Pre-proposal submission instructions determine whether binding commitments are required. While most pre-proposals are non-binding, any that include binding commitments should be reviewed by the RAS Contract Administrator.
The RCR training requirement applies to new proposals submitted, or due, on or after January 4, 2010, to conduct research, which excludes, for example, conference, symposium, workshop, or travel proposals.
Postdoctoral fellow appointments, as referred to in 5.3.3 of MIT Policies and Procedures, are not appropriate costs for organized research activities (research project WBS) of the Institute. The primary purpose of the postdoctoral fellow appointment is the development of the individual and not the advancement of a research project. See Policy reference below.
Non-federal awards in particular could mention the term Fellow in the context of recruiting postdoctoral level staff to work in their research programs. When we do have major agreements where the sponsor is supporting both an organized research program and a fellowship award program (two distinct purposes), RAS creates a research WBS for the organized research program and a fellowship WBS for the fellowship award program.
Please note, however, that where grants are made for the primary purpose of postdoctoral research training (e.g. NIH T32 training grants), consistent with A-21, the grant is established in an organized research account and postdoctoral fellow appointments are allowable charges to the research account.
Yes. With the designation of a discretionary source of back-up funding, the DLC may authorize the RAS to create a new WBS element in Pending Status (not billable to sponsor). Under such circumstances, the DLC assumes all of the financial risk associated with the possible failure of MIT to negotiate or receive an acceptable, fully executed award from the sponsor. The DLC must submit in writing the request for a cost objective in Pending Status; the request must be endorsed by an individual authorized to commit the source of back-up funding and by the DLC administering the pending WBS element.
No. As of 2013, the NSF has specified that only federally negotiated indirect cost rates are allowable on NSF awards. MIT does not have a federally negotiated F&A rate for non-research activities. However, federal regulations allow us to charge a de minimis F&A rate of 10% MTDC on non-research activity funded by Federal awards, provided we do so consistently. This is the rate that should be proposed and will be charged. DLCs are not required to fund underrecoveries of fund overhead associated with awards that receive the de minimis rate.
A: NSF response: Please see questions #10 and #14 in this NSF document: Frequently Asked Questions on Current and Pending Support PAPPG (NSF 20-1) These will address your questions. The text of the answers to questions 10 and 14 is included below.
Q: Mentoring of a trainee is an example of a time commitment that must be reported in current and pending support. There is a difference, however, between a time commitment and an activity that takes time. Should the latter be reported in current and pending support?
A: NSF response: An individual need not identify any mentoring activities in their current and pending support submission that take place as part of their regular appointment at the proposing organization. If an individual, however, receives in-kind support either directly or through their organization from an external source to support mentoring of undergraduate or graduate students, that in-kind support, including the time associated with such mentoring, should be identified in the individual’s current and pending support submission
Q: Do individuals serving as senior personnel need to disclose all postdoctoral fellows and graduate students who are individually funded through fellowships as in-kind support? For example, if a postdoctoral researcher is personally funded by a foundation, and the fellowship does not flow through the proposing organization, does this need to be disclosed as in-kind support?
A: NSF Response: The current and pending support information that must be provided is all planned, pending and current project and in-kind support that is either provided directly to the individual, or to the individual through their organization in support of that individual’s research endeavors. If the postdoctoral researcher is personally funded by a foundation or other organization, then the support of the postdoctoral researcher should not be submitted as part of the PI or co-PIs current and pending support submission.
Do investigators need to complete Financial Conflict of Interest training before a new award or change to an existing NIH award can be set up in Kuali Coeus and SAP?
Yes, the new CITI training on COI will need to be completed.
Additionally, at time of award, a new COI disclosure will be required as part of the annual COI disclosure, for yearly continuations, Renewals and New awards. The Significant Financial Interest (SFI) threshold has been lowered so will need to be done under the new regulations. For more information go to http://coi.mit.edu.
Do undergraduates, graduate students and postdoctoral researchers have to receive Responsible Conduct of Research training before being identified on a proposal to NSF?
No. It is not required that the training be completed at that time. The MIT plan for training requires that training be completed within 60 days of their salary being charged to the account. RAS strongly recommends that the training be completed within 30 days.
- Up to 66 percent of the MIT-provided tuition subsidy for Graduate Research Assistants
- Other expense categories
- Faculty academic year (AY) effort greater than 10 percent, Employee Benefits, F&A
Does the Responsible Conduct of Research requirement flow down to any subawardee identified on the project?
Yes. The RCR training requirement does flow down to all subawardees, at any tier. MIT must therefore ensure that these RCR requirements are appropriately met.