Understanding the Federal Demonstration Partnership (FDP) & the Expanded Authorities: A Primer for Research & Sponsored Programs Staff

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Understanding the Federal Demonstration
Partnership (FDP) the Expanded Authorities A
Primer for Research Sponsored Programs Staff

• September 19, 2003
• Francine Massey, MPA
• Policy Planning Analyst

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Applicability of FDP Expanded Authorities

• OMB Circular A-110 Uniform Administrative
  Requirements for Grants Agreements with
  Institutions of Higher Education, Hospitals, and
  Other Non-profit Organizations applies to grants
  cooperative agreements (assistance mechanisms)
  made by Federal agencies to institutions of
  higher education, hospitals and other
  non-profits. Federal agencies have implemented
  A-110 in their own specific grant regulations in
  the CFR.
• It does NOT apply to contracts for procurement.
• FDP Terms Conditions replace many of the
  standard provisions of A-110, and, therefore,
  apply only to grants (some) cooperative
  agreements.

Only NIH, EPA AMRMC award cooperative
agreements under FDP or Expanded Authorities.
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Federal Demonstration Partnership History

• The FDP is a cooperative effort among federal
  research agencies, universities and the National
  Academy of Science's Government-University-Industr
  y Research Roundtable aimed at streamlining and
  improving the federal/university research support
  relationship and reducing administrative burden
  on Principal Investigators.
• It began with the Florida Demonstration Project
  (Phase 1) from 1985-1988.
• In 1988 it was expanded and renamed the Federal
  Demonstration Project II.
• In 1996, it was again expanded and renamed the
  Federal Demonstration Partnership Phase III.
• FDP Phase IV began in June 2002 with 90 member
  institutions and 10 participating Federal
  agencies.

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Federal Agencies that Participate in FDP IV

• National Science Foundation (NSF)
• National Institutes of Health (NIH)
• Office of Naval Research (ONR)
• Department of Energy (DOE)
• Department of Agriculture (USDA)
• Air Force Office of Scientific Research (AFOSR)
• Army Research Office (ARO)
• Army Medical Research and Material Command
  (AMRMC)
• National Aeronautics Space Administration
  (NASA)
• Environment Protection Agency (EPA)

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Federal Demonstration Partnership Purpose

• Gives grantee institutions unilateral authority
  to
• Incur pre-award costs 90 calendar days prior to
  award. All pre-award costs are incurred at the
  recipients risk.
• Initiate a one-time extension of the award
  expiration date of up to 12 months. The grantee
  must notify the Federal agency in writing with
  the supporting reasons and revised expiration
  date at least 10 days before the expiration date
  specified in the award! This one-time no cost
  extension may not be exercised merely for the
  purpose of using unobligated balances.
• Carry forward unobligated balances to subsequent
  funding periods.
• Rebudget funds across budget categories.

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FDP IV General Terms Conditions

• FDP IV General Terms Conditions are available
  at http//www.nsf.gov/pubs/fdp/fdpIV.pdf
• This document is dated October 2002 and shows the
  cross-walk between OMB Circular A-110 terms and
  FDP IV General Terms Conditions.

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Agency Specific FDP Terms

• Each participating Federal agency has its own
  Agency Specific FDP Terms Conditions. These
  terms vary from the General Terms Conditions.
• ALWAYS be familiar with the Agency Specific FDP
  Terms for the granting agency with which you are
  working!
• They may be found athttp//www.nsf.gov/home/gran
  ts/grants_fdp.htm

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Agency Specific FDP Terms

• (a) State which awards are covered by FDP terms
  and conditions. (If an agency wants to make a
  point of the fact that a particular class of
  awards is not covered, it should state these,
  too.)
• (b) State any additional prior approval
  requirements not included in the general TCs
• (c) State which categories of costs aside from
  those in A-21 are unallowable as direct charges
• (d) Provide contact information for technical
  matters (probably titles, not individuals)
• (e) Provide contact information for
  administrative matters (probably titles, not
  individuals).
• (f) Provide contact information for intellectual
  property (titles, not individuals).
• (g) State other agency-specific requirements,
  with reference to general requirements if
  possible.
• (h) State whether revised budgets must be
  submitted on agency forms
• (i) Specify format, content, and timing of
  technical reporting.
• (j) Specify form and timing of final financial
  reporting
• (k) State any additional documentation besides
  progress reports needed to trigger incremental
  funding.

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Agency Specific FDP Terms Conditions

• For example, NSFs Agency Specific FDP Terms
  impose prior approval requirements on 1)
  rebudgeting of funds from the trainee or
  participant support budget category and 2) any
  modification of the cost sharing amount listed on
  Line M of the awarded proposal budget.
• The AFOSR, ARO and ONR all require agency prior
  approval of a first no cost extension (NCE)!
  AFOSR requires that the request be submitted 30
  days prior to expiration of the grant, while ARO
  requires it at least 20 days prior to the
  expiration of the grant! However, AMRMC allows
  the grantee authority to do a one-time NCE. EPA
  allows one-time grantee approved NCEs, except on
  awards for which the funds are restricted to use
  during that year or if the NCE would push the
  project over 5 years.

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Agency Implementation of FDP Matrix

• A matrix showing the particular agency-specific
  implementations of FDP may be found
  athttp//www.nsf.gov/home/grants/grants_fdp.htm
  
• The document is under the header FDP Prior
  Approval and Other Requirements.

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Exceptions to the FDP Terms

• Each grant award may carry exceptions to the
  standard and agency-specific FDP terms and
  conditions.
• For example, you may receive an NIH award that
  says, This award is made under the terms of the
  FDP. However, carryover of an unobligated
  balance requires NIH prior approval.
• ALWAYS read the specific grant award notice to be
  certain what institutional authorities UW-Madison
  has for that award!

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Handy Tools in the FDP Operating Procedures

• Appendix A of the FDP Operating Procedures offers
  guidance on provisions that apply to subgrants
  made under FDP
• http//www.nsf.gov/pubs/fdp/fdpappa02.pdf
• Appendix B is a National Policy Requirements
  Matrix listing many of the policies that apply to
  FDP grants.

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FDPs Pioneering Success Resulted in the
Expanded Authorities

• The FDP demonstrations of streamlined agency
  terms and conditions were so successful that, in
  1993, OMB revised Circular A-110 and incorporated
  these expanded authorities into A-110 as the
  default terms for research grants.

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Expanded Authorities

• OMB Circular A-110 Section __.25(e) authorizes
  agencies to waive cost-related and administrative
  prior written approvals required by A-110 and
  A-21.
• This is known as the Expanded Authorities.

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Expanded Authorities

• The Expanded Authorities authorize grant
  recipients to
• Incur pre-award costs 90 calendar days prior to
  award. All pre-award costs are incurred at the
  recipients risk.
• Initiate a one-time extension of the award
  expiration date of up to 12 months. The grantee
  must notify the Federal agency in writing with
  the supporting reasons and revised expiration
  date at least 10 days before the expiration data
  specified in the award! This one-time no cost
  extension may not be exercised merely for the
  purpose of using unobligated balances.
• Carry forward unobligated balances to subsequent
  funding periods.

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Program Income Under Expanded Authorities

• For awards that support research, OMB A-110
  instructs that the additive method of accounting
  for program income shall apply automatically,
  unless the awarding agency indicates another
  alternative in the terms of the award.
• (_24.(b))program income earned during the
  project period shall be retained by the recipient
  andadded to funds committed to the project by
  the Federal awarding agency and recipient and
  used to further eligible project or program
  objectives.

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Expanded Budget Administrative Authorities for
Research Grants

• _25(e)(4) For awards that support research,
  unless the Federal awarding agency provides
  otherwise in the award or in the agencys
  regulations, the prior approval requirements
  described in paragraph (e) are automatically
  waived (i.e., recipients need not obtain such
  prior approvals) unless one of the conditions
  included in paragraph (e)(2) applies.
• This means that agencies have the option to issue
  research grant awards under Expanded Authorities,
  thereby waiving cost-related (rebudgeting) and
  administrative prior approvals required by A-110
  and A-21.
• In practice, individual Federal agencies have
  implemented some or all of the Expanded
  Authorities for research grants. For example,
  NIHs implementation of Expanded Authorities for
  research grants is identical to its
  implementation of the FDP terms and conditions.
  Always refer to the specific agencys regulations
  and to the particular grant award notice for
  clarification of institutional authorities.

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Know Understand Institutional Authorities

• Be sure you understand when UW-Madison has
  institutional authority to unilaterally take an
  action on a grant, such as issuing a first-time
  no cost extension.
• If you inadvertently send a request to the
  granting agency for that action, you have
  potentially forfeited the institutional
  authority. Once you ask the agency, it has the
  right to deny the request, and RSP cannot then
  invoke the institutional authority!

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Know Understand Institutional Authorities

• Remember that, during an institutionally granted
  first-time no cost extension period, the PI does
  not have to get agency prior approval in order to
  reduce his/her effort on the project.
• Once the original project period is over, the PI
  has met his/her promised effort commitment and
  may adjust effort during the no cost extension
  without getting approval.

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Notifying the Federal Agency

• When exercising a first-time no cost extension on
  a grant under FDP or Expanded Authorities, RSP
  must notify the Federal agency in writing with
  the supporting reasons and revised expiration
  date at least 10 days before the expiration date
  specified in the award!
• Requests for required agency prior approval must
  be submitted to the agency at least 30 days
  before the date of the proposed action! (NSF
  requires the request 45 days in advance for a 2nd
  no cost extension.)
• Requests for prior approval must be submitted to
  the agency by RSP and must be signed by an
  authorized institutional official. (All NSF
  notifications and requests must be submitted via
  FastLane.)

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Use the Correct Award Terms Order of Precedence

• Remember that agencies update their Agency
  Specific FDP Terms Conditions periodically. The
  terms in effect at the time the award was issued
  govern the award.
• Agency research grants are governed by the
  following in order of precedence the Federal
  statute authorizing the award, a special
  condition of the award, the agency-specific FDP
  Requirements, and the FDP General Terms
  Conditions