Authored by:
Alma Hurd
Senior Accountant
University of South Florida
Email: ahurd@health.usf.edu
My boss and I handle the post award financial and compliance aspects of this private grant from a "famous" foundation. I am not naming names as the grant is still very active. :) The PI is a post-doctoral fellow/scholar from a foreign nation and the co- investigator is a "local," one of our very own at the Institution. The research will be conducted in a foreign nation. The award period was for a year but the actual research start date was delayed to wait for the IRB approval since the grant involves human subjects. After almost three months the IRB approval was received. Thus a five-month extension of the grant performance date was in order.
The first expenditure activity on the first month of the grant, aside from payroll, is to hire consultants. The consultants were foreigners, so Export Control/vetting comes in. After Export Control provided the green light, the PO process was initiated. Due to other special requirements for a foreign national, as independent contractor, the PO set up was finally completed about three months later.
On the sixth month of the grant, the PI, co-PI and a student researcher initiated their travel authorizations for their upcoming research trip to the foreign country. An IRB review from the foreign nation will also be needed before the research can be done overseas. As we all know, a pre-payment is necessary before a review can start. Turn-around time for the review is six weeks after receipt of payment. Enter Export Control again for the necessary vetting. We ran into a snag as the foreign reviewing agency’s bank failed the Export Control vetting (I need not elaborate). We considered the option of paying the IRB fees through international check. We needed to find a solution without holding up the research efforts. We explored further with the help of our Central Purchasing Office and finally resolved it and additional paperwork need to be done.
The invoice for one of the foreign consultant and the IRB fee was received. An international check was mailed and the payee received the check four weeks later, only to find out the payee’s bank does not cash international checks. We gathered that mailing a check to that foreign country is not feasible due to their not so reliable postal system and some odd banking policies. A check cancellation was initiated and payment was done via wire transfer to the consultant’s bank. This, too, took a while.
After the IRB fee was paid, we received information that the foreign reviewing agency will need the study monitoring fee and general research participants protection requirements paid prior to the agency initiating the IRB review. They refer to the monitoring and administrative fee as the "research levy." Normally, here in the U.S., we pay the monitoring fee after the IRB has been approved and the research have commenced and sometimes after any other additional reviews. Meanwhile, four other foreign independent contractors for transcription and translation work in the three different provinces where the study will be conducted, will need to be vetted. Some special requirements for foreign national vendors will also need to apply. And we all know the process is quite lengthy.
It is now one year into the grant and five months into the end date. The PI, co-investigator and student researcher have yet to commence their foreign travel. The PI received new information from the foreign nation that the three travelers will need to be registered first with the country’s Foreign Research Council. The registration fee is quite pricey. It was determined that a Research Advance will be necessary for this but the process will only start two weeks prior to actual foreign travel.
The PI is now getting frustrated at this point. My boss and I have to then assume our "appeaser roles" to ease the PI’s frustration. I am sure the PI will accomplish the grant program requirements before the end date. I am also positive that together we can work all these things through. Just a little more push and patience will get us there. This was quite (and is still is, as of this writing) a challenging experience for the young PI, my boss, the Research Department and myself.
#insights#ProfessionalDevelopment