Sponsored Research and Activities

Policy number: 10.1

Policy section: Research

Revised Date: December 16, 2019

1. Definitions

Definitions of capitalized terms are set forth in Appendix A.

2. Policy Statement

Sponsored Projects must support the research, educational, and service mission of the University and the objectives of the University’s Principal Investigators/Project Directors.

3. Purpose

  1. The purpose of this policy is to establish the obligations of faculty members, other University employees, and administrative units in initiating, operating, and administering Sponsored Projects within the institutional framework of the University. Sponsored Projects must be conducted within the framework of a regular college, school, department, center, institute, or division of the University, or through the cooperation of several colleges, schools, departments, centers, institutes, or divisions.
  2. The University expects faculty members to engage in research, scholarship, and creative efforts guided by three general objectives: (a) the advancement, dissemination, and preservation of knowledge through teaching, research, and scholarship at the undergraduate, graduate, and postdoctoral levels; (b) the protection and advancement of the University's welfare and interests; and (c) the advancement and protection of the public interest and public welfare.
  3. In addition to complying with the requirements of this policy, faculty members and other University employees conducting and administering Sponsored Projects are directed to other University Policies on faculty classifications, appointments, and eligibility to conduct research, and on specific aspects of research. University requirements and procedures for proposing, initiating, conducting, and administering research activities are provided in the Research Handbook.

4. Permitted External Funding

The University will accept external Funding for Sponsored Projects which are:

  1. consistent with the University's mission, supportive of its commitments to its students and the community, and consistent with its adherence to principles of academic freedom;
  2. consistent with the standards and objectives of the academic unit and within the competence of the Principal Investigator/Project Director; and
  3. compatible with the University’s facilities, financial resources, and administrative capacities.

5. Prohibited External Funding

The University will not accept a Sponsored Project:

  1. that endangers the University's nonprofit status and privileges;
  2. without the approval of the President of the University, that is designated as “classified” by an agency of the federal government; or
  3. that has value only to the Sponsor and not to the University.

6. Compliance with Law and Policy

Sponsored Projects will be conducted and administered in accordance with all University Policies, federal laws and regulations, other applicable governmental laws and regulations, and the conditions imposed by the Sponsor in the Award.

7. The Role of the Officer of Research and Graduate Studies

All Proposals and Awards for Sponsored Projects must be coordinated through, approved by, and administered by the Office of Research and Graduate Studies. Approval is required prior to initiation of a Proposal for external funding, and prior to acceptance of an Award to validate that the Sponsored Project and restrictions imposed on the University by the Award are consistent with University Policies and with the University’s mission, its capabilities and capacity, and its commitment to free and open inquiry. Procedures for obtaining University approval are detailed in the Research Handbook.

8. Ownership of Intellectual Property

The University asserts its ownership of intellectual property resulting from Sponsored Projects and will administer such intellectual property as defined and described in University Policy 10.16, Intellectual Property.

9. Faculty Responsibilities and Release Time

  1. A faculty member’s involvement in a Sponsored Project must not interfere with the faculty member’s obligations under University Policies governing faculty workload and responsibilities, nor may participation in a Sponsored Project affect the responsibilities of the faculty member with respect to classroom teaching, directing student research, counseling students, and other college, school, department, center, institutes or division responsibilities.
  2. Released time from teaching during the academic year may be allowed with the approval of the Dean of the faculty member’s college or school, who determines whether the released time from teaching must be compensated fully with Funding. When full compensation is required, it will be done at the rate of no more than one-eighth of the academic year salary of the faculty member for each three-credit-hour course released.
  3. Faculty members participating in Sponsored Projects are eligible for extra compensation as described in University Policy 10.2, Compensation from Sponsored Project Funding.

10. Responsibilities of the Principal Investigator/Project Director

  1. In proposing and conducting a Sponsored Project at the University, Principal Investigators/Project Directors agree to comply with University Policies, the terms of the Award, and administrative and governmental regulations including, but not limited to, regulations governing employment, employee relations, Effort monitoring and reporting, fiscal processes, purchasing, intellectual property, ethics, conflicts of interest, controlled substance abuse, procurement integrity, experimental use of research animals, use of human subjects in research, and environmental health and safety.
  2. Principal Investigators/Project Directors shall propose and conduct Sponsored Projects in ways consistent with the principles of academic freedom. Except to the extent required by applicable governmental laws and regulations or as approved by the President or the Provost of the University, the Principal Investigator/Project Director must retain the prerogative to publish the results of research.
  3. Prior to submitting a Proposal to a Sponsor, a Principal Investigator/Project Director is required to follow procedures outlined in the Research Handbook to:
    1. obtain University approval to initiate the Proposal process;
    2. prepare a Proposal that is consistent with University Policies, the terms of the Award, and administrative and governmental regulations; and
    3. complete and obtain University approval of a budget for the Sponsored Project that is compliant with University Policies, allowable as defined by Sponsor’s policies and guidelines, consistent with the proposed Statement of Work, adequate for the Sponsored Project period of performance, and that specifically shows University contributions to the Sponsored Project, whether in the form of direct or indirect expenses.
  4. Prior to initiation of work on a Sponsored Project, a Principal Investigator/Project Director is required to follow procedures and comply with requirements outlined in the Research Handbook to:
    1. ensure completion of all University training requirements by the Principal Investigator/Project Director and students, post-doctoral fellows, and research staff who will work on the Sponsored Project; and
    2. submit all conflict of interest and other disclosures required by the University.
  5. In the execution and completion of work on a Sponsored Project, a Principal Investigator/Project Director is required to follow procedures and comply with requirements outlined in the Research Handbook to:
    1. maintain and document the level of Effort described in the Award Statement of Work and budget. In the event changes are necessary, the Principal Investigator/Project Director must contact the Office of Research and Graduate Studies, which will coordinate obtaining necessary consents from the Sponsor; and
    2. prepare and submit technical reports and publications as specified in the Award. The University considers the failure to submit technical reports by the due date to be a violation of the Principal Investigator/Project Director's agreement with the University and a material breach of the Award.
  6. The University affords the Principal Investigator/Project Director the opportunity to request a waiver of the aforementioned responsibilities. Such a request for waiver must be in writing addressed to the President of the University who may approve or deny the request at his/her discretion or may delegate such decision to the Provost.

11. Oversight Responsibility of Schools, Departments, Centers, and Institutes

  1. In approving a Proposal for or the acceptance of a Sponsored Project, Department Chairs, and Center and Institute Directors are responsible for validating that the Sponsored Project is:
    1. consistent with University Policies and the standards and objectives of the department, center, or institute;
    2. within the competence of the Principal Investigator/Project Director; and
    3. compatible with and achievable as proposed with available facilities, financial and human resources, and administrative capacities.
  2. In approving a Proposal for or the acceptance of a Sponsored Project, School Deans and their Financial Business Managers are responsible for validating:
    1. the determinations made by Department Chairs, Center Directors, or Institute Directors as to consistency with the standards and objectives of the department and competence of the Principal Investigator/Project Director;
    2. the availability of financial and human resources, particularly matching funds and cost sharing facilities; and
    3. the consistency of the proposed Sponsored Project with University Policies, mission, commitments to its students and the community, and adherence to principles of academic freedom.
  3. During the execution and completion of a Sponsored Project, Department Chairs, Center Directors, Institute Directors, Deans, and Financial Business Managers are responsible for:
    1. monitoring changes in Sponsored Project personnel, Sponsored Project scope, and level of Effort specified by the Award;
    2. ensuring timely and accurate reporting of Effort;
    3. monitoring compliance with University Policies;
    4. supporting efforts by the Office of Research and Graduate Studies to ensure that technical reports are filed on time; and
    5. supporting efforts of the Office of Grant and Contract Accounting to ensure that Sponsored Project expenditures are allowable, accurately assigned, consistent with Award budget restrictions, and reported in a timely manner that is consistent with the Award, applicable regulations, and University Policies.

12. Responsibilities of the University

The University recognizes its obligations to Principal Investigator/Project Director and to the Sponsors and regulating and auditing agencies. To meet these obligations the University will:

  1. provide administrative assistance to aid faculty and staff in proposing and conducting approved Sponsored Projects;
  2. not unreasonably cancel or withdraw commitments for facilities, professional assistance, or an appropriate share of personnel time made in accepting Funding;
  3. maintain a staff to provide adequate administration and control over Awards, property, and expenditures of Awards. This staff will maintain adequate fiscal and property records and prepare and submit fiscal and administrative reports as required by the Award;
  4. not discriminate in its policies and administrative controls between its own funds and those obtained from a Sponsor. This includes maintenance of records and fiscal controls, purchasing procedures, provision of facilities and space, and property control;
  5. conform to the Award and University Policies and procedures in payment of salaries and benefits from external funds;
  6. comply with applicable federal and other government laws, regulations and policies, as well as guidelines and instructions in the Award. In the use of non-federal funds, the University will comply with the Award and University Policies so long as they are not in conflict with federal and other government regulations and policies. The University reserves its right to participate in sharing direct and indirect Sponsored Project costs (even when a Sponsor does not require such cost sharing);
  7. present major changes in Effort to a Sponsor for its review and approval. The Office of Research and Graduate Studies is the sole administrative office responsible for submitting requested changes on behalf of the University and the Principal Investigator/Project Director; and
  8. receive and process Principal Investigator/Project Director's complaints regarding the University's failure to meet the obligations specified in this section of this policy through the Associate Vice President for Research.

13. Sponsored Project Administration: The Research Policy Committee

The Research Policy Committee reviews and recommends University Policies relevant to the solicitation, acceptance, conduct, and administration of Sponsored Projects and advises the Associate Vice President for Research on the general supervision and implementation of such University Policies.

14. Sponsored Project Administration: The Office of Research and Graduate Studies

The Office of Research and Graduate Studies administers the University's Sponsored Projects and is responsible for the following functions:

  1. providing information about funding sources and funding opportunities;
  2. administering development of Proposals for Funding so that the Proposals, Proposal budgets, and related forms meet University and Sponsor requirements and guidelines;
  3. screening Proposal and Award budgets to ensure that direct costs are allowable;
  4. administering the internal approval process for Proposals and Award, authorizing University approval prior to formal submission, and processing the submission to the appropriate Sponsor;
  5. negotiating, and to the extent authorized by the Board of Trustees, accepting or executing Awards on behalf of the University;
  6. administering the Sponsored Project acceptance and initiation process;
  7. ensuring that the administrative obligations of a Grant or Contract are fulfilled; and
  8. keeping administrative files and appropriate records and statistics of Proposals and Awards.
  9. working with the PI to manage and facilitate the technology management process
  10. monitoring the Sponsored Project to ensure adherence to University Policies and Sponsor guidelines and requirements;
  11. monitoring the timely submission of required reports and deliverables;
  12. obtaining internal University and Sponsor approval of changes to the terms of the Award;
  13. obtaining special Sponsor approval for such matters including, but not limited to, consultants, overtime pay, international travel, and equipment acquisition above a specified value;
  14. conducting satisfactory negotiations at or near termination to prevent cost overruns and ensure collection of all legitimate claims for reimbursement to the University;
  15. maintaining official files (except accounting records and documentation for expenditures) of each Award until conclusion of the Sponsor audit or audit vulnerability period; and
  16. maintaining a description of current procedures and requirements in the Research Handbook for proposal, execution, oversight, and completion of Sponsored Projects.

15. Sponsored Project Administration: Accounting

  1. The Controller's Office, primarily through Budgets and Finance, serves the administration of Sponsored Projects by:
    1. screening Award budgets and Sponsored Project expenditures to ensure that costs are allowable and ensuring that expenditures are categorized by the proper account code;
    2. supervising budget control of all Sponsored Project expenditures consistent with approved budgets and applicable University Policies and guidelines and processing payroll, purchase requisitions, invoices and vouchers, time or Effort reports, cost sharing, cross charging, and facilities and administrative cost reimbursement and allocation;
    3. preparing budget estimates of forecasted income and expenses provided by the Principle Investigator/Project Director, for Sponsored Projects, and performing internal reconciliations of Sponsored Project income and expenses, as needed, and submitting a statement of expenses on each Sponsored Project to the Principal Investigator/Project Director no less frequently than monthly;
    4. establishing and maintaining fiscal records; submitting billings to Sponsors; and filing interim and final fiscal reports with Sponsors and governmental agencies;
    5. requesting, scheduling, coordinating, and responding to internal and external audits. External audits include the annual audit prescribed by government regulations (Audits of States, Local Governments, and Non-Profit Organizations pursuant to the Single Audit Act) and agency audits on an as-needed basis (e.g., for certain cost proposals and Sponsored Project close-outs). Internal audits may be requested through the Office of the President to assess independently the fitness, function, processes, and/or procedures of a department or activity;
    6. providing equipment and other property accountability and administration; and
    7. providing facilities and administrative cost studies and negotiating the facilities and administrative cost rate with the cognizant agency.
  2. Faculty members and other University employees are required to comply with procedures established by the Controller, including the Office of Grant and Contract Accounting, in order to ensure that the foregoing responsibilities are met.

Appendix A: Definitions

"Award" means a Grant, subgrant, Contract, subcontract or Cooperative Agreement that provides for Funding.

"Contract" means a legally enforceable agreement between the University and a Sponsor that provides Funding when a primary purpose is delivery to the Sponsor of property or services for the benefit of the Sponsor, in addition to the research, educational or service benefit to the University.

"Cooperative Agreement" means a legally enforceable agreement between the University and a Sponsor that provides Funding when substantial interaction between the Sponsor and the University is anticipated during the performance of the Sponsored Project.

“Effort” means the time spent on Sponsored Projects and all other activities for which an individual is compensated by the University. See University Policy 10.15, Sponsored Project Effort Reporting.

“Funding” means financial support for a Sponsored Project, including money, property, services, or anything of value in lieu of money.

"Grant" means a legally enforceable agreement between the University and a Sponsor that provides Funding when:

  1. the Sponsor has no expectation of delivery of a specific product or service other than a final written report;
  2. no substantial interaction between the Sponsor and the University during performance is anticipated; and
  3. the agreement contains general terms and conditions that stipulate a period of performance and minimal reporting requirements.

"Principal Investigator/Project Director” means the individual solely responsible for technical conduct of a Sponsored Project, technical contact with the Sponsor, expenditure of Sponsored Project Funding, and fulfillment of technical performance and reporting obligations under an Award. "Principal Investigator” (PI) includes an individual designated in an Award as "Project Director" (PD), when performing the functions of a Principal Investigator, or other individuals performing the functions of a Principal Investigator. For the period of the Award, the Principal Investigator/Project Director must be a full-time employee (staff, tenured or, tenure track faculty, Research Professor, Research Associate Professor, Research Assistant Professor, or, if approved by the Provost or his or her designee, a non-tenure track, non-tenure eligible faculty member) appointed pursuant to University Policy 2.3, Faculty Ranks, Academic Titles, and Voting Rights.

“Proposal” means the document submitted to a Sponsor requesting Funding for a Sponsored Project which includes, without limitation, (i) Financial Obligations, Regulatory Obligations, Reporting Obligations or Accounting Obligations, as described under “Sponsored Projects”, (ii) a Statement of Work and (iii) a budget.

"Research Policy Committee" means the committee charged with providing guidance on the content of the Research Handbook and University Policies governing research.

“Research Handbook” is a document maintained by the Office of Research and Graduate Studies specifying current procedures and requirements for the proposal, acceptance, execution, and oversight of Sponsored Projects.

"Sponsor” means any external entity that provides Funding to the University. Sponsors may be (i) governmental agencies (for example, federal, state or local governments or their administrative organizations); (ii) nonprofit organizations (for example, universities, nonprofit corporations, foundations or associations); (iii) for profit organizations (for example, corporations, partnerships, sole proprietorships and other business entities); or (iv) individuals.

"Sponsored Projects” means all projects, programs, research, training, public service and other activities that receive external Funding through Grants to the University or through Contracts or Cooperative Agreements between the University and a Sponsor, where one or more of the following obligations applies:

  1. Financial Obligation. The University is required to comply with conditions imposed when a Sponsor awards Funding for the performance of services or delivery of products described in a Statement of Work;
  2. Regulatory Obligation. The University is required to comply with Sponsor regulations.
  3. Reporting Obligation. The University is required to provide to the Sponsor technical performance reports or regulatory or administrative reports; or
  4. Accounting Obligation. The University is required to establish a separate accounting record of Sponsored Project expenditures to demonstrate allowability of costs, to maintain financial accountability, to make financial reports to the Sponsor, and to preserve appropriate records for audit.

“Statement of Work” means the component of a Proposal or an Award that describes the specific work to be undertaken and the products that will be produced by the Sponsored Project.

“University Policies” means, for the purpose of this policy, all University Policies included in the University Policy Manual and all other procedures, guidelines, and requirements of the Office of Research and Graduate Studies and the Office of Grant and Contract Accounting included in the Research Handbook, and the procedures, guidelines, and requirements of all University colleges, schools, departments, centers, institutes, and divisions.

Revised: December 16, 2019

Adopted: January 15, 2015

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