SPA Newsletter - Fall 2025

SPA NEWS

Fall 2025

Greetings from SPA/OSP/CGA!

In this edition of the SPA Newsletter, we extend our gratitude to Twila Reighley for her leadership of Sponsored Programs Administration (SPA), the Office of Sponsored Programs (OSP), and Contract and Grant Administration (CGA), and we offer our warmest congratulations on her retirement.

For nearly 14 years, Twila has been a driving force in advancing MSU's research enterprise. Her steady leadership guided our community through evolving sponsor requirements, major system implementations, and strengthened collaborations that support research excellence and compliance. Twila's commitment to open communication, training, and partnership has fostered engagement across campus and advanced continuous improvement in research administration.

The SPA Newsletter itself is one of the many initiatives Twila championed to improve communication and connection within the MSU research administration community. This issue, the first published since her retirement, stands as a reflection of her influence and the collaborative spirit she cultivated.

We wish Twila every happiness in retirement and know that her legacy will continue to shape and inspire research administration at MSU for years to come.

– SPA, OSP, and CGA Staff

Subaward Process in the Office of Sponsored Programs (Non-FDP Subawards)

The Office of Sponsored Programs (OSP) Subawards Team handles all non-FDP Subawards (non-standardized subawards). FDP subawards are issued by CGA Subawards Group in Contract and Grant Administration (CGA) Office.

The Federal Demonstration Partnership (FDP) is an association of federal agencies (e.g. NSF and NIH), research policy organizations and academic institutions that strive to standardize sponsored research processes and documents between participating organizations.

For a detailed list of funding agencies that participate in FDP, refer to the FDP website.

How OSP Subawards Team Receives Subaward Requests

When a subaward is included in the proposal for a project, the OSP Subawards Team will generally be notified of the need to complete the subaward at one of two times:

When the prime award is initially received by OSP for review and negotiation.
When the award is sent to CGA for account set up.

If your department is interested in adding a subaward to a project after the award has received an account number, or if an amendment to an existing subaward needs to be issued, the department needs to email the OSP Subawards Team with a request for a new subaward. (subawards@osp.msu.edu)

Documents Needed to Issue a Subaward

The following documents are needed to complete a subaward agreement:

Signed and completed Subrecipient Commitment Form.
Subaward statement of work.
Subaward budget and budget justification.
Most current audited financial statement.
Current copy of subrecipient's fringe benefits policy.
Current copy of subrecipient's Negotiated Indirect Cost Rate Agreement. (If unavailable, the subrecipient may request to use the de minimis rate – currently 15% Modified Total Direct Costs.)

OSP Subaward Preparation Process

Subaward and amendment requests are received in the OSP Subawards inbox and assigned to a reviewer → The reviewer checks the subaward documentation and works closely with the department regarding any questions, comments, and concerns → The reviewer passes the reviewed documents to a second team member for drafting and finalizing. The department administrator and PI should work with the subrecipient to obtain any information needed to issue a subaward/subaward amendment.

Timing of Subaward/Subaward Amendment Process

The OSP Subawards Team has a goal to draft each subaward agreement within 10 business days after receiving the final copies of the subaward documents from the department. Please note that the length of time it takes to finalize an agreement after it has been issued depends largely on how long it takes the subrecipient to respond and the complexity of language negotiations with MSU.

Once the OSP Subawards Team receives the partially executed subaward, they have it signed by an MSU authorized signer and return a fully executed copy to the subrecipient (cc'ing the department). A copy is sent to the CGA Subawards Team for post award management. Questions related to subaward invoices should be directed to the CGA Subawards Group.

Risk Assessment

Part of the MSU risk assessment (internal and not shared with the subrecipient) involves reviewing the subrecipient's current audited financial statements prepared by an independent Certified Public Accountant. OSP Subawards or CGA Subawards will evaluate and classify each subrecipient's risk level as elevated or low for internal purposes. Management of elevated risk subrecipients requires the subrecipient to provide a copy of all supporting documentation/receipts with every invoice prior to payment under cost reimbursable subawards.

MSU conducts a risk assessment prior to each subaward and amendment execution. Upon review of a pending payment, if a subrecipient's risk assessment is expired, CGA or OSP will contact the department to update financial information for the subrecipient.

Debarment

OSP/CGA will verify that a current debarment check is on file for each subrecipient prior to subaward or amendment execution as well as before a payment is approved.

UEI

When the grantor is federal, a Unique Entity Identifier (UEI) is required and can be acquired on SAM.gov. The department is responsible for working with the subrecipient to obtain a UEI prior to issuance of a federally funded subaward. Additional instructions on obtaining a UEI are available by contacting the OSP Subawards Team.

SUBAWARD AMENDMENTS

A formal request is required for all subaward amendments by submitting the Subaward Modification Request Form, to OSP Subawards. When filling out the modification form, please make sure to include the following information

Subaward number – this is located on the fully executed subaward agreement and in the Account Explorer Subaward tab.
Subrecipient name.
Modification amount – If the subaward modification is adding or reducing funding, then enter the amount by which the subaward needs to be increased/decreased.
Cumulative amount – Including the 'modification amount', enter the new total obligated to-date for the subaward.
Additional information – If you selected “other” in the “Type of Modification” line, explain what needs to be modified in the subaward agreement(s), e.g. change in the subrecipient's PI, necessary budget revision, etc. Please also include any additional information OSP should know.

The following documents may need to be submitted with the Subaward Modification Request Form:

Scope of work – for additional funding or scope of work changes.
Budget and budget justification – when adding funding or revising budget.
Updated audit – when the current audit is expired.

When a subaward amendment is requested, the OSP Subawards Team aims to have amendments drafted and to the subrecipient for review within 10 business days following the receipt of all documents necessary for that amendment.

If you have any further questions regarding non-FDP subawards, subaward amendments or the subrecipient monitoring process, do not hesitate to contact the OSP Subawards Team: Julia Miszkiewicz, Torri Falardeau, Aidan Blecke.

Charging Salary to NSF-Funded Projects

Properly charging salary costs to NSF-funded projects is critical for compliance and transparency. To be allowable, charges must be supported by documented effort that aligns with the project's objectives. Salary must be charged during the time period that work was performed. Charging salary without corresponding effort is unallowable.

Below is an overview of NSF's salary policies and important reminders for MSU faculty and staff working on NSF funded awards.

NSF's Two-Month Salary Policy at Proposal Stage:

NSF limits salary compensation for each senior/key person to no more than two months across all NSF-funded projects per year.

If more than two months of NSF and NSF flow-through salary support is anticipated during proposal submission, the excess salary must be disclosed in the proposal budget, explained in the budget justification, and be approved explicitly by NSF in the Award Notice.
NSF Salary After an Award is Received:

Once awarded, NSF allows certain budget changes, including salary over the two-month limit, without prior NSF approval, provided there is no change to the project's scope or objectives. (Chapter II: Proposal Preparation Instructions - Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 24-1) | NSF - National Science Foundation)

All salary charges must align with the work actually performed and be supported by effort documentation that complies with 2 CFR §200, Subpart E (including §200.430(i)). (eCFR :: 2 CFR 200.430 -- Compensation—personal services.)
Summer Salary Guidance:

Summer salary must only be charged to a sponsored project when the work is performed during the summer months.

Faculty must ensure that no vacation is taken during periods in which summer salary is charged to a sponsored award. Additionally, time spent on university activities unrelated to the sponsored project, such as administrative duties, proposal writing, or work on other projects, must not be included in the salary charges.

It is generally discouraged for 9-month faculty to charge 100% effort for all three summer months, as doing so leaves no room for activities not directly tied to the sponsored project. If there are any questions related to effort or effort certifications, please contact (effortreporting@cga.msu.ed).

Additional information can be found on our website: National Science Foundation (NSF) | MSU Sponsored Programs Administration.

Research Security and Disclosures at Proposal and JIT

The National Security Presidential Memorandum 33 (NSPM-33) requires that institutions receiving Federal support in excess of 50 million dollars establish and operate a research security program that addresses cybersecurity, foreign travel security, disclosure requirements, and research security and export control training.

In response to the requirements of NSPM-33 and the Chips and Science Act, many Federal agencies have mandated that covered individuals receive Research Security Training that describes best practices for mitigating risk. Additionally, many Federal sponsors now require that Covered Individuals and/or institutions certify at proposal and/or at JIT or RPPR that they are not participating in a Malign Foreign Talent Recruitment Program.

The Research Security Disclosures and Training by Sponsor table provides an “at-a-glance” view of these current compliance requirements checked by OSP prior to submission. Please note that sponsors are continually updating and adjusting these requirements. It is the PI's and research unit's responsibility to be aware of individual sponsor requirements, and the specific requirements of the solicitation.

To maintain the integrity and transparency of our research enterprise, and to comply with the mandates of our sponsors, please be aware that if investigators have not completed their required research security and or disclosure requirements at proposal and/or Just in Time, OSP will not be able to submit proposals or Just in Times until these requirements have been met.

OSP's Research Security Disclosures and Training by Sponsor webpage as well as the Office of Research and Innovation's Research Security webpage are both excellent resources to help faculty and staff stay current on emerging federal guidelines. As always, if you need assistance, please reach out to OSP.

2025 Quality FIRST Award Recipients

The Quality FIRST staff recognition program recognizes SPA/OSP/CGA team members who have served MSU in an exceptional manner by exemplifying our office values: Quality, Fairness, Integrity, Respect, Service, and Teamwork, i.e., "Quality FIRST”. The 2024 awardees were recognized during a staff event held in September.

Congratulations to Mel Steward (OSP Proposal Team 1) and Raeann Hagen-Davis (SPA Team), the winners of the 2025 Quality FIRST Awards! Mel and Raeann consistently demonstrate the values of quality, fairness, integrity, respect, service, and teamwork that form the core values of SPA/CGA/OSP and MSU as a whole. Thanks to the 2025 awardees for their outstanding service and valuable contributions to SPA/OSP/CGA and MSU's research community!

In addition to the Quality FIRST Awards, six Value Awards were presented to staff members who have shown excellence in a particular Quality FIRST core value. Congratulations to the 2025 Value Award winners:

Quality: Lisa Sather (CGA Awards Group)
Fairness: Hima Pasapula (SPA IT)
Integrity: Andrew Cascaddan (CGA Cash Management Group)
Respect: Mandy Johnston (CGA Awards Group)
Service: Amber Nichols (OSP Proposal Team 1)
Teamwork: Micky Zolnai (OSP Proposal Team 1)

The offices of Sponsored Programs Administration (SPA), Office of Sponsored Programs (OSP), and Contract and Grant Administration (CGA) are honored to recognize excellence and exemplary service through the Research Administrator (RA) Spotlight Award. We are happy to announce that Karen Hassankhani was selected as the Fall 2025 awardee. Congratulations Karen, and thank you for playing an integral role in advancing MSU's research mission! We appreciate your dedication and hard work.

Karen Hassankhani

Research Administrator II
Osteopathic Medical Specialties, College of Osteopathic Medicine

Karen has dedicated 46 years to Michigan State University, including the last 17 in Research Administration. In her current role, she specializes in international contracts and grants, providing comprehensive pre-award and post-award support to faculty in the Department of Osteopathic Medical Specialties. She also manages several research-related funding sources outside of traditional grant accounts, as well as the donor-funded Malawi Fund at MSU, which supports important initiatives in Malawi, Africa.

What do you enjoy most about your job here?

“I enjoy so many things about my job. Here are a few:

international contract and grant work is very rewarding, although it can be complex and challenging;
the opportunity to work with an outstanding group of faculty members and PIs;
training and mentoring colleagues in Malawi, Africa on both MSU and funding agency grant-related rules and best practices;
learning about, and appreciating, the different customs, culture, language, foods, and the natural beauty of Malawi.”

What advice do you have for new research administrators?

“OSP/SPA/CGA are great resources for information and assistance; don't hesitate to reach out to them. Networking with other Research Administrators at MSU is also very helpful since, many times, someone else has already figured out a solution to the problem you are working on.”

Certifications, Disclosures, and Trainings Needed for Account Setup

Per the MSU Faculty Handbook “Michigan State University is committed to maintaining the trust of the general public, which supports it and which it serves.” To aid in maintaining this trust and to meet changing federal agency requirements, MSU's Office of Sponsored Programs has written several guidelines to assist with meeting disclosure, certification, and training requirements described in further detail below. Any disclosures, certifications, or trainings required for your project, normally listed in the initial award email, must be completed before a project account number can be established.

Project-Based Conflict of Interest (COI) Disclosure

All MSU key personnel (including PIs) who are listed in the Institutional Proposal (IP) or added in an Award Revision must complete a project-based disclosure for each project prior to account setup. Project-Based COI Disclosures are necessary to ensure transparency, manage potential conflicts of interest, and meet regulatory and sponsor requirements. To complete the Project-Based COI Disclosure in Kuali Research, review the instructions found on the CDM website, and make sure to check the box to “Complete Project-Based Disclosure.”

Annual Conflict of Interest Disclosure

A “financial conflict of interest” exists when a faculty member's significant financial interests or other opportunities for tangible personal benefit may compromise, or reasonably appear to compromise, the independence of judgment with which the faculty member performs his/her responsibilities at the University. Investigators conducting MSU research must update their disclose within 30 days of acquiring a new significant financial interest or other opportunity for tangible personal benefit, or if there were no new disclosures, they must update their disclosure annually, to avoid potential conflicts of interest or to allow any conflicts to be managed as described in the Conflict of Interest and Conflict of Commitment Identification and Disclosure policy.

Several federal agencies, including the Public Health Service (PHS) agencies, the National Science Foundation (NSF), the Department of Energy (DOE), National Aeronautics and Space Administration (NASA), and the Department of Justice (DOJ) require annual COI disclosures. To complete an annual COI disclosure in Kuali Research, please review instructions found on the CDM website, and make sure to check the box to “Complete New/Annual Disclosure or Updating Existing Disclosure.”

Malign Foreign Talent Recruitment Program (MFTRP) Certification

To date all NSF, NASA, DOE, and some DOD projects, are prohibiting senior key personnel from participating in MFTRPs, as required by the CHIPS and Science Act of 2022. Participation in malign programs sponsored by a foreign country of concern (FCOC) could include one of several activities, such as receiving compensation, research funding, and several other types of remuneration or consideration better described on the MFTRP write-up found on MSU's Research Security website. The MFTRP certification, required to be completed before account set-up, is included in MSU's Annual Conflict of Interest Disclosure, completed in Kuali Research.

Financial Conflict of Interest (FCOI) Training

All Senior Key Personnel (including PIs) who are included in the Institutional Proposal (IP) or added in an Award Revision must complete CITI FCOI Training within the last 4 years for all U.S. Public Health Service (PHS) and Department of Energy direct and prime awards before an account can be set up. PHS includes CDC, NIH, FDA, and seven other HHS agencies. FCOI training is a federal regulation requirement for investigators, created to help participants understand their responsibilities in disclosing financial interests and for institutions to manage and report any identified COI to the funding agency.

To complete FCOI Training, log in to Ability and complete the CITI FCOI Training course by following the instructions on the Conflict Disclosures and Management website / Training page. Once training has been completed, the date will appear in the COI Disclosure Information table in Kuali Research.

Research Security Training

Several federal agencies (NIH, NSF, and the Department of Energy) have adopted new compliance requirements in recent months. To support research integrity and to comply with evolving federal requirements, MSU has established a comprehensive Research Security Program, which includes targeted training to help faculty, staff, and students understand and meet federal research security guidelines. The Research Security Training must be completed by senior key personnel. Please see the Research Security Training site for how to enroll and complete the training.

Importance of Completing Disclosures and Trainings

As indicated above, all applicable disclosures and trainings must be completed prior to setting up a project account number. If you have any questions, contact the Contract Team member working on your award, or visit the Resources for Faculty Disclosures webpage for additional information.

Coming Soon: Sponsored Programs - OSP CGA News Listserv Archive

We're excited to share that an online archive of messages sent via the Sponsored Programs - OSP CGA News listserv is coming soon! Once available, you’ll be able to easily access past announcements and updates directly from our website. The archive will be located under the “Resources and Training” dropdown menu at the top of the homepage. Two-factor authentication will be required for access.

Training, Education, & Resources

Essentials of Research Administration (ERA) Series

SPA/OSP/CGA, in collaboration with SPROUT and an extensive network of MSU staff involved in pre-award, post-award, and compliance aspects of research administration, provide a certified training series for research administrators and other support staff with responsibilities for research proposals, grants, contracts, and pre- and post-award administration at MSU.

D2L E-Learning: Sponsored Programs Administration offers four eLearning courses in D2L. To register for eLearning, please email Amy Bane (barteram@msu.edu) to be added to the course in D2L. All eLearning electives are worth 4 elective credits.

International Research I	eLearning in D2L
International Research II	eLearning in D2L
Contracts and Other Agreements	eLearning in D2L
Animal Care and Use Requirements	eLearning in D2L

2026 Schedule: We are offering our 4 Core Courses and 16 Electives in 2026, along with eLearning options. All courses are open to anyone with a valid MSU NetID. We are offering both long courses and short courses to better fit your busy schedule! Each session name below is hyperlinked directly to the corresponding registration page in Ability. All courses will be held on Zoom.

(NOTE: Please enable pop-ups from Ability in your browser settings in order to access the course registration pages.)

Course Title	Date	Elective Credits
Core 1: Principles of Pre-Award Research Administration, Part 1	13-Jan	N/A
Core 1: Principles of Pre-Award Research Administration, Part 1	20-Jan	N/A
Core 2: Principles of Pre-Award Research Administration, Part 2	27-Jan	N/A
Core 3: Principles of Post-Award Research Administration	3-Feb	N/A
Core 4: Compliance	10-Feb	N/A

Subawards (Short-course)	14-Apr	2
Effort Reporting and Cost Share (Short-course)	21-Apr	2
University Procurement and Logistics for Research Administrators	28-Apr	4
Intellectual Property	12-May	4
Post-Award Receivable Process and Financial Transactions	19-May	4
Audits	2-Jun	2
Proposal Development in KR	4-Aug	4
Beginner’s Hands-On Budgeting in KR	11-Aug	4
Reporting & Data Collection	1-Sep	4
Export Control	15-Sept	2
Departmental Post-Award Account Management	6-Oct	4
Fee-for-Service & Service Centers	13-Oct	4
Advanced Budgeting	10-Nov	4
NIH Agency Specifics	24-Nov	2
NSF Agency Specifics	1-Dec	2
Hot Topics	8-Dec	4

Client Feedback Surveys

At SPA/OSP/CGA, we strive to provide excellent customer service in all stages of research administration, from proposal development to the final closeout of an award. We continue to use client feedback surveys to solicit feedback on our proposal, award, and post-award processes. Ratings response details are available on the SPA Metrics section of our website (two-factor authentication required).

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Greetings from SPA/OSP/CGA!

Featured Articles

Subaward Process in the Office of Sponsored Programs (Non-FDP Subawards)

How OSP Subawards Team Receives Subaward Requests

Documents Needed to Issue a Subaward

OSP Subaward Preparation Process

Timing of Subaward/Subaward Amendment Process

Risk Assessment

Debarment

UEI

SUBAWARD AMENDMENTS

Charging Salary to NSF-Funded Projects

NSF's Two-Month Salary Policy at Proposal Stage:

NSF Salary After an Award is Received:

Summer Salary Guidance:

Research Security and Disclosures at Proposal and JIT

2025 Quality FIRST Award Recipients

Karen Hassankhani

Certifications, Disclosures, and Trainings Needed for Account Setup

Project-Based Conflict of Interest (COI) Disclosure

Annual Conflict of Interest Disclosure

Malign Foreign Talent Recruitment Program (MFTRP) Certification

Financial Conflict of Interest (FCOI) Training

Research Security Training

Importance of Completing Disclosures and Trainings

Coming Soon: Sponsored Programs - OSP CGA News Listserv Archive

Training, Education, & Resources

Essentials of Research Administration (ERA) Series

Client Feedback Surveys

Resources/Training

Site Management