Q&A Follow Up November MRAM

Greetings Colleagues, 

The November 2022 MRAM materials are published for your review.  Q&A from our session are included here for reference and will be available with the other meeting materials shortly. Please note we will be sharing the UWFT Q&A from both MRAM & the special RAPN session collectively sometime next week. 

 

PAFC Hot Topic: Travel on Sponsored Awards

Q1: If a Fly America Act (FAA) carrier's flight to an international location is 35 hours and a non-FAA carrier's flight is 14.5 hours, is this a justification for purchase for a non-FAA ticket?
A1: The Fly America Act has several itinerary-specific exceptions when use of a non-U.S. flag carrier is permissible. Please see the U.S. General Services Administration website for specific details on the exceptions to the FAA.  Fly America Act | GSA

Q2: If a UW approved travel agency makes PAFC mistakes, is the UW department still responsible? How much PAFC faith should be placed in the travel agency?
A2: The PI is responsible for the achievement of the award objectives and compliance with the terms and conditions of the sponsor, including regulations concerning travel.
The Fly America Act contains several itinerary-specific exceptions for use of a U.S.-flag carrier. Additionally, use of a code share or an applicable Open Skies agreement may also allow for an exception. Thus, compliance for individual flights can only be determined with access to all available flight options and up to date information on Code Share and Open Skies agreements. As the PAFC team does not have this capacity, the best option is to work with a UW travel agent to ensure compliance. The UW Travel website has information on UW Travel agents.

Q3: 14-hour travel policy: When business class is purchased, economy class portion can be charged to federal grant and anything above goes in discretionary budget, yes?
A3: If the cost of a ticket exceeds the limit under the federal regulations, only the allowable portion of the ticket may be charged to the federal award. The excess cost could be charged to non-sponsored funds provided the cost is reimbursable under the University’s travel policies.

Q4: Purpose/justification of travel: Could you please suggest appropriate wording?
A4: Justification for travel on a sponsored award will depend on the nature of the award and the award’s objectives. The justification should tie the necessity of the travel to those objectives, such as “travel to X-location to conduct field work” or “attending the conference to disseminate research results in accordance with the award terms and conditions.”

The justification should be clearly written and simple; do not use jargon or technical language. Anyone should be able to read the justification at any point in time and understand how the travel benefited the award.

Q5: Are checked baggage fees allowed (so prevalent these days)?
A5: Under UW travel policies, fees charged by airlines, excluding overweight charges, are allowable up to the first two bags. Overweight charges/additional bags require UW business justification. Please see the UW Travel website for more information.

Q6: Regarding “benefit to the award”, is this something described (typically) in award notifications or grant applications? 
A6: The objectives of the award are typically described in the proposal. The PI, or a designee of the PI, is the individual best positioned to determine whether travel benefits the award objectives.

Q7: Can you recap the cancelation policy quickly again?
A7: The federal regulations allow for the purchase of refundable (unrestricted) airfare. You may purchase a non-refundable ticket and charge the cost to the award if the ticket is used. However, if a non-refundable ticket is purchased and the travel does not occur (the ticket is unused), the cost of the ticket is unallowable on the award.

 

NSF Update Highlights

Q1: For proposal changes, do we do it in Research.gov and not in FastLane?
A1: Yes. When a proposal is submitted in Research.gov, any proposal file updates/budget revisions are also submitted in Research.gov.

Q2: Is that Concept tool like a pre-application to NSF?
A2: Concept Outlines, Letters of Intent, and Preliminary Proposals have different purposes and requirements. The Types of Submission section of the PAPPG contains details about all 3 and about Full Proposals.

 

NIH: Data Management & Sharing Policy, FORMS-H

Q1: Will they be providing additional funds to do this? Or are PI's expected to cut the budget in other areas to comply?
A1: No, NIH is not providing additional funds. NIH has guidelines related to  planning and budgeting for data management and sharing that may be helpful.

Q2: Is the burden still on the department to pay for data storage and data sharing costs after the award ends?
A2: All allowable costs submitted in budget requests must be incurred during the performance period, even for scientific data and metadata preserved and shared beyond the award period. According to NIH, for instance, if a DMS plan proposes preserving and sharing scientific data for 10 years in an established repository with a deposition fee, the cost for the entire 10-year period must be paid before the end of the period of performance.

In addition to the NIH guidelines that detail budgeting for data management and sharing, the UW Libraries has several useful resources guides to consider, including Retaining, Sharing and Archiving Data that includes best practices that may help reduce costs for long term storage and archiving.

 

Certificates of Confidentiality and Data Sharing

Q: How is CoC similar or different from privacy laws in the EU that some of us have bumped up against?

A: The European Union’s General Data Protection  Regulation (EU GDPR) is Europe’s most impactful privacy law. Its scope is vastly different from the NIH Policy on Certificates of Confidentiality (CoC) which applies only to research records. However, both provide individuals with certain protections related to their personal information and have implications for individually identifiable information collected for research purposes.

The EU GDPR broadly applies to information relating to persons residing in the European Economic Area. EU GDPR limits when and how organizations worldwide can collect, store, use, or otherwise process personal data. It also provides individuals with certain rights related to their personal data, including the right to be informed, to make choices about personal data processing, to access personal data, and in some cases, to delete personal data, among other rights.

More information about the EU GDPR can be found on the UW Privacy Office website.

The CoC Policy applies to all research that collects identifiable sensitive information and is funded wholly or in part by the NIH. It can also apply to research not funded by the NIH in situations when a CoC has been requested and granted by the NIH. The policy prohibits disclosure of protected information, except in limited circumstances. It specifically prohibits disclosure in response to legal demands. For studies that will obtain informed consent, subjects must be told about the protections provided by the CoC, and any exceptions to those protections.

More information about CoCs can be found on the Human Subjects Division website.

 

UWFT Demo & Details - Grant Award to Close

Stay tuned, we expect a link to the Q&A from the special UWFT Grant Award to Close Q&A session within the week. We will share it out as soon as we have it. It will also be available from the  UWFT for the Research Community as well as the November MRAM materials

Watch the recorded demo from November's MRAM. 

Have questions for UWFT? email  UWFTask@uw.edu

Thank you,
MRAM

November Materials