NRAPSC Updates

by Mitch Meyle, CGA

Non-Resident Alien Professional Service Contracts (NRAPSCs) have seen a recent change in the way they are processed at MSU. To comply with MSU’s procurement policies, NRAPSCs over $25,000 should now be processed as requisitions/purchase orders.

However, because the university threshold for competitive bidding ($25,000; https://upl.msu.edu/mbp/mbp-270/index.html#bidding) is higher than the federal threshold ($10,000), CGA prepared the following guidance to assist units with compliance on federal and state sponsored program (RC) accounts.

• For federal/state sponsored awards

1. NRAPSCs up to $10,000 – send the NRAPSC via email to CGA (audit.compliance@cga.msu.edu) for review and signature if allowable. Please note, if the total anticipated amount of the NRAPSC is budgeted for, or expected to be, over $10k for the project period, note 2 below would apply.
2. NRAPSCs of $10,001 or more - to be compliant with 2 CFR 200, a requisition should be processed.

• Foundation/Other sponsored awards

1. Up to $25,000 – send the NRAPSC via email to CGA (audit.compliance@cga.msu.edu) for review and signature if allowable. Please note, if the total anticipated amount of the NRAPSC is budgeted for, or expected to be, over $25k for the project period, note 2 below would apply.
2. $25,001 or more – to be compliant with Section 270.7 of MSU’s Manual of Business Procedures (Competitive Solicitation), a requisition should be processed.

As outlined above, in many cases you would now process a NRAPSC in KFS just as you have been for a domestic PSC. CGA will be on the approval route log when appropriate and will still review for allowability on the specific sponsored account(s). Once the NRAPSC is established on a purchase order (PO), CGA would not be on the route log for review of specific expenses. However, those expenses are still subject to a post-audit review, which CGA does on a regular basis. If there are any questions with a specific expense once the PO is established, please feel free to reach out to the Audit and Compliance Group (audit.compliance@cga.msu.edu) and they can review the situation. Please review the expense processing FAQs on CGAs website for additional information (https://osp.msu.edu/PL/Portal/1515/ExpenseProcessingFAQs).

Current and Pending/Other Support Webpage

by Amanda Blank, OSP

Non-domestic influence in federally funded research has become a hot topic over the last few years. In December of 2020, the Government Accountability Office issued a report urging the need for enhancing the policies related to influence. Included in the report were the five federal agencies that fund the most research at universities: the National Institutes of Health (NIH), National Science Foundation (NSF), Department of Defense (DoD), Department of Energy (DOE) and National Aeronautics and Space Administration (NASA).

In response, federal sponsors have updated their reporting requirements for personnel working on research projects. To assist faculty in navigating through all the new and updated sponsor requirements, SPA/OSP/CGA has created a Current and Pending/Other Support webpage, featuring the five agencies in the GAO report. Information you’ll find on this webpage includes:

• What needs to be reported;
• What does NOT need to be reported;
• When and how to report; and
• Links to sponsor resources such as FAQs, templates, and application guides

Do you have questions not addressed on this new webpage? If you have questions about completing Current and Pending or Other Support information at proposal or Just-in-Time stage, please contact your OSP Proposal Team; for questions on updating disclosures after award, please reach out to CGA Awards.

Audit Corner

by Evonne Pedawi, CGA

The purpose of this section is to keep campus updated on sponsored program audits at MSU, as well as national trends in audit activity. Audits are an important part of sponsored programs as they provide an opportunity for sponsors to verify that MSU is complying with the award terms and conditions. As the point of conduct for external sponsored program audits, CGA has been very busy in the last six months!

Due to the COVID pandemic, we experienced fewer external audits in 2020. We are currently seeing sponsors try to catch up on lost audit opportunities, scheduling many virtual site visits and expense monitoring audits since Spring of 2021. Although sponsors have conducted audits virtually in the past, those have typically been audits with a smaller scope, such as an invoice audit. In this post-pandemic environment, it is a new trend to conduct audits with a large scope virtually and both sponsors and MSU are learning in this process. We have found that it is important in these audits to schedule face to face virtual meetings often to address the auditor’s questions and develop relationships. In addition, these audits have tended to be more time consuming as they are a more detailed review with a larger audit sample given that they are drawn out over a larger period of time as opposed to a focused 3-5 day on-site visit. We anticipate the trend of virtual audits to become the standard process.

The federal government’s funding in response to the COVID crisis has been an audit target that we believe will continue. A large portion of MSU’s Single Audit will be dedicated to HEERF and CRF funding received by MSU, and documented policies and procedures will be tested. In addition, we have experienced an increased interest by sponsors in MSU’s procurement methods and billing rates. This is a good reminder that even if the expense you incurred benefitted the project, if it did not comply with a required process, such as competitive solicitation, the sponsor may produce an audit finding and require MSU to return funds.

Please make sure to retain all information and communication related to your sponsored program and decisions made on spending in the event that a project you are or were involved in is audited during the project or after closeout (during the record retention period) Any questions can be sent to me at pedawi@cga.msu.edu or to Kristy Smith at smith@cga.msu.edu.

Resource for RCR Training Requirements by Agency

by Erin Schlicher, SPA

Responsible Conduct of Research (RCR) training covers the core norms, principles, regulations, and rules governing the practice of research, and is intended to foster a climate of research integrity. It is required for investigators who receive funding from NIH, NSF, or USDA-NIFA, as well as for those conducting research involving animal or human subjects. Because the specific training requirements can vary by agency, SPA/OSP/CGA has developed an easy-to-use table listing requirements for NIH, NSF, and USDA-NIFA. The table includes responses to frequently asked questions, including:

• Who needs RCR Training?
• When should RCR training take place?
• What subjects must be included?
• How much training is required?
• How should RCR training be delivered?

Answers are shown side-by side for each of the three agencies, allowing for easy comparison. The table is provided as a resource for research administrators or investigators and can be printed to one page or bookmarked for easy reference.