Office of Sponsored Programs
The Office of Sponsored Programs' mission is to conduct the centrally organized administrative, business, and financial functions related to grant and contract administration and to assist faculty, principal investigators, and their administrators in the identification of resources for and the management of individual sponsored projects consistent both with MIT's academic and research policies and with the stewardship requirements of and obligations to external sponsors.
Research Volume
For FY2003 the total volume of sponsored research performed on campus was $471,755,000. This increase of $47,100 million represents an increase of 5.3 percent in total volume compared with the FY2002 volume of $447,888,000. The breakdown by sponsor is shown in the table below.
Campus Research Volume By Sponsor—1999–2003
(in thousands of dollars)
| 1999 | 2000 | 2001 | 2002* Original Source |
2002* Proximate Sponsor |
2003* Original Source |
2003* Proximate Sponsor |
|
| Federal | |||||||
| DHHS | 58,246 | 65,905 | 69,539 | 83,517 | 74,806 | 93,254 | 81,837 |
| DOE | 63,138 | 57,000 | 57,780 | 65,455 | 59,658 | 65,175 | 59,210 |
| DOD | 65,718 | 65,686 | 60,971 | 80,377 | 60,117 | 85,866 | 62,904 |
| NSF | 35,352 | 35,669 | 37,520 | 52,612 | 44,878 | 57,695 | 48,804 |
| NASA | 27,301 | 22,734 | 18,592 | 34,326 | 25,119 | 35,735 | 26,252 |
| Other | 7,409 | 6,753 | 6,777 | 12,143 | 11,562 | 13,172 | 12,452 |
| Subtotal | 257,164 | 253,747 | 251,179 | 328,430 | 276,140 | 350,897 | 291,459 |
| Non-Federal | |||||||
| Industry | 74,325 | 73,609 | 92,036 | 86,389 | 99,966 | 73,265 | 89,105 |
| Non-profit | 42,214 | 50,970 | 55,588 | 25,593 | 59,824 | 34,275 | 73,916 |
| Other | 2,344 | 5,662 | 8,620 | 7,476 | 11,958 | 13,318 | 17,275 |
| Subtotal | 118,883 | 130,241 | 156,244 | 119,458 | 171,748 | 120,858 | 180,296 |
| TOTAL | 376,047 | 383,988 | 407,423 | 447,888 | 447,888 | 471,755 | 471,755 |
*Beginning with FY2002, we are showing expenditures in two ways: from the original source (i.e., if funds were federal in origin but flowed down through another entity, such as industry or another university) to MIT; and from the entity which made the actual award to MIT (called the "proximate sponsor").
Compliance Issues
The most significant development over the past year has been the implementation of the Final Rules under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), known as the Standards for Privacy of Individual Identifiable Health Information. The Privacy Rule, as it is also known, is now in effect and impacts MIT research operations, as well as the Medical Department, where it involves the transfer of personal health information obtained from human subjects of research. OSP assisted the Committee on the Use of Humans as Experimental Subjects (COUHES), which has been designated to review requests for authorization for release, waivers or alteration of personal health information in research, and to restructure its web site providing guidance to researchers on the Privacy Rule as well as to complete the training requirements under the rule. This information is now coordinated with COUHES' guidance on informed consent.
In addition, the past year has seen the continued close scrutiny by federal agencies (particularly NIH) on the issue of compliance. New requirements have been implemented designed to protect humans as subjects, particularly requirements concerning the disclosure by investigators of certain financial information in human subjects informed consent forms. The government now also requires federal wide assurance (FWA) with respect to human subjects. MIT filed its FWA forms and received approval of its new assurance in May 2003 and is moving toward more detailed financial disclosures for both individual and institutional conflicts.
Costing Issues
The Institute addressed a variety of costing issues during the past fiscal year, ranging from audit issues, new MIT programmatic initiatives, and the negotiation of Facilities and Administrative (F&A) rates for future years. Items of particular interest are described below.
Negotiation of Facilities and Administrative and Employee Benefit Rates
MIT successfully completed negotiations with our cognizant federal agencies, DCAA and ONR, to establish Facilities and Administration (F&A) rates on a fixed with carryforward basis for FY2004 at 60.0 percent of modified total direct cost. The 2004 rate is significantly lower than the 2003 fixed rate of 63.0 percent.
Employee benefit (EB) rates have been established for fiscal years 2004 and 2005. Unlike F&A rates, MIT is experiencing a dramatic increase in EB rates due primarily to the impact of diminishing investment gains on our pension assets and the escalation of health insurance costs. EB rates for on-campus programs increased to 23 percent of salaries in 2004 compared to 18 percent in 2003 and will increase to 25 percent in 2005.
Other Costing Activities
In FY2003 MIT's federal cognizant agencies, DCAA and ONR, raised the issue of a separate F&A rate for Lincoln Laboratory. It has been MIT's longstanding practice to oppose the negotiation of separate F&A rates for specific programs, interdepartmental laboratories, or locations. In response to the government's position, the Cost Analysis staff prepared a comprehensive feasibility study that modeled the impact of separate F&A and EB rates for Lincoln Lab. This analysis provided compelling reasons to leave MIT's costing practices intact and effectively countered the government's argument for separate rates.
OSP played a major role in the evaluation and formation of the Broad Institute (BI). The Cost Analysis staff performed extensive modeling of the financial impact of the BI on MIT, developed costing strategies for incorporating the BI into MIT and successfully negotiated several BI-related issues with the federal cognizant agencies, DCAA and ONR. OSP's director played a key role in the formulation and negotiation of agreements with founding partners of the BI: the Broad Foundation, Harvard University, and the Whitehead Institute. OSP will continue to play a major role in the transition of the BI to MIT, effective November 1, 2003.
OSP has developed a draft policy governing the operation of service centers at MIT. Service centers are facilities within MIT that are established to provide goods and services to departments, laboratories, and centers and pass on the cost of the goods or services by charging rates, or user fees. Because service center charges are frequently made to federal grants and contracts, federal costing regulations play an important role in the operation of service centers. Furthermore, service centers represent a major use of Institute resources, and Institute policies and procedures governing the operation of these centers are necessary to ensure that these resources are used effectively and the centers are run in accordance with sound business practices.
Export Control Laws and Related Issues
Export control laws, federal laws implemented both by the Department of Commerce through its Export Administration Regulations (EAR) and the Department of State through its International Traffic in Arms Regulations (ITAR) have been in existence for more than 20 years. However, in the last two years the regulations have become more prominent and scrutiny concerning the level of compliance with these regulations has heightened. In the case of academic or research institutions, there is an exclusion from the regulations for fundamental research, the results of which are, are about to be or, in some cases, ordinarily are publicly available. When these conditions do not exist—and the technology itself or information about the technology is on one of the controlled lists administered by Commerce or State, then institutions are required to seek licenses to disseminate the technology outside the country or, as in many cases, to foreign nationals located within the US. OSP is the focal point for compliance with the regulations and is responsible for ensuring, to the maximum extent possible, that the Institute does not accept contract and grant awards with restrictions that would destroy the fundamental research exclusion.
As a result, OSP has continued to negotiate hundreds of awards annually that contain proposed clauses, the acceptance of which would have been against the Institute's policy. In all but a very few cases, the Institute has been successful in working cooperatively with sponsors to craft language that addresses agency concerns and, at the same time, is in compliance with these Institute policies. Over the last year or so, however, there has been a marked increase in the number of proposed awards that include language that MIT cannot accept. The majority of these clauses appear in awards with certain DoD and DoE installations, security agencies (NSA, NRO, etc.) and the FAA. Most of the restrictions address two specific areas: restrictions on dissemination of research results and restrictions on foreign nationals performing work under research awards. This is an extremely time consuming and delicate set of negotiations and is an ongoing challenge.
Internal OSP Initiatives
Client Orientation
OSP has continued the training program that it offers each semester to the Institute community. This program covers a range of general federal topics (policies and procedures, applicable circulars, F&A and EB costs) as well as a cradle-to-grave summary of how to manage a research award. We have added additional basic guidance on proposal preparation and review as well as post award sponsored program administration to the OSP web site. In addition, OSP has begun regular meetings with clients to supplement the sporadic visits and presentations made in the past. Implementation of the web-based human subjects training course with its automated recording in the Warehouse of persons who have successfully completed the training has expedited the processing of NIH research proposals. We have initiated a secure web-based financial conflict of interest reporting system that is the Institute's standard process effective July 1, 2003. In another area, the Cost Analysis Office has been working with the appropriate units to review the allocation account process and set annual allocation rates for each unit subject to review by ONR.
OSP continues to serve as the Institute point of contact for each new federal electronic proposal system as it is implemented. We investigate the new system, explain it to the MIT department, lab, and center (DLC) client users/proposers and see them through the process to ensure proposal accuracy and, thus, the highest likelihood of funding. In the past year, this has involved new electronic systems from NIH (e-SNAP), NASA, DoE, and DoD. Further, we continue to perfect our COEUS electronic proposal submission system that will provide a single face to our client DLCs while allowing submission to the multitude of federal sponsors.
Continued positive feedback from DLC clients reinforces the need to deliver services via a mechanism that provides a primary OSP contract administrator contact for each DLC client. Primary client contact is such an important concept in OSP that staff at all levels in our operational teams include some amount of primary contact responsibility in their assignments. Our commitment to strong backup from agency and functional specials and OSP teamwork are key to our success in making this method of service delivery work.
A working group of campus administrators will be formed early in FY2004 to finalize the draft service center policy (mentioned above) and to guide a campus-wide implementation of this policy. It is critical to get campus involvement in the process to ensure that the policy is reasonable and enforceable and to gain a "buy-in" from the affected parties.
Collaboration
Many of the training courses are being taught in collaboration with personnel from academic units. In other areas, OSP personnel have worked with academic units to use SAP in new ways to track and record research activities. In this past year, numerous staff members have continued their roles on the Provost Office's team for development and implementation of improvements to cost-sharing management. In support of these activities, we have held training classes and added additional guidance and training materials to the OSP web site. Personnel from academic units have served as reviewers and collaborators as the MIT electronic proposal initiative has reached roll-out stage. During FY2003 OSP has held a series of sessions to show academic administrators how the COEUS screens can be utilized for simple but sophisticated reporting. These sessions (originally scheduled to be held three times) have been offered more than a dozen times so far this year.
In addition, OSP staff members are now involved in the School of Science pilot of new cost-sharing planning and reporting procedures. Cooperation is ongoing with the provost and deans' offices to improve accounting tools and reporting of non-research activity. In addition, OSP and the Administrative Services Organization are involved in a pilot program of replacing of paper with email communication in routine award creation and processing.
Sustainability
One key element for MIT is the growth in volume of its research endeavors. The metrics above show how the research enterprise has grown this past year and its gradual growth over the past several years. OSP has developed, in conjunction with certain federal agencies, mechanisms for electronic receipt of awards (called TS 840s) and streamlined loading of the terms and conditions into COEUS. Along with this growth has come major financial and administrative compliance requirements and, primarily through the efforts of Cost Analysis, MIT has continued to integrate these requirements without disallowed costs or questioned systems.
Accountability
OSP is continuing participation in designing administrative processes that apply the MIT control environment, which sponsors and auditors expect, to new relationships and activities that require unique business approaches. For example, the move of the Research Subawards Office to OSP has been a step toward clarifying roles and responsibilities. Academic units no longer need to work both with OSP and with Procurement in the development and issuance of research subawards. The successful completion of audit reviews, F&A negotiations, and the establishment of rates underscores this.
In spring 2003, OSP released MIT's electronic Financial Conflict of Interest reporting and management system, which becomes the system of record for MIT as of July 1, 2003. This system permits faculty and other researchers to create records of companies and activities that meet the federal definitional requirements and update the information in a secure, simple-to-use, web-based environment.
The service center policy drafted in FY2003, and to be implemented in 2004, is a key element of MIT's program of compliance with federal regulations and will tighten controls over the use of MIT resources.
Professionalism
OSP personnel play an important role in professional associations including the Federal Demonstration Partnership (FDP), the National Council of University Research Administrators (NCURA), and the Council on Governmental Relations (COGR). In 2003 Julie Norris was elected as the Chair of the FDP Executive Committee and several other OSP staff, notably Patrick Fitzgerald and Steve Dowdy, play prominent roles in the FDP. Pat Fitzgerald is Vice President/President-Elect of NCURA.
OSP is a national leader in electronic research administration. We were the first institution to receive electronic awards in a standardized format from ONR, and we were the first to be able to submit NSF FastLane proposals in an EDI format (fall 2002). Participation at a senior level in policy initiatives of the federal government, authoring books and book chapters, serving on national panels, and on COGR, testify to the professionalism of the staff and their involvement in the important research administration issues being addressed across the country. OSP representatives continue to accept requests for meetings and presentations on our processes and tools. As one example, OSP is actively participating with the Boston Consortium in developing programs to cooperatively meet training needs throughout the Boston area.
More information about the Office of Sponsored Programs can be found on the web at http://web.mit.edu/org/o/osp/www/.