1.
Besides the Stimulus funding being tied to Economic Recovery – what is unique about this opportunity?
The Stimulus funding provides an unprecedented and unique opportunity for Penn State to participate in the American Recovery and Reinvestment Act (ARRA). However, it’s important to note that these monies will be awarded with their own terms and conditions separate from our existing federally funded portfolio. Specifically, the funding will require all recipients to quarterly document expenditures as well as the number of jobs created and the number of jobs retained.
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2.
What specifically is unique about the reporting requirements?
Not later than 10 days after the end of each calendar quarter, starting with the quarter ending September 30, 2009 and reporting by October 10, 2009, recipients must submit quarterly reports containing the following information:
a. The total amount of ARRA funds under this award;
b. The amount of ARRA funds received under this award that were obligated and expended to projects or activities;
c. The amount of unobligated award balances;
d. A detailed list of all projects or activities for which ARRA funds under this award were obligated and expended, including
The name of the project or activity;
A description of the project or activity;
An evaluation of the completion status of the project or activity;
An estimate of the number of jobs created and the number of jobs retained by the project or activity; and for infrastructure investments made by State and local governments, the purpose, total cost, and rationale of the agency for funding the infrastructure investment with funds made available under this Act, and the name of the person to contact at the agency if there are concerns with the infrastructure investment.
e. Detailed information on any sub-awards (sub-contracts or sub-grants) made by the grant recipient to include the data elements required to comply with the Federal Funding Accountability and Transparency Act of 2006 (Public Law 109-282). For any sub-award equal to or larger than $25,000, the following information: The name of the entity receiving the sub-award; The amount of the sub-award; The transaction type; The North American Industry Classification System code or Catalog of Federal Domestic Assistance (CFDA) number; Program source; An award title descriptive of the purpose of each funding action; The location of the entity receiving the award; The primary location of performance under the award, including the city, State, congressional district, and country; and a unique identifier of the entity receiving the award and of the parent entity of the recipient, should the entity be owned by another entity.
All sub-awards less than $25,000 or to individuals may be reported in the aggregate, as prescribed by HHS. Recipients must account for each ARRA award and sub-award (sub-grant and sub-contract) separately. Recipients will draw down ARRA funds on an award-specific basis. Pooling of ARRA award funds with other funds for drawdown or other purposes is not permitted.
Recipients must account for each ARRA award separately by referencing the assigned CFDA number for each award.
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3.
Will the unique reporting requirements be captured centrally or is this something that the investigators will have to capture?
Centralized systems are being modified to identify the Stimulus funding and to allow us to extract some elements of the required report. The process for reporting is currently under review and more information will be forthcoming. However, due to the uniqueness of the reporting requirements, we do anticipate that investigators and their departments may need to track items such as jobs created and jobs retained.
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4.
Will the stimulus funding be targeted toward all investigators or only those with existing federally funded portfolios?
This depends on the federal agency. The National Science Foundation will primarily utilize existing proposals submitted on or after October 1, 2008 to allocate significant portions of their funding. The National Institutes of Health will be providing supplemental funds to existing R01 awards but have also initiated some new competitive programs such as their RC1 Challenge. The National Endowment for the Arts is limiting their ARRA funding to institutions who have received NEA money in the last 4 years.
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5.
Do I need to do anything different when submitting a proposal targeted toward ARRA funding?
No, the same internal routing process that you are currently using should be utilized. We are asking that the titles of all ARRA proposed or funded projects include the prefix “ARRA:” on the Proposal Internal Approval Form (PIAF).
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6.
What F&A (indirect) rate should we be charging on the Stimulus funding?
Since the Stimulus funding will be received as a mutually exclusive award, the F&A rates should be the currently negotiated Penn State rates in place upon receipt of the award.
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7.
Do we have to submit detailed budgets for this money?
Yes, even proposal budgets previously submitted as an NIH modular grant are required to be resubmitted as a detailed budget.
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8.
Are there any costs that are unallowable specifically to the Stimulus funding?
Yes, the law specifically precludes the use of ARRA funding for casinos, aquariums, zoos, golf courses, and swimming pools. It’s important to remember that the Stimulus funding remains subject to the cost principles outlined in OMB circular A-21.
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9.
Can you escalate salaries and consumable costs as normally allowed?
Yes – you should follow the current institutional guidelines for developing federal budgets should be followed. However, keep in mind that program limitations such as those imposed by NIH’s modular grants ($250K per year) remain in effect.
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10.
Given the extra reporting requirements imposed by the ARRA funding, can I direct charge some administrative costs to assist with the reporting?
No, at this time an exception to the direct charging of administrative costs to assist with the reporting requirements has not been approved by Office of Management and Budget.
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11.
I was under the impression that the Stimulus funding needed to be expended within 2 years in order to have an economic impact but NSF talks of their Stimulus funding as being granted over a longer period of time? Can you clarify?
The National Science Foundation’s Stimulus funding amounts to a 50% increase in their total budget. In order to avoid having all of their existing awards and their Stimulus awards coming due at the same time, they have proposed to spread out their administrative costs by awarding their Stimulus funding over a period exceeding two years. Remain cognizant that if NSF elects to award over a period of multiple years, the quarterly detailed reporting requirements will most likely remain in effect.
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12.
Given the short duration of the funding combined with the fact that the monies are one-time, should I place new doctoral students on the ARRA funded projects?
Your academic unit will need to assist you in making the call as to whether or not Stimulus funding should be used to recruit new graduate students. There is the liability that the Stimulus funding will not fully fund a doctoral student and that another source of funding would need to be in place to complete the student’s degree program.
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13.
Some investigators have received warnings from the program officers that any non-financial compliance action (IRB or IACUC) needs to be approved prior to the receipt of the Stimulus funds. What is being done to ensure that the pending protocols will be processed in a timely manner?
The Office of Research Protections has scheduled additional IRB and IACUC meetings in the event the Stimulus workload mandates the additional meetings. All PSU service offices are sensitive to the need to timely process and expend the Stimulus funding. If you are submitting a new protocol, please alert the Office of Research Protections that the pending protocol is affiliated with Stimulus funding.
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14. Given that the Stimulus Funding is about economic recovery, we have been informed that the agencies will be intolerant of projects whose expenditure “burn-rate” is not in line with the budget. Does this mean that the agencies may elect to revoke funding if projects are not progressing?
Yes, the agencies have indicated that they will be monitoring all Stimulus funded projects to ensure that the funding is being expended in a timely manner. In the event that they are not, the agencies are reserving the right to revoke or reduce Stimulus funded projects.
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15.
Given the high profile of this funding and the need to quickly expend, do you anticipate the various OIG offices being proactive in their review and audit of these monies?
Yes, the Stimulus authorization bill includes monies for both the DHHS and NSF OIG offices to specifically audit Stimulus expenditures.
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16.
The Stimulus funding is subject to the Buy American requirement. What does this mean?
As the name implies, the Buy American Act (41 U.S.C. § 10a–10d) requires the purchase of goods produced by American based manufacturers and suppliers when utilizing federal funding. In certain circumstances, the requirement of the act may be waived if the purchase of domestic goods would burden the federal government with an unreasonable cost differential between the American based manufacturer and the foreign manufacturer.
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17.
When can we expect to actually receive our Stimulus awards?
PSU began receiving NIH ARRA awards in early May 2009. We expect to see more ARRA awards as other agencies begin distributing their ARRA funds.
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