continuing contracts and grants awarded for funding on or after July 1, 2023. Existing contracts/grants may still use the old rates as originally awarded.
As a reminder, it is the policy of Emerson College to request indirect costs on proposals to non-federal sponsors, when permitted. Many foundations specify their own indirect cost rates, and it is the policy of the College to utilize these rates in its proposal budgets. When a non-federal sponsor is silent on F&A, a de minimis rate of 10% should be applied.
To learn more about F&A costs and how they are budgeted and recovered, please review the answers to Frequently Asked Questions (FAQs) below.
FAQs
What are Facilities and Administrative Costs? Also referred to as indirect costs, F&A costs are expenses incurred by an organization that cannot be identified readily and specifically with a particular sponsored project but contribute to the ability of the College to conduct sponsored projects. Expenses of maintaining and operating the College’s sponsored project infrastructure include costs related to buildings (labs, offices, training facilities, etc.), utilities (water, electricity, heating, air conditioning, etc.), maintenance (custodial and facilities services, etc.), equipment, libraries, general administration (purchasing, accounting, payroll, human resources, legal services, etc.), departmental administration (deans offices, academic departments, etc.), and sponsored project administration. These costs are considered F&A costs, and sponsoring agencies reimburse organizations for these expenses through an F&A rate.
To what budget items does the F&A rate apply? All rates are applied to a Modified Total Direct Costs (MTDC) base. The MTDC base includes all direct costs, excluding capital expenditures, equipment with a per-unit cost of $5,000 or more, charges for tuition remission, rental costs of off-campus facilities, scholarships, fellowships, participant support costs, and the portion of each subaward
Why does the College require project directors to budget for F&A costs? F&A costs are actual costs that are incurred by the College in administering a sponsored award. Because it is not practical for a project budget to allocate funding for all such costs, the Federal government utilizes a rate model to account for these expenses and to provide a fair and consistent method through which reimbursement can be made. The College requires that sponsored project budgets include F&A costs because facilities and administrative expenses are incurred for each sponsored project, and without funds to cover these costs, the College would not have an infrastructure that could support sponsored projects. It would be unfair to require students to cover these costs through tuition revenue, especially for projects that are not for their direct benefit.
How are the rates determined? The Federal government outlines specific procedures to be used in determining the rates and requires institutions to provide a proposal and financial data in accordance with these procedures. The government then uses a detailed review process to arrive at approved rates for each organization. The rates are not set by the College and cannot be amended without a new Federal rate agreement.
What does the College do with funds recovered through the F&A rate? Recovered F&A funds are used to help offset the College’s facilities and administrative expenses.
What if I want to apply to a funding program that limits or prohibits F&A costs? If a sponsoring agency limits or prohibits the recovery of F&A costs, the College currently accepts these restrictions and subsidizes the F&A costs provided that written documentation (i.e., policy statement or application guidelines) from the sponsoring agency is provided when the proposal is submitted for internal review.
What if I have a current sponsored project award that uses a lower rate? The revised rates apply only to new awards and do not impact existing awards. Effective immediately, project directors are required to use the new rates for all proposals submitted for internal review.
In June 2018, the Financial Accounting Standards Board (FASB) issued an Accounting Standards Update (ASU) that clarifies and revises how a non-profit organization may account for “contributions of cash and other assets received” from an external entity. It is meant to reduce “diversity in practice” and improve guidance as to whether a transfer of assets is a contribution or an exchange transaction.
Based on this guidance, the Office of the Controller at Emerson College has determined that certain awards that were previously classified as “grants” or “agreements” may now be classified as contributions, and accounted for as “conditional (or restricted) gifts”. The basis for this is the FASB’s contention that, unlike an exchange transaction (e.g. a fixed-price service contract), contributions are not contingent on a specified level of service, identified number of units of output, or a specific outcome. They nonetheless may still contain stipulations previously associated with grants, including:
A finite award period/period of performance
Narrative progress and final reports
Cost restrictions
The requirement to return any unspent funds at the end of the award period.
In contrast, an “unrestricted gift” does not include any such requirements.
While the College is modifying how it classifies and records the revenue from contributions, the change in classification does not negate whatever requirements a sponsor may include in an award’s terms and conditions. Accordingly, the Provost and Vice President for Academic Affairs has stipulated that restricted gifts shall continue to be managed by the College with the same oversight and accounting standards that were applied when they were deemed grants or contracts. Specifically, this means the following:
With the exception of contributions received by ArtsEmerson (which operates independently of the College’s academic departments), contributions that are identified as “restricted gifts” will still be managed in the same fashion as when they were labeled “grants.” The Office of Research and Creative Scholarship will continue to monitor expenses, advise on restrictions, and assist faculty with purchases, reimbursements, and compliance.
Unrestricted gifts will be the sole responsibility of the recipient and their department.
Consistent with the lifecycle process for funded faculty projects, ORCS will request a gift worktag (under the “Spendable – Former Grants” Workday hierarchy) for new awards, and facilitate the uploading of a spendable line item budget with the Budget Office.
All awards received from federal, state, or local governmental agencies, regardless of FASB guidance, will continue to be classified as “grants,” and managed accordingly.
For more information on this guidance, please contact ORCS at orcs@emerson.edu. Details on the FASB’s updated guidance may be found here.
The federal government is implementing a new “Unique Entity Identifier (UEI)” to replace the current DUNS number used to identify and validate federal contractors. This implementation will be effective April 4, 2022.
Although the implementation isn’t until April, many federal agencies (including the National Science Foundation) have begun the transition from the use of the DUNS number to the UEI, so you may be asked to include this number on your federal grant applications moving forward. As April gets closer, you will see more and more federal agencies replace the DUNS requirement with the UEI requirement.
Emerson’s UEI is JQMBE83BZHY6.
If you have any questions, please feel free to contact ORCS.
ORCS and the Office of Finance are currently developing a dedicated policy on how to pay human subject participants in IRB-approved research at Emerson College. In the interim, we have added new guidance on this topic to the Institutional Review Board’s home page, entitled Compensation for Human Subjects. The contents of this section is reproduced below.
As always, please feel free to contact ORCS should you have any questions.
Compensation for Human Subjects
A research protocol may offer compensation to human subjects for their participation. Researchers who are conducting sponsor funded research or internally funded research are responsible for ensuring that subjects are eligible to receive payments (in accordance with US Tax and Immigration laws) and for ensuring that the payment process is appropriate. The following section outlines how human subjects can be compensated.
Compensation and Consent Considerations
Payments or non-monetary rewards may be given to subjects as remuneration for time and inconvenience of participation in research studies, as well as an incentive to participate. Compensation can include monetary (gift cards, vouchers, etc.) and/or non-monetary (gifts/promotional items, etc.) remuneration.
There are two ways in which compensation can be problematic:
Undue influence: An offer of excessive or inappropriate compensation is made in order to obtain compliance.
Coercion: An overt or implicit threat of harm/negative consequences is intentionally presented by one person to another in order to obtain compliance.
Protocol and Consent Considerations: The protocol application should fully describe the plan for compensation of subjects as well as the reasoning behind the amount, method of payment, proration and scheduling of payment, and any other terms of compensation — for example, what happens if a subject withdraws his or her participation. All of this information should be included in the informed consent process. It is also appropriate to disclose possible compensation in recruiting and advertising materials.
Amount of Payments
Compensation should be appropriate for the time and effort subjects devote to participation. The level of payment should not be high enough to cause subjects to accept risks that they would not otherwise accept or participate in activities to which they would otherwise strongly object based on personal values or beliefs.
Some researchers may base the payment amount on the acceptable average wage in the location where the research is conducted or for the specific study population. This is often an acceptable level of payment that does not exert undue influence. When hourly payments are not suitable or feasible, compensation may be task- or procedure-specific (for example, some studies pay subjects per sample collection or survey).
Methods of Compensation
Emerson College facilities the payment of human subjects by researchers through the following methods (in order of institutional preference):
Payments to Participants via Online Survey Platforms. For protocols that solicit participant responses via a College-approved online survey platform –such as Qualtrics– a researcher may elect to have the platform pay Human Subjects directly for their participation. For more information on using Qualtrics through Emerson’s site license, click here.
Tangible Items/Gifts are non-cash items given to human subjects in recognition of their participation in a protocol. Examples include Examples include: books, trophies, plaques, event tickets, food, Emerson logo items, memento items, pens, pennants, or similar items. Gift items may be purchased via the Workday Marketplace, or submitted for reimbursement via an Expense Report (subject to the College’s purchasing and reimbursement policies).
Gift Cards are “cash equivalents” that can be used to purchase merchandise or which can be easily converted to cash.
Gift card payments are reportable as miscellaneous income to the IRS. It is strongly recommended that a researcher contact the Office of Research and Creative Scholarship for assistance with acquiring gift cards for human subject payments. Gift cards being held in reserve may be stored securely in a fireproof safe by the Office of Finance, upon request.
Prohibition on the Use of Personal Funds. Under no circumstances should researchers use their personal funds to compensate human subjects. These cannot be reimbursed under Emerson’s accounting rules.
Tracking Human Subject Payments
Researchers on an IRB-approved protocol must maintain a payment log for all payments made to human subject participants. Researchers must record the following information for each Payment to an individual:
Full legal name
Active phone number or email
Date, amount, and method of payment
For protocols that pledge confidentiality to participants, the researcher should use a coded identifier in place of an individual’s name, using the same identifier consistently for each participant. However, the researcher must also record sufficient information so that an individual can be contacted by Emerson for IRS-required information when the $600 threshold is reached.
Tax-Reporting Requirements and IRS Obligations of the College
The IRS treats monetary human subject payments (gift cards or gift certificates) as taxable income to the recipient. This means the recipient is supposed to report the payment when they file a personal tax return at the end of the year.
As the payer, Emerson must adhere to IRS regulations. The tax treatment of human subject payments depends on the amount paid, the recipient’s tax status, and whether the study takes place inside or outside the U.S.
If Emerson issues $600 or more in Human Subject Payments to an individual in a calendar year, the College is required to report the payments to the IRS and issue the recipient a Form 1099.
Pursuant to the above, Emerson must collect a completed and signed Form W 9 from an individual when they receive $600 or more in Human Subjects Payments in a calendar year. Participants should be notified of this requirement in the Informed Consent Form.
Payments to human subjects facilitated by a third-party data-collection platform, such as Qualtrics, are typically exempt from the above rule, but must still be logged by the researchers.
Further Guidance on Paying Human Subjects
For further information, policies and procedures on compensating human subjects, please contact the Executive Director for the Office of Research and Creative Scholarship. A dedicated policy to this topic, Payment of Human Subjects Participants in Research, is forthcoming from the College.
The National Science Foundation has issued a revised version of the NSF Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 22-1). The new PAPPG will be effective for proposals submitted or due on or after October 4, 2021. Significant changes include:
A new section covering requests for reasonable and accessibility accommodations regarding the proposal process or requests for accessibility accommodations to access NSF’s electronic systems, websites and other digital content;
Increasing the page limit for the biographical sketch from two to three pages;
Updates to the current and pending support section of NSF proposals to require that information on objectives and overlap with other projects is provided to help NSF and reviewers assess overlap/duplication;
Adding planning proposals and Career-Life Balance supplemental funding requests as new proposal types;
Updates to travel proposals will require that AORs certify that prior to the proposer’s participation in the meeting for which NSF travel support is being requested, the proposer will assure that the meeting organizer has a written policy or code-of-conduct addressing harassment.
NSF plans to conduct a webinar covering these changes. Visit the NSF policy outreach website to sign up for notifications about this and other outreach events.
While this version of the PAPPG becomes effective on October 4, 2021, in the interim, the guidelines contained in the current PAPPG (NSF 20-1) continue to apply.
If you have any questions regarding these changes, please contact the DIAS/Policy Office at policy@nsf.gov.
On May 27, 2021, Erik Muurisepp, Assistant Vice President of Campus Life, announced that Emerson College would “revise its regulations for those living, learning, and working on campus,” effective June 1. These changes reflect the growing state and local vaccination rates, lowering case numbers, and the most recent guidance from Tufts Medical Center, the Boston Public Health Commission, the Massachusetts Department of Public Health and the Centers for Disease Control and Prevention.
The new guidelines allow the return of non-Emersonian visitors to campus, subject to the continuation of certain safety measures. With this change, Emerson is pleased to announce that researchers may resume conducting human subjects studies, on campus, with in-person participants. In order to ensure that sufficient protections are in place for both researchers and subjects, the co-chairs of the Emerson Institutional Review board have approved the following procedures for doing so. These procedures will be in effect until further notice:
Submission of the On-Campus Human Subjects Research—COVID Safety Protocols And Attestation form. This form must be completed and submitted to the IRB by the lead researcher, and returned to the researcher with an IRB approval stamp, before an in-person HS study may be conducted. The form outlines both universally mandated safety measures, along with specific protocols based on the nature, duration, and contact frequency of the study.
Consistent adherence to the IRB-approved safety measures proposed by the lead researcher.
Offering a copy of the signed form to participants as informed consent on the safety measures.
Purchasing the necessary sanitization supplies and Personal Protective Equipment (PPE) needed for the studies.
Immediately notifying the IRB if any HS participant reports a positive test, of the onset of COVID-like symptoms, within seven (7) days of having participated in the study.
For all studies, participants will need to pre-register in iVisitor, and perform a symptom check one day before the study and the morning of the study. All researchers are still required to perform their own daily symptom checks, and must be tested once per week.
Once your on-campus request has been approved, you can procure sanitization supplies by ordering them through VEOCI. Requests for PPE—including gloves, masks, face shields, and lucite barriers—can be directed to Donna Brescia in Business Services.
Mellon Foundation to Fund Diversity Programs at Library of Congress The library will start an initiative, called “Of the People: Widening the Path,” which will encourage diversity among future librarians and archivists. The program is funded with a $15 million grant from the Andrew W. Mellon Foundation, part of a shift by the foundation toward issuing art and humanities grants through what it has called “a social justice lens.”
Arkansas Professor Is Accused of Hiding Chinese Funding The professor kept the financial arrangements secret, allowing him to secure other grants from American government agencies that the Chinese funding made him ineligible for.
First implemented in 2014, the Office of Management and Budget’s (OMB) “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” (2 CFR Chapters I, II, Part 200, et al), provides guidance to federal grantmaking agencies and applies to all federal awards received by Emerson College for research, scholarship, and other projects. The Uniform Guidance (UG) consolidated and replaced eight OMB Circulars such as the A-110 (Administrative requirements), A-21 (Cost principles), and A-133 (Audit requirements). Federal agencies (NIH, NSF, NEA, etc) have each developed their own agency-specific implementation plans for the Uniform Guidance.
What’s Changed
On November 12, 2020, OMB implemented its Final Guidance on amendments to the OMB Guidance for Grants and Agreements. Overall, these changes give agencies more flexibility in designing and monitoring programs, as well as encouraging the use of data collection and analysis to identify best practices.
Key Changes for Emerson and Principal Investigators (PI’s) on Federal Awards
“Must” Vs. “Should.” Section §200.101(b)(1) clarifies that when the word “must” is used it indicates a requirement. Whereas, use of the word “should” or “may” indicates a best practice or recommended approach, and permits some discretion.
SAM.Gov Registration. SAM.gov registration numbers will be replaced with the new Unique Entity Identifier (UEI), and current SAM registrants will receive a UEI automatically. The UEI transition timeline was recently be extended to April 2022. DUNS numbers will be phased out for new registrations. SAM will retain DUNS numbers for historical purposes.
Subaward Reporting. The reporting threshold for subawards, under the Federal Funding Accountability and Transparency Act (FFATA), has increased from $25,000 to $30,000.
Prohibition on Certain Telecommunications Equipment and Services. Federal funds may not be used to make purchases from Huawei Technologies Company or ZTE Corporation and their subsidiaries
Methods of Procurement. The micro-purchase threshold was raised from $3,500 to $10,000; the simplified acquisition threshold was raised from $150,000 to $250,000.
Domestic Preferences for Procurements. Grantees are encouraged to maximize the use of goods, products, and materials produced in the United States when procuring goods and services under Federal awards.
Monitoring and reporting program performance. Grant reporting requirements may become more stringent; granting agencies are required to more actively monitor progress on certain discretionary research awards.
Termination. Granting agencies are given more latitude in terminating an award when it is not meeting “program goals” or “agency priorities.”
Extended Closeout Dates. Final performance reports are now due 120 calendar days after the performance end date.
Publication and Printing Costs. The New guidance clarifies that any printing and publishing costs may only be charged to a federal grant if the award is in its final budget period.
