Grants and Contracts Administration Technical Assistance Manual Office of Research and Sponsored Programs Stephen F. Austin State University Effective: February 2005 Revised: September 2008

TABLE OF CONTENTS

Introduction to Grants and Contracts Administration at SFA - Whom do I contact for help?

• Office of Research and Sponsored Programs (ORSP)
• Grant Assistance - College and Department Contacts

ORSP Essential Services - When must I involve ORSP?

• ORSP Essential Services
• Proposal Submission - The Proposal Clearance Form (PCF)
  • PCF (PDF)
  • PCF Instructions
• Binding Agreements (Contracts, subcontracts, subgrants, consulting agreements)
• Project Revisions (Amendments)
• Online Submissions
• Request to Establish an Account
  • REA Form for External Grants and Contracts (PDF)
• Grant and Contract Accounting
• Foundation and Gifts

PART I - External Funding

Introduction - What policies govern sponsored projects?

• Policies Overview
• Overview of ORSP Services
• TABLE: Which proposals must be processed through ORSP?
• ORSP Areas of Assistance and Responsibility
• Standard Information for Proposals
• Policies and Regulations Governing External Funding
  • University Policies
  • Federal Regulations
• Who is Responsible for Externally Funded Projects?
  • Role of the Principal Investigator (PI) or Project Director (PD)
  • Role of University Offices
  • Disposition of Supplies and Equipment
• Safety in Research
  • Protection of Human Subjects (IRB)
  • Biosafety
  • Animal Use and Care
  • Environmental Safety and Health/Radiation
• Definitions
  • Sponsored Projects
  • Gift or Grant?
  • What is CFDA?
  • What is Restricted Research?

Proposal Preparation - What do I need to consider?

• Preparation Overview
• Requests for Proposals, Applications, and Programs Announcements
• Award Types
• Budget Preparation
  • Direct Costs
    • Allowable Cost Guide for Federal Projects
  • Salaries and wages
  • Additional Compensation
  • Fringe benefits
  • Consultants
  • Equipment
  • Supplies and materials
  • Publication Costs
  • Travel
  • Subawards and Subcontracts
  • Other Direct Costs
  • Indirect Costs (AKA: IDC, Facilities & Administration, F&A, Overhead Costs)
  • On and Off-Campus IDC Rates
  • Matching and Cost Sharing Commitments
• Time and Effort Reporting
• Representations and Certification (Provisions and Assurances)
• Subawards and Subcontracts
• Contracts with Commercial Sponsors
• Proposal Deadlines
• Administrative Review and Approval of Proposals
• Proposal Writing Handbook
• Program Income and Other Credits
• Changes in Projects that Require Explicit Sponsor Approval
• Sponsorship Acknowledgement and Disclaimers
• Technical Reports and Other Deliverables
• Intellectual Property and Publications

Post-Award Administration - Responsibilities of the PI/PD

• Award Acceptance and Post-Award Administration
• Areas of Post-Award Grant Administration
• Establishing a Grant Account
• Budget Changes
• Supplemental Funds Request
• Change of Principal Investigator
• Leave of Absence
• I'm leaving. How do I take my grant with me?
• Effective Grant Management
• Audit Considerations
• Responsibilities of the PI/PD in the Conduct of a Grant or Contract
  • Project Management
  • Budget Management
  • Subrecipient Monitoring
  • Personnel Policies and Procedures
  • Cost Sharing and Matching
  • Time and Effort Reporting
  • Research Integrity - Misconduct in Research
  • Conflict of Interest in Sponsored Activities

Project Closing Procedures - What to do when it's all over

• Closing Procedures

PART II - Internal Funding

• Faculty Research Grants
• Minigrants
• Research Development Program
• University Research Council

Grants and Contracts Office at SFA - Whom do I contact for help?

Office of Research and Sponsored Programs (ORSP)
See also About Us

ORSP is the administrative center at Stephen F. Austin State University (SFA) that provides services related to:

• Grants, contracts, and gifts from external sources when the use of the funds is restricted. Restricted means that the purpose of the funds has been either proposed to a sponsor or required by a sponsor.; and
• Internal research-related funding (Faculty Research Grants, Minigrants, and the Research Development Program).

ORSP Essential Services - When must I involve ORSP?

ORSP provides a vital link between faculty and staff who develop proposals for submission and the submission process for restricted use grants, contracts, and gifts.

ORSP must be involved in the following key processes:

Grant Proposals - All grant proposals where SFA is the fiscal agent (regardless of source of funds) must be approved in advance of submission by the appropriate chair, dean, and vice-president, as well as the president. The Proposal Clearance Form (PCF). is used to route your proposal through the university for appropriate review and signatures.

1. The completed form should be submitted to ORSP for routing with:

• A final budget
• A final or "final draft" of the proposal
• Required departmental and college signatures

2. To ensure that all signatures can be obtained, please submit the PCF and related materials to ORSP at least three days before the submission deadline (see Proposal Deadlines).

No proposals shall be submitted without the signature of the President or his delegated authority. Only the President has the authority to make commitments for the University and its employees.

See the Instructions for the Proposal Clearance Form

See also Preaward and Forms

Binding Agreements - Before contracts, subcontracts, subgrants, consulting agreements, or cooperative agreements can be executed, they first must be:

• Reviewed by ORSP
• Reviewed by General Counsel (ORSP will route)
• Signed by the President (ORSP will route)

1. If the contract represents the entire proposal, a Proposal Clearance Form (PCF) also must be submitted to ORSP.
   The completed form should be submitted to ORSP for routing with:

• A final budget
• A final or "final draft" of the contract
• Required departmental signatures

2. To ensure that there is sufficient time for legal review and to obtain the President's signature, please submit the contract (and PCF as required) to ORSP at least two weeks before the start date of the contract.

No contracts or other agreements shall be executed without the signature of the President or his delegated authority. Only the President has the authority to make commitments for the University and its employees.

See also Contracts

Project Revisions (Amendments). ORSP must review any amendment that requires sponsor approval. If you are not sure if sponsor approval is required, contact ORSP.

The following revisions are required for federally funded projects and must be reviewed by ORSP before they are submitted to the sponsoring agency:

1. Amendments that significantly change a project's scope or timeline.
2. Budget amendments that change the award total or affect indirect costs or matching commitments.
3. Budget amendments for federal projects that exceed $100,000 and the cumulative amount of transfers among direct cost categories exceed 10% of the total budget as last approved.

PD/PIs must complete the project Revision Clearance Form and submit it to ORSP for signature.

Irrespective of whether prior approval is required for a budget change, ORSP must receive copies of any revised budgets so that they can be appropriately entered into the FRS system and coordinated with the Grants Accountant.
Budget Revision Request Form (for internal use) (sample completed form)

See also Recipients and Forms

Online Submissions. ORSP is the administrative unit at SFA that is approved to submit applications to government agencies using electronic or online applications (including Grants.gov, NSF Fastlane, e-Grants, the Texas Education Agency, and the Texas Higher Education Coordinating Board). All online submissions require prior approval of the President and require a Proposal Clearance Form. Some applications also may require thqat a signature page be submitted after completion of the online submission.

Contact ORSP as soon as possible if a grant is to be submitted electronically. This will help ensure that ORSP has access to the application in advance and the Principal Investigator (PI) or Project Director (PD) has registered with the sponsoring agency, if required.

Most federal projects are now submitted through Grants.gov. Individuals DO NOT register in this system for projects submitted by SFA; ORSP is already registered on behalf of SFA. On the other hand, Project Directors (PD) or Principal Investigators (PI) are required to register for the NSF FastLane system and for NIH grants. These require several levels of approval, so be sure to notify ORSP as soon as you begin proposal development using one of these online application systems.

Sometimes there are technical difficulties with Web applications, so please don't plan to have your application submitted electronically on the due date.

Request to Establish an Account. After receiving notice of award or receipt of funds, a REA Form for External Grants and Contracts must be submitted to ORSP for routing through the Controller's Office. A REA form also should be processed through ORSP for unrestricted awards or restricted cash gifts from private sources if they are to be used for research purposes. ORSP must have acopy of the award notice before the REA will be processed.

The routing process is as follows:

• REA is completed and signed by the PI/PD
• The PI/PD gives the REA to the chair for signature
• The chair gives the REA to the dean for signature
• The dean sends the form to ORSP
• ORSP reviews the form and routes it to the Controller's Office
• A copy of the completed form is returned to the PI/PD

The REA also serves as a vehicle for the PI/PD to acknowledge and accept responsibility for the programmatic managment of the grant or contract. The PI/PD receives a copy of the form once all signatures have been obtained and an account number has been assigned.

As soon as you receive a grant account number from the Controller's Office, you may begin expending funds according to the approved budget.

See also Grant Accounts and Forms

Grant and Contract Accounting

Each new grant or contract must have its own account and internal budget. (See above section for how to request an account.)

Externally funded, restricted use grant, contract, and gift account invoicing and reconciliation is managed by the Grant Accountant, Letitia Hamilton, in the Controller's Office. She is responsible for requesting payments from sponsors, reporting University matches based on information provided by the PI/PD, and preparing financial reports. In addition, the College of Forestry and Agriculture has accounting staff who assist in the invoicing process and work in coordination with the Controller's Office.

The Grant Accountant is NOT responsible for ensuring that expenditures are allowable, allocable, or reasonable. This is the direct responsibility of the PI or PD.

Resources for the PI/PD include: Allocable / Allowable Quick Guide, Federal OMB A-21 Allowable Costs

See also Grant Accounts, Allowable Costs, and Forms

Foundations and Gifts

For assistance with solicitation of philanthropic gifts from foundations and individuals, proposals to be submitted by the SFA Foundation, and general information on unrestricted gifts from foundations, individuals, and/or other private sources, contact University Development.

• Some foundations limit the number of applications that can be submitted from an institution.
• Some proposals are best submitted by the SFA Foundation rather than the University.
• All proposals to private entities (including foundations) submitted by the University require a Proposal Clearance Form (PCF).
• ORSP staff assist in the development of proposals submitted by the SFA Foundation, as well as by the University.

Tax-exempt Status

• The Stephen F. Austin State University Foundation, Inc. is an IRS 501(c)(3) organization.
• SFA is a state agency and therefore is a tax-exempt, non-profit institution; however, some funding agencies require 501(c)(3) status. In these instances, proposals are submitted by the SFA Foundation, as applicable.

See also Gifts vs Grants

Grant Assistance - College and Department Contacts

Some colleges or departments have staff that serve as development officers for the college, provide grant writing assistance, and/or help manage grant budgets. They are:

• College of Forestry and Agriculture – Christy Wood
• College of Sciences and Mathematics – Bea Clack
• Department of Human Services – Donna Wood
• Department of Biology – Angie Brazil

PART I - External Funding

Introduction - What policies govern sponsored projects?

Faculty and staff are encouraged to seek external funding for research and sponsored projects undertaken to further the mission of SFA in teaching, research and public service.

Sponsored projects enhance and expand the educational opportunities available to undergraduate and graduate students at the University, permit research, scholarly inquiry, and the development of new knowledge, and contribute to the academic achievement and stature of SFA.

The primary responsibility for the development of proposals rests with the Principal Investigator (PI) or Project Director (PD). All proposals are expected to be relevant to the interests and expertise of the PI/PD and consistent with the mission of SFA.

All grant and contract awards are made to the University; however, the PI/PD is responsible for the management, execution, and completion of the project, including submission of all required reports. When a PI/PD signs and submits a Request to Establish an Account (REA) they are accepting responsibility for the management of the award, while adhering to program, sponsor, and university guidelines, procedures, and policies.

See also Policies

Prevent grant fraud, waste, and abuse

Overview of ORSP Services
See also About Us and Services

SFA’s responsibility to the sponsoring agency is to ensure that the project is conducted and funds are administered and spent in accordance with the award, state and federal regulations and guidelines, and University policies and procedures. ORSP is the office established to facilitate these processes.

ORSP is a service department that:

• Offers pre-award services; information, assistance and technical support are provided to the PI/PD upon request.
  
• Maintains a database of sponsored activities and prepares reports for the University related to research awards.
  
• Offers post-award technical assistance to help the PI/PD comply with conditions of the grant or contract and applicable University, state, and/or federal rules and regulations.

What Proposals and Forms Must Be Processed Through ORSP?
See also Procedures and Gift vs Grant

If one or more of the following apply:	Process through:
	ORSP and Submit	Development
A specific program of work or research is proposed to, or required by, the sponsor.	Proposal Clearance Form Request to Establish Account
The sponsor requires an authorized institutional signature.	Proposal Clearance Form Request to Establish Account
The sponsor requires or expects one or more progress reports, a final report, financial reports, and/or formal accounting of how the funds were expended.	Proposal Clearance Form Request to Establish Account
There are intellectual property, confidentiality and/or publication conditions associated with the receipt of funds.	Proposal Clearance Form Request to Establish Account
If none of the above apply:	Process through:
	ORSP and Submit	Development
Cash gifts designated for any type of research	Request to Establish Account*
Unrestricted cash gifts
Donations of equipment and other non-cash items used in research
Not sure? Contact ORSP or call ext 6606
*To ensure that ORSP completes a Current Year Award Checklist to capture all research funds for reporting purposes (accurate reporting ensures the SFA receives maximum funding from the state for research development).

ORSP Areas of Assistance and Responsibility
See also Services and Staff

ORSP is a resource for assistance in developing ideas into grant proposals and contracts and for providing post-award technical assistance to help ensure a successful award outcome. ORSP functions include:

• Proposal Preparation
  • Identification of outside funding sources and insight into agencies’ interests, funding priorities, and funding record.
  • Proposal writing assistance and review.
  • Assistance in the preparation of proposal budgets.
  • Routing and overseeing the University clearance process (Proposal Clearance Forms - PCF) prior to submission in order to secure written approval for sponsored programs from appropriate Vice Presidents and from the President .
• Proposal Submission
  • Review of University commitments during and after the project period, including cost sharing and indirect cost recovery.
  • Coordinate online proposal submissions.
  • Completion of sponsor assurances and certifications, when required.
• Post-Award Technical Assistance
  • Enter award information into the ORSP database.
  • Process Request to Establish an Account (REA) and provide notice of award and other project-related documents to the grants accountant in the Controller’s Office.
  • Provide financial and contract advice and administration assistance during contract negotiations.
  • Conduct contract reviews in coordination with the University's General Counsel.
  • Read, review, and interpret terms and conditions of incoming awards.
  • Coordinate online report submissions.
• Data Collection and Reporting
  • Prepare annual reports of proposals, awards and expenditures.
  • Prepare and disseminate information to faculty, departments, and others, as requested.
  • Prepare and submit reports concerning state, federal, and privately funded support for research and sponsored projects.
• Technical Assistance
  • Conduct workshops to provide proposal writing tips and post-award assistance.
  • Obtain and interpret program guidelines and post-award requirements.
  • Assist in the completion of Time and Effort reports required of all faculty and staff who expend effort (paid or cost-shared) on state and federal grants and contracts.

Standard Information for Proposals

Policies and Regulations Governing External Funding
See also Policies

Research and sponsored project funds awarded to and administered by the University are to conform to University policies and guidelines and those of the sponsor. Projects where the University is a subawardee are subject to applicable policies of the sponsor providing the funding, as well as whatever other terms and conditions are specified by the prime awardee.

Federal Regulations
See also Federal Regulations

Prevent grant fraud, waste, and abuse

When a sponsor provides federal funding for a project, either directly or indirectly as pass-through funds, there are specific compliance requirements. The State of Texas has adopted these requirements. Be sure to check the award document and/or check with state funding entities for any specific additional requirements.

1. Statutory Requirements, which are created when laws are enacted. These requirements take precedence over all other policies and regulations related to sponsored projects.
   
2. Office of Management and Budget Circulars (OMB) for government-wide sponsored project management:

Federal Regulations - The University and the PI/PD, in accepting an award from a sponsoring agency, assume the responsibility for the financial, technical, and administrative aspects of the award. There are five principal sets of regulations that provide guidance in the financial and programmatic management of awards to universities from federal agencies.
The Office of Budget Management (OMB) circulars outline acceptance practices for institutions that accept government funds in the form of contracts and grants.
A-21	Principles for Determining Costs Applicable to Grants, Contracts, and Other Agreements with Educational Institutions (Note that A-21 applies to contracts and to subrecipients performing work under federal awards.) http://www.whitehouse.gov/omb/circulars/a021/a021.html
A-110	Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations (Note that federal contracts are subject to Federal Acquisition Regulations rather than A-110). http://www.whitehouse.gov/omb/circulars/a110/a110.html
A-133	Audits of States, Local Governments, and Non-Profit Organizations http://www.whitehouse.gov/omb/circulars/a133/a133.html
EDGAR	Administrative regulations for the U.S. Department of Education grants. http://www.ed.gov/policy/fund/reg/edgarReg/edlite-part75f.html
FAR	Federal Acquisition Regulations (FAR) are the primary regulations used by federal sponsors to govern contracts for supplies and services, including research services. FAR incorporates OMB Circular A-21 for the purpose of defining allowable costs. FAR is not applied to grants and cooperative agreements that are governed by OMB Circular A-110, agency grant regulations, or FDP terms and conditions. (Federal contracts typically incorporate all of the FAR clauses applicable to a given project.) http://www.arnet.gov/far/

State of Texas Uniform Grant Management Standards

Who is Responsible for Externally Funded Projects?
See also Responsibilities

Awards from external sources (grants, contracts, and cooperative agreements) are made to the University, not the principal investigator or project director who prepared the proposal.

Therefore, the President of SFA is the only individual who can commit the University to the terms of a sponsored agreement, indicated by his signature on a proposal or a contract.

• Role of the Principal Investigator (PI) or Project Director (PD)
  • Overall responsibility for the conduct of the project
  • Execution of the project according to the terms outlined in the agreement
  • Adherence to the budget as approved by the sponsoring entity
  • Adherence to regulatory or policy requirements (such as human or animal subjects in research)
  • Monitoring subgrants and subawards
  • Requests for “no cost extensions” (NCE) [These must be processed through ORSP]
  • Development and submission of technical and programmatic reports
  • Accurate reporting of paid and contributed effort (Time and Effort reporting)
  • Maintenance of records for the required time (usually three years after formal end of project)
  • Establish and maintain contact with the program officer
• Role of University Offices
  • Authority to accept funds from external sources and to agree to the terms outlined in the agreement (President)
  • Approval and acceptance of contracts, subgrants, and cooperative agreements (General Counsel and President)
  • Authority to modify budgets and contracts (General Counsel and President)
  • Financial monitoring, reporting, requests for reimbursements, and maintenance of financial records (Controller’s Office)
  • Administrative procedures (ORSP, Controller’s Office, Human Resources)
  • Audits (Internal Auditor, Controller’s Office)
• Disposition of Supplies and Equipment
  At the conclusion of a project:
  • Supplies and materials remain the property of the department and/or college that received the funding.
  • Inventoried equipment (of any value) remains the property of the University and usually stays in the department and/or college that received the funding, unless otherwise provided for in the award document or sponsor policies.
    
• Prevent grant fraud, waste, and abuse

Safety in Research
See also Research Safety, Select Agents, and Forms

Individuals proposing research projects which anticipate the use of carcinogenic or toxic compounds, animals, human subjects (including surveys), recombinant DNA, pathogens, or radioactive materials in research activities should contact the committee chairs listed below and/or ORSP for further information.

Protection of Human Subjects – Institutional Review Board (IRB) - The Institutional Review Board is responsible for reviewing and approving research involving the use of human subjects, including surveys. Principal Investigators proposing reseach using human subjects at any level should review related policies and are encouraged to submit the appropriate application early in the process. This includes research conducted by students.

Contact Chair: Dr. Michael Walker
Phone: 936.468.4402, irb@sfasu.edu

ORSP Contact: Angela Ford
Phone: 936.468.6606, aford@sfasu.edu

• US Department of Education's web site on protection of human subjects in research

Biosafety Committee - Research involving biohazards, such as novel recombinant DNA, blood-borne pathogens, and carcinogens (including select agents) requires protocol review in compliance with NIH guidelines prior to the submission of a proposal or the start of the research.

Contact Chair: Dr. Robert Stewart
Phone: 936.468.3601, rstewart@sfasu.edu

ORSP Contact: Dr. Carrie Brown
Phone: 936.468.6606, brownch@sfasu.edu

Animal Care and Use Committee - All projects involving the use of live animals must be reviewed by the Institutional Animal Care and Use Committee (IACUC) prior to the initiation of any research. Precautions are taken to protect the user as well as the particular animal species involved. Only properly trained personnel are allowed to handle and dispose of animals. Radioactive animals receive special handling according to federal, state, and campus guidelines on radiation safety; see the section which follows on radiation safety. The use of radioactive materials must be approved prior to submission to the IACUC. Please note that most federal agencies now require that protocols using animals be reviewed and approved by the IACUC prior to submission.

Contact Chair: Dr. Tim Cherry
Phone: 936.468.3705, tcherry@sfasu.edu

ORSP Contact: Dr. Carrie Brown
Phone: 936.468.6606, brownch@sfasu.edu

Environmental Safety and Health/Radiation Committee - The University Radiation Safety Officer is responsible for ensuring the effective use of safety measures relating to radioactive materials and radiation devices, consistent with the Radiation Control Program of the Texas Department of Health, the Texas Radiation Control Act, and the Federal Radiation Control for Health and Safety Act of 1968. This Radiation Safety Officer regulates the receipt, possession, use, transfer, or acquisition of any source of ionizing or non-ionizing radiation or radiation-producing device. Compliance is required regardless of the source of funds used to support the research.

Radioactive or Radiation Producing Materials or Equipment
Contact Officer: Dr. Bea Clack
Phone: 936.468.6908, bclack@sfasu.edu

Health and Safety Policy
Emergency Management Plan Policy
Contact Officer: Jeremy Higgins
Phone: 936.468.4514, higginsjk@sfasu.edu

Hazardous Materials; Chemical Removal
Contact Officer: Dr. Wayne Boring
Phone: 936.468.3606, wboring@sfasu.edu

Definitions

Sponsored Projects - A sponsored project is any externally funded research, scholarly activity, or public service that has a defined scope of work or set of objectives, which provide a basis for sponsor expectations.

Sponsored projects are supported by entities outside the University, have a defined scope or objective, and usually include reporting requirements. They result from proposals submitted by SFA and funded by an external organization, such as a federal, state, local, or foreign unit of government, a foundation, an association, or a commercial entity.

Sponsored projects such as grants, contracts, and cooperative agreements are solicited and/or accepted for purposes which are consistent with and enhance the teaching, research, and public service mission of SFA.

All proposals for support of sponsored activities must be submitted to the sponsor through ORSP. (See section on Proposal Submission)

See also Preaward

Sponsored project awards can be:

1. Grants – Grants are used when the principal purpose of the award is to accomplish a specified public purpose of support or stimulation of initiatives authorized by federal or state statute. Grants are also used by state agencies, local governments, foundations, associations, corporations, and other private entities. Grants differ from gifts in that they entail reporting requirements, and differ from contracts in that they do not typically involve specific deliverables. Grant terms and conditions usually are sponsor or program regulations that are referred to but not included in the grant document itself.
2. Cooperative agreements – Cooperative agreements have the same principal purpose as a grant but are chosen as the instrument of award when conduct of the work involves substantial participation by the federal sponsor.
3. Contracts – Contracts are used when the principal purpose is procurement, i.e., acquisition of property or services for the direct benefit of the sponsor. Contracts entail specific deliverables, and terms and conditions are incorporated directly into the contract document. Contract Issues.
4. Standard research agreements – The University has developed standard contracts and consulting agreements for commercial and other non-federal sponsors. Common contract templates (previewed by General Counsel). Additional contract information - Office of the General Counsel Web site.
5. Sponsor-originated agreements – When sponsors furnish agreements to be used instead of standard agreements they must be reviewed by ORSP and approved by the General Counsel. Where necessary, ORSP will negotiate with the sponsor to reach mutually satisfactory terms and conditions for conducting the work.
6. Subawards – Subawards are awarded by a pass-through entity using funds it received from a prime sponsor, rather than its own funds. Subawards are typically subject to the same terms and conditions of the prime award to the pass-through entity, plus any additional terms and conditions the pass-through entity feels it needs for the effective administration of the subaward.
7. Scholarships – Scholarships are payments to students to provide financial assistance during the period of their education and training. Scholarships may be managed in a number of ways. They are considered sponsored projects and are covered under sponsored project policies if they are:
   • Received as part of a sponsored project and awarded to eligible students selected by the sponsor, or
   • Received as part of a sponsored project when the sponsor imposes terms and conditions for which the University is responsible for compliance, irrespective of whether the sponsor or University selects the recipient.
   • Scholarship funds are classified appropriately in the accounting system (graduate, undergraduate) and awards are managed by Student Financial Aid.

Is it a Gift or a Grant?

Gifts are contributions made to the University for which the donor receives no direct benefit and provides the support with minimal requirements (no terms, conditions, or other obligations, no authorized signature required, no financial or programmatic reports required, and no intellectual property, confidentiality, or publication conditions).

Research gifts do not require specific deliverables but a Request to Establish an Account (REA) should be processed through ORSP to aid in accurate reporting of research funds.

Gift letters and checks should be forwarded to University Development for processing. Unrestricted gift funds are generally placed in “various donors” gift accounts.

Is it a gift or a grant?

What is CFDA?

CFDA is the acronym for the Catalog of Federal Domestic Assistance, a compendium of federally funded programs. It is noted for federally-funded projects on the Proposal Clearance Form (PCF) and is used for reporting purposes.

See the CFDA.

What is Restricted Research?

A project is classified as Restricted Research if:

1. The use of the funds is Restricted - Restricted funds are funds for which some external entity has restricted how the funds can be spent. When a federal agency provides a grant for a specific purpose, the grant would be considered a restricted fund. A contract from a private sector company would typically be a restricted fund. When a donor provides a gift for a specific purpose or for creation or addition to an endowment fund (the income from which is for a specific purpose), the funds expended would be considered restricted funds.
   
   
2. The purpose is primarily Research - Primary purpose will normally be demonstrated by the sponsor’s statement of purpose or other documented evidence, such as the statement of work and/or certification by the Principal Investigator (PI) or Project Director (PD), but may be demonstrated by more than half of the funds (equal to or greater than 50%) having been budgeted for research.

Research and Development (R&D) means all research activities, both basic and applied, and all development activities that are supported at universities, colleges, and other non-profit institutions. “Research” is defined as a systematic study directed toward fuller scientific knowledge or understanding of the subject studied. “Development” is the systematic use of knowledge and understanding gained from research directed toward the production of useful materials, devices, systems, or methods, including design and development of prototypes and processes. The term research also includes activities involving the training of individuals in research techniques where such activities utilize the same facilities as other research and development activities and where such activities are not included in the instruction function. (U.S. Office of Management and Budget, circular A-110, Appendix A, Subpart A.2.dd)

Note: Curriculum development projects may be considered "R&D" when the primary purpose of the project is developing and testing an instructional model through appropriate research methodologies, i.e., data collection, evaluation, dissemination, and publication.

R&D activities are properly classified as Sponsored R&D if the activity is funded (sponsored) by externally derived funds that are designated by the sponsor primarily for R&D purposes. External entities that can provide sponsored R&D funds via grants, gifts, and/or contracts (including “sponsored research agreements”) include federal, state, or local governmental agencies; private philanthropic organizations and foundations; for-profit businesses; and individuals.

• Examples of Sponsored R&D include:
  • awards to University faculty to support R&D activities;
  • external faculty "career awards" to support the R&D efforts of the faculty;
  • external funding to maintain facilities or equipment and/or operation of a center or facility that will be used for R&D;
  • external support for the writing of books, when the purpose of the writing is to publish R&D results;
  • activities involving the training of individuals in R&D techniques (commonly called R&D training) where such activities utilize the same facilities as other R&D activities and where such activities are not included in the Instruction function; and
  • the research portion of expenditures in the federal work-study program, in accordance with instructions for preparing the Annual Financial Report.
    
  From the Texas Higher Education Coordinating Board’s Standards and Accounting Methods (SAM) for Reporting Restricted Research Expenditures, July 2005.

Proposal Preparation – What do I need to consider?
See also Preaward

ORSP staff is available to assist in the development of proposals for external funding. Faculty and staff are encouraged to seek assistance early in the proposal development process. Because resources are limited, ORSP is unable to write grants in their entirety. Available services include:

• Review and analysis of proposal solicitations;
• Assistance in developing strategies and formats to address sponsor requirements;
• Review and editing of draft proposals;
• Budget preparation and justification;
• Research for project justification section; and
• Online proposal submission.

Requests for Proposals (RFPs), Applications (RFAs) and Program Announcements (PAs)

RFPs, RFAs, and PAs are solicited proposal packages that normally include representations and certifications to be completed and executed by the University and may include proposed contract terms and conditions. Most of these types of proposals have firm deadlines applicable to their receipt by the sponsor. A copy of the entire proposal solicitation instruction package should be forwarded to ORSP when it is received by the investigator or department, along with an indication of who intends to submit a proposal under the RFP, so that appropriate internal reviews and approvals may be accomplished before specified submission deadlines.

Award Types

There are two types of award based on how funds are provided by the sponsor:

• Fixed Price – a set amount is provided to perform the activity and is payable before, during, or after the project (common in contracts).
  
• Cost Reimbursement – reimbursements are requested based on actual expenditures (common in grants).

Budget Preparation
See also Budget Development

Because budget preparation is a critical component of grant applications and contracts, it is encouraged that you consult with ORSP staff.

It is important that the budget section of the proposal reflect, as accurately as possible, the funding needed to carry out the proposed project and the Principal Investigator (PI) or Project Director (PD) should neither overestimate the funds required nor underestimate budgetary needs. Either of these strategies may lead to proposal rejection. A budget that accurately details the funds necessary to carry out the technical statement of work strengthens the overall proposal and increases the likelihood of funding. (A carefully prepared budget can also identify weak areas in the proposal narrative and result in improvement of the technical proposal.)

ORSP staff are experienced in preparing budgets, and encourage investigators to contact them when they have a draft of the budget. ORSP can provide expertise in completing a budget request, calculating fringe benefit and indirect cost rates, documenting subcontracts/subrecipient agreements, consultants, indirect costs, and identifying matching funds and/or cost sharing resources. ORSP also completes sponsor assurances and certifications for the President's signature, when required by the sponsor.

Standard budget template (to help translate your award budget with internal accounting codes)

Direct Costs

The categories established for federal budgets are useful in the preparation of budgets for all types of proposals.

For federal projects, direct costs are those that can be directly attributed to the project (OMB Circular A-21). To be eligible as a direct cost, a cost must be allocable to the project, allowable under the cost principles, reasonable, and charged consistently. Categories of direct costs include:

• Salaries and wages
• Additional compensation
• Fringe benefits
• Consultants
• Equipment
• Supplies and materials
• Publication Costs
• Travel
• Subawards and Subcontracts
• Other Direct Costs

Allowable Cost Guide for federal projects (adapted from OMB A-21)
Allocable, Allowable Quick Guide

If you are uncertain or have any questions about what constitutes an allowable direct cost under your specific award, contact ORSP.

See also Direct Costs

Salaries and Wages

Salaries and wages should be listed by the amount of time to be spent by each person, including faculty, administration and student assistants, who will be working on the project. Time commitments are usually shown in terms of months and a percent of full-time effort (i.e., 9 months at 25% time). Budgets should show a breakdown between summer and regular academic year for faculty.

• Sponsored activities may not result in any employees receiving compensation at a rate in excess of their authorized base salary or rate of pay.
• For multi-year projects, the budget should take into consideration any possible salary increases.
• In many cases, administrative or clerical salaries are considered an indirect cost and cannot be included in direct costs. There are exceptions for major projects where direct charging of these salaries may be appropriate. Examples are found in Exhibit C, OMB Circular A-21. Contact ORSP for more information.

Additional Compensation

Faculty and Exempt (non-classified) Staff

Normally and preferably, faculty are paid a portion of their base salary with grant funds and are granted proportional release time from teaching and other duties.

If warranted and approved as outlined below, extra effort expended during the conduct of sponsored projects (and less frequently research) may be paid additional compensation up to an amount not to exceed 25% of their base salary for work performed in addition to teaching and other duties.

Specific terms for additional compensation of faculty and staff must be specifically outlined in the grant application or contract and approved by the sponsoring agency. For specific details, see Policy E-9 - Salary Supplements, Stipends and Additional Compensation.

The Director of ORSP approves requests for additional compensation after verifying that the request meets criteria coutline in Policy E-9.

Request for Additional Compensation Services
Request for Additional Compensation Payment

Example 1: Full-time faculty on a 9 month contract, base salary of $40,000

• May earn up to $10,000 (25%) in additional compensation during the nine month period
• May earn up to $4,445 a month (proportional base rate) for each summer month not on contract

Example 2: Full-time faculty on a 10.5 month contract, base salary of $46,673

• May earn up to $11,668 (25%) in additional compensation during the ten and one-half month period
• May earn up to $4,445 a month (proportional base rate) for each summer month not on contract

Example 3: Full-time faculty on a 12 month contract, base salary of $53,340

• May earn up to $13,335 (25%) in additional compensation during the twelve month period

Example 4: Half-time faculty receiving $5,000 during the academic year

• May earn up to $5,000 in additional compensation during the academic year

Classified (non-exempt) Staff - Effort expended during the conduct of research and other sponsored projects by classified staff is compensated in accordance with compensatory or overtime payment regulations and procedures. A Request for Additional Compensation form is not used for classified employees unless it is for casual, seasonal work that must be performed outside of their regular department. In general, this would not apply to classified staff paid with grant or contract funds.

See Policy E-9.

Fringe Benefits

Fringe benefits are a direct cost to a sponsored project, are clearly related to the salaries and wages to be paid, and are shown as a separate entry in the budget. The actual costs for fringe benefits are charged (billed) to the sponsored project at the time the costs are incurred; the amount charged is based on salary, selected benefit package, and other variables applicable to the individual employee. Current rates for unspecified personnel are:

• 26% of salaries and wages (faculty and staff)
• 2% of wages and 50% of health insurance (graduate students)
• 2% of wages (undergraduate students)

For specified personnel, rates are 16.23% of salaries and wages (see note below for non-TRS employees) plus the state paid portion of the selected health benefits plan (employee only, employee and spouse, or employee and family). Calculations for additional compnsation are 16.23% (see note below for non-TRS employees).

The breakdown is as follows:

Fringe Benefit Breakdown
Description of benefit	Regular Employee	Graduate Assistant *	Student Assistant *
Insurance coverage	100%	50% (optional)	0%
Employer social security matching	7.65%	0	0
Retirement matching	8.5% / 6.58% **	0	0
Unemployment compensation	1%	1%	1%
Worker's compensation	1%	1%	1%
*Enrolled in more than 6 hrs (F/S) or more than 3 hrs (summer). ** Non-TRS employees hired before 1996 receive 8.5%. All others receive 6.58%.

Use the ORSP Fringe Benefit Calculator
See monthly rates for health insurance

Consultants

Normally, consultants are paid a consulting fee plus travel expenses, if applicable. Some sponsors do not permit payments to consultants and some restrict or limit such payments and may require inclusion of travel costs in the contract fee. If in doubt as to the allowability of consultants or rates paid to consultants, refer to the sponsor's program guidelines and/or award documents, or contact ORSP for assistance.

Whenever possible, provide the following information in the proposal before it is submitted:

• identify the proposed consultant by name;
• indicate the number of days to be worked and the daily rate of pay; and
• a curriculum vitae.

In some instances, SFA employees may be used as consultants on a project and ONLY if the consultant is from a different department than the Principal Investigator or Project Director.
See Policy E-9.

See also Contracts

Capital Equipment

SFA defines capital equipment as a item with a cost of $5,000 or more, that is non-consumable, independently functional, not attached to a permanent structure, and with a useful life of more than one year. Most sponsors defer to the institution’s definition of capital equipment. In most cases, capital equipment must be specifically outlined in an approved budget. Capital equipment is the property of the University and must be inventoried.

Access the University's Department Property Management Manual

Expendable Equipment (Materials) and Supplies

These are items costing less than $5,000 and include such items as expendable laboratory supplies, teaching aids, computer software, and office supplies. A reasonable amount should be budgeted for these items.

NOTE: Federal grants generally do not allow the purchase of office furniture and other general purpose equipment unless they are specifically approved in the budget. In addition, some general office supplies are considered part of indirect costs and are not allowable without clear justificaiton.

Some items costing less than $5,000 are controlled items, are the property of the University, and must be inventoried. For more information, see the university’s Department Property Management Manual.

Publication Costs

Budget the anticipated cost of publishing the results of the research, keeping in mind that page charges may vary from journal to journal. Consider both page charges and reprint costs.

Travel

Official University business travel requires prior approval of the University and usually requires prior approval of the sponsor. Travel on grants must directly support project goals, which may include dissemination of results. Federal grants generally prohibit travel outside of the 48 contiguous United States.

If specifically approved in the project budget by the sponsor, travel to any foreign country other than Canada or Mexico requires advance written approval from the Chair of the SFA Board of Regents. The traveler must submit a travel request through the appropriate administrative channels to the President, who will forward the request to the Board Chair. To be considered for approval, foreign travel must be directly related to the University’s mission and must require a duty that cannot be performed without the travel.

See rates for domestic travel

For complete information regarding University travel policies and procedures, access the Travel Office Web site. Meal and lodging rates differ depending on whether the travel is in-state or out-of-state. Refer to Policy C-49, Travel for additional information.

Subawards and Subcontracts

Subawards are made by the University to other organizations that will perform a part of the scope of work for a project awarded by the sponsor to the University. Subawards may be subgrants, sub-cooperative agreements, or subcontracts, and are generally of the same type as the award to the University. Agreements to obtain goods or routine services are purchases and not subawards, and subject to all relevant University procurement policies.

Additional information on the distinction between subawards and procurement is found in OMB Circular A-133, Section 210.

The PI/PD should incorporate prospective subrecipient's work statements, budgets, administrative approvals, in the sponsor’s format if the sponsor so requires, with the University’s initial proposal to the potential sponsor. Failure to identify a subrecipient in a proposal may require sponsor approval or competitive selection before the subaward can be executed.

In some cases (for example, proposals submitted to the National science Foundation) partnering institutions that constitute subawards will be required to enter and submit their own information in an online applicaiton.

If your project involves expenses associated with a cooperative organization or a tiered agreement, those expenses should be included as a subcontract in the proposed budget. The total subcontract cost should appear as a line item in your proposal budget, and a separate budget breakdown for subcontract costs should follow the proposal budget. In addition to a detailed subcontract budget, a letter signed by the individual authorized to contractually commit the subcontracting organization should be included in the proposal. Subcontract costs should include the subcontracting organization's fringe benefit expenses.

$25,000 IDC limitation - Indirect costs (IDC) in a subcontract must be in compliance with the sponsoring agencies guidelines. Under federally sponsored research awards, the University only recovers the indirect costs on the first $25,000 of the subcontract at the university`s negotiated rate.

Subcontractors may recover indirect costs on the amount of the subcontract in excess of $25,000 at the organization's negotiated rate. If the subcontracting organization does not have a negotiated rate, no indirect for the organization should be included.

This limitation generally does not apply to training grants or other programs that require alternate IDC rate calculaitons. Be sure to carefully read the programs guidelines, and request assistance from ORSP, as needed.

See also Contracts

Other Direct Costs

Consider, as appropriate, costs for copying, long-distance telephone calls, postage, reference books and materials, tuition and required fees for participating students, equipment maintenance, and contracted services. Some of these costs are considered indirect costs, so the Principal Investigator (PI) or Project Director (PD) needs to justify the need for these items in relation to the project, and it is the PI's/PD's judgment that this is the best way to spend the funds.

Indirect Costs [AKA: IDC, Facilities & Administration (F&A), Overhead Costs]

The University expects external sponsors to pay the actual costs of conducting the sponsored project, both direct and indirect.

Indirect costs (IDC) are necessary because in addition to costs that are directly related to your project, the University incurs certain costs that indirectly relate to your project. According to OMB Circular A-21, Cost Principles for Education Institutions, these indirect costs include building space, utilities, and related University services (i.e., the Office of Research and Sponsored Programs, Payroll, Purchasing, university security, departmental clerical support, and custodial support). The recovery of these costs is essential because even if not recovered, these costs don’t go away but are paid for by tuition and other unrestricted sources.

In other words, they include all those things essential to support sponsored activity which cannot be broken down and directly charged to a specific grant or contract. Indirect cost rates are determined annually from actual cost records through a detailed cost accounting procedure and are audited and approved by the federal government. These costs are charged to sponsored project by application of the facilities and administrative cost rate.

IDC must be included using SFA’s federally-negotiated rates unless the sponsor has a written policy which deviates from these rates. All deviations are subject to SFA administrative approval in advance. Sponsor guidelines limiting facilities and administrative costs must be justified on the Proposal Clearance Form (PCF).

IDC is charged to sponsored projects, and the resulting revenue is placed in a campus account for distribution by campus administration based on Policy A-51, Indirect Cost Recovery, Distribution and Use . Any questions about the distribution of IDC recovery should be directed to Dr. Carrie Brown, Director of Research and Sponsored Programs.

1. SFA’s current negotiated indirect cost rate for federal research projects is 50% of salaries and wages (on-campus) and 18% of salaries and wages (off-campus). Use this rate for all federal projects unless otherwise specified by the sponsor in the program announcement.
   
2. The maximum indirect costs allowed by the sponsoring agency should be included in your budget.
   
3. Only the Director of ORSP or his/her disignee, in consultation with the President, is authorized to negotiate alternate IDC rates. The President of the University is the only person with the authority to waive indirect costs (this is the same as entering into a cost sharing agreement on behalf of the University for indirect costs).
   
4. Indirect costs in a subcontract must be in compliance with the sponsoring agencies guidelines. If IDC is based on total direct costs, the University recovers the indirect costs on the first $25,000 of the subcontract. Subcontractors may recover indirect costs on the amount of the subcontract in excess of $25,000 at the organization's negotiated rate. If the subcontracting organization does not have a negotiated rate, no indirect for the organization should be included.
   
5. Including indirect costs in a budget does not negatively affect the outcome of a review.

NOTE: Any under-recovery of the indirect cost due to grantor restrictions must either be treated as cost sharing on behalf of the University or supplied from other funds. All proposals submitted on behalf of the University must include indirect costs either as a request from the grantor or as cost sharing on behalf of the University, as allowed by the sponsor.

See also Indirect Costs

On and Off-Campus IDC Rates

Off-campus rates are generally used when the Principal Investigator (PI), Project Director (PD), or other research staff are actually conducting research away from the campus for a period of no less than one long semester or all three summer months. Costs which are incurred in the field generally qualify for the off-campus rate.

A proposed budget may include both on and off campus budget items. Prior to submitting your proposal, please contact ORSP for assistance.

Matching and Cost Sharing Commitments

If sponsor guidelines require cost sharing or matching funds (cash contribution or donation of in-kind services such as contributed time and effort by the PI/PD), they must be included in the budget and budget justification. Appropriate letters of commitment from third-party sources also must be provided.

Matching funds are normally defined as cash (e.g. a percentage of the cost of a piece of equipment), whereas cost sharing is usually in the form of contributed time and effort by the Principal Investigator, Project Director, other project or University faculty and staff, and/or community volunteers. However, these terms are frequently used interchangeably.

• Do not include cost sharing unless it is required.
• For federal projects - Only cost-share federal projects with non-federal funds and cost-share only federally-allowable costs.
• For all projects - Do not use the same funds to match more than one project.
• Matching commitments must be honored and are reported to the sponsoring agency. When a Proposal Clearance Form (PCF) is prepared, the PI/PD must specify whether the commitment is cash or in-kind and must designate an account name and number for reporting purposes.
• Matching commitments must be approved by the department chair, the college dean, the Provost and Vice President of Academic Affairs, and the President.
• All matching funds or cost sharing commitments based on the faculty member's academic time and effort must be approved in advance by the PI/PD’s department chair and dean on the Proposal Clearance Form (PCF).

If cost sharing is required, ORSP can provide suggestions as to sources of funds. Some sources of cost sharing are release time, graduate students, equipment use, and computer lab usage. Matching funds may be available for projects which significantly further the University's primary mission. The University can also coordinate matching fund solicitations and contributions on behalf of corporations or foundations if the project is funded.

Documentation for cost sharing should demonstrate that:

1. It is verifiable from the recipient's records.
2. It was incurred during the period of performance of the award.
3. It is not included as contributions for any other project or program.
4. It is necessary and reasonable for proper and efficient accomplishment of project or program objectives.
5. It is allowable under the applicable cost principles.
6. It was not paid by the federal government under another award, except where authorized by federal statute to be used for cost sharing or matching.
7. It was provided for in the approved budget when required by the federal awarding agency .
8. It was consistent with federal cost allocation principles.

Other requirements related to cost sharing include:

• Unrecovered facilities and administrative costs may be included as part of cost sharing or matching only with the prior approval of the federal awarding agency.
• Principal Investigator's or Project Director's effort, whether fully reimbursed or contributed, cannot be reduced by 25% or more without prior approval by the sponsor when the sponsor is federal.
• Cost sharing in the form of volunteer effort or contributions from third parties must be accounted for in terms of the “market value” of the effort or contribution.
• In accepting an award where the proposal indicated institutional cost sharing, the University is committing itself to formally documenting that the cost sharing was actually applied to the project. If the award level is significantly lower than the requested level, a corresponding reduction in cost sharing should be negotiated.

See also Cost-Sharing or Matching

Time and Effort Reporting
See also Effort Reporting

Time and effort is required by federal (OMB Circular A-21) and state (Governor's Office, Uniform Grant Management Standards), and SFA policy A-68 (Effort Reporting and Certification for Sponsored Activities).

The federal Office of Management and Budget’s Circular A-21 requires the documentation of services charged to sponsored federal agreements. Circular A-21 requires reporting of the percentage of time each employee spent on all grants and contracts compared to total time (effort); these requirements are the same as those of the Uniform Grant Management Standards for Texas state agencies. This process is commonly known as “Time and Effort Reporting.”

The Principal Investigator (PI) or Project Director (PD) is responsible for knowing if there are any requirements for personnel time and effort reporting and for ensuring and certifying that personnel paid with grant or contract funds have performed at the level of effort as paid.

• SAMPLE FORM
• SAMPLE INSTRUCTIONS
• FAQ
• View a PowerPoint Presentation on Time and Effort
• ORSP training

Because organizations sponsoring research and sponsored programs at Stephen F. Austin State University do not directly supervise work performed, SFA is responsible for ensuring that only legitimate expenses are charged to the contracts and grants funded by these organizations.

Each contract includes guidelines for charging employee time spent working on that project. In order to comply with organizations’ funding regulations, SFA must maintain complete and accurate records of work performed by employees paid from a grant or contract. Time and effort charges to any contract must represent work done on that project only. It is inappropriate to charge time and effort from any other project for any reason whatsoever.

Effort must be reported for faculty, staff, and graduate assistants who are paid:

• Any percentage of a salary (base salary only);
• Either directly (salary) or through cost sharing (matching or contributed time); and
• From one or more federal or state grants or contracts.

Guidelines for Time and Effort Reporting

The purpose of the effort certification report is to confirm that the charge made to the payroll system “reasonably reflects” each employee’s activity. Significant deviations (+/- 5%) from payroll charges may require an adjustment to the payroll. This reporting requires the signature of the employee, Principal Investigator, Project Director, or other responsible official to confirm (certify) that the percentages allocated to each activity represent a reasonable estimate of the work performed.

The effort report should reflect how a person spent his or her total time (effort) proportional to each activity (teaching, reseach, service, and grants/contracts), which would not necessarily agree with how the person is paid. The estimated percentage of effort shown may be adjusted if it is significantly different (+/- 5%) from the actual time spent on a particular activity. The amount of effort must be greater than or equal to pay distribution on grant fund.

• Effort is based on total time, not on a 40-hour work week or percent of salary
  
• Effort used as cost sharing must be documented in the same fashion as if receiving salary from the grant or contract.
  
• Effort CANNOT exceed 100% - For example:

• If you work a total of 20 hours a week and 10 hours is spent on grant activities, effort on the grant(s) is 50%.
• If you work a total of 60 hours a week and 30 hours is spent on grant activities, effort on the grant(s) is still 50%.

Effort Notification Process:

Upon receipt of notification of a federal or state award or contract, ORSP notifies the payroll office that an effort report should be generated for the employee. Reports are generated for each employee every month and are distributed for signing either monthly (classified employees) or by semester (non-classified employees). Forms are sent to the Principal Investigator or Project Director for each employee identified in the grant or contract for processing.

Principal Investigators / Project Directors need to:

1. Maintain records of actual time each employee works on each project.
2. Use these records to charge time to contract budgets.
3. Require that faculty and staff submit effort reports and revisions promptly at the appropriate time interval.

• Faculty and Professional Staff (including graduate assistants) are required to report effort at the end of each academic term (fall, spring, summer).
• Classified salaried staff are required to report effort at the end of month.
• Staff and students paid hourly use University time sheets and are not required to complete additional effort forms.

Persons actually working on the sponsored project or a responsible party with direct knowledge of the employees activities should:

• Prepare and sign the effort report.
• Revise and sign the effort report, when needed.
• Write and sign a full and complete explanation for revised effort reports.

Supervisors (PI/PD) should:

• Review and approve the effort report.
• Approve and sign any revisions to the effort report.
• Review and sign the written explanation for the revision.

Guidelines for Time and Effort Reporting and Certification
The report should reflect how a person spent his or her total time (effort), which would not necessarily agree with how the person is paid. The estimated percentage of time shown may be adjusted if it is significantly different (+/- 5%) from the actual time spent on a particular activity.

The employee, or a responsible party with direct knowledge of the employee's activities, is responsible for signing a form for every month in the certificaiton period (monthly or semester) to affirm the accuracy of reported time and leave taken. In cases where the timesheet is prepared by someone other than the employee, if appropriate the employee should review the information.

Changes and Corrections to Time and Effort Reports
It is important to report time and effort carefully to avoid the necessity of making retroactive corrections. Retroactive changes may be warranted when it is necessary to correct clerical and data entry errors, when subsequent information is received indicating an incorrect original entry, and/or when charges applicable to a continuing project have been charged to an old account number because the new account number was not established when the expense was incurred.

Retroactive changes and transfers will not be approved when sufficient reasons and explanation are not provided or when the changes or transfers violate the restrictions of an account.

When it is necessary to make corrections to time and effort reported in a previous time period, a copy of the original effort report or time sheet must be used. The incorrect information must be lined through carefully and correct information provided and initialed by the person making the change. Time and effort reported should never be corrected by adjusting time reported in a subsequent period. The revised timesheet requires the same approvals as the original timesheet.

Cost-Shared Effort

If effort is used as cost sharing, effort is essentially documented in the same fashion as above; however, an additional form is generated by ORSP and included with the effort forms and instructions. This form should be completed, signed and dated, and returned along with the signed monthly reports.

• SAMPLE COST-SHARE FORM
• Cost-share example
  

YES, it can happen in Texas! Audit Challenges Oversight of NSF Grant in Texas The National Science Foundation (NSF) Office of Inspector General (OIG) published an audit of Texas State Technical College, West Texas. Weaknesses reported in financial controls at the institution included: Criticism of salary charges because the college did not have documentation to show that money was paid for work directly related to the grant. The college did not maintain activity reports to document that salaries charged to the grant reflected effort expended on the grant. Salary was paid for work performed after the expiration of the grant period (did not request a no cost extension). Cost sharing related to the grant was not adequately tracked. A consultant was paid with grant funds without a formal agreement for services. The OIG recommended that the institution be classified as a high-risk institution for future grants.

Representations and Certifications (Provisions and Assurances)

Required assurances, representations or certifications are usually detailed in the proposal instructions. Proposals are considered incomplete if required endorsement signatures are omitted, or if required certifications are not provided. ORSP will obtain the required signature of the President when the proposal is routed through ORSP.

For example, federal funding agencies require certification that the University is in compliance with the Drugfree Workplace Act; that the University has not used and does not intend to use federal funds for lobbying activities; and that the University is not debarred or proposed for debarment.

For electronic submissions, signed certifications may not be requested by the sponsoring agency until the project is under consideration for funding.

Subawards and Subcontracts

Subawards are made by the University to other organizations that will perform a part of the scope of work for a project awarded by the sponsor to the University. Subawards may be subgrants, sub-cooperative agreements, or subcontracts, and are generally of the same type as the award to the University. Agreements to obtain goods or routine services are purchases and not subawards, and subject to all relevant University procurement policies.

Additional information on the distinction between subawards and procurement is found in OMB Circular A-133, Section 210.

The PI/PD should incorporate prospective subrecipient's work statements, budgets, administrative approvals, in the sponsor’s format if the sponsor so requires, with the University’s initial proposal to the potential sponsor. Failure to identify a subrecipient in a proposal may require sponsor approval or competitive selection before the subaward can be executed.

In some cases (for example, proposals submitted to the National science Foundation) partnering institutions that constitute subawards will be required to enter and submit their own information in an online applicaiton.

If your project involves expenses associated with a cooperative organization or a tiered agreement, those expenses should be included as a subcontract in the proposed budget. The total subcontract cost should appear as a line item in your proposal budget, and a separate budget breakdown for subcontract costs should follow the proposal budget. In addition to a detailed subcontract budget, a letter signed by the individual authorized to contractually commit the subcontracting organization should be included in the proposal. Subcontract costs should include the subcontracting organization's fringe benefit expenses.

$25,000 IDC limitation - Indirect costs (IDC) in a subcontract must be in compliance with the sponsoring agencies guidelines. Under federally sponsorec research awards, the University only recovers the indirect costs on the first $25,000 of the subcontract at the university`s negotiated rate.

Subcontractors may recover indirect costs on the amount of the subcontract in excess of $25,000 at the organization's negotiated rate. If the subcontracting organization does not have a negotiated rate, no indirect for the organization should be included.

This limitation generally does not apply to training grants or other programs that require alternate IDC rate calculaitons. Be sure to carefully read the programs guidelines, and request assistance from ORSP, as needed.

See also Contracts

Contracts with Commercial Sponsors

These contracts require special handling. When developing proposals to commercial sponsors, issues concerning intellectual property (patent and copyright) provisions, publications restrictions, and confidentiality should be directed to the General Counsel as early as possible.

Proposal Deadlines

The ORSP offers three levels of proposal review:

• Level One, Signatures only - 3 working days requested
• Level Two, General editing and signatures - 5 working days requested
• Level Three, Technical review, editing and signatures - 7 working days requested

To ensure the submission of proposals by prescribed deadline dates, Principal Investigators (PI) and Project Directors (PD) should normally allow at least three (3) working days for a proposal to be processed by ORSP.

If a proposal reaches ORSP with insufficient time for review, ORSP will perform a post-submission review and make the sponsor aware of any needed revisions. Proposals with serious deficiencies may be withdrawn.

Administrative Review and Approval of Proposal

All proposals (at least a final budget and a working draft of the text) must be submitted to ORSP for administrative review at least three working days prior to the date the proposal must be transmitted to the sponsor. Proposals must be accompanied by a Proposal Clearance Form (PCF). The summary information contained on the completed form facilitates administrative review and approval, and helps to expedite processing.

(See also Proposal Submission and Proposal Deadlines)

Proposal Development Resources

• Plan Your Project
• Find Funding
• Develop Your Budget
  • Direct Costs
  • Indirect Costs
  • Matching - Cost Sharing
• Write Your Proposal
• Writing Resources
  • Standard Proposal Components
  • Standard Information for Proposals
  • Proposal Writing Tips: Do's and Don'ts
  • SFA Description and Fast Facts
  • SFA Grantwriters and Grant Assistants
  • ORSP Faculty Resource Station
• Submit Your Proposal

Program Income and Other Credits

Program income means gross income earned by the recipient that is directly generated by a supported activity or earned as a result of the award. Program income includes, but is not limited to, income from fees for services performed, the use or rental of real or personal property acquired under federally funded non-research projects, the sale of commodities or items fabricated under an award, license fees, and interest on loans made with award funds. It excludes income earned on intellectual property and interest earned on cash advances.

Program income generally is deposited in the sponsored project account in which the expenses were originally incurred, if the account is still active. Similarly rebates, refunds, proceeds from the sale of animals, etc. must be credited to the project account. If the project is no longer active when the income or other credit is received, it is to be treated in conformance with the sponsor policy. Note that under federal policy, the University has no obligation to the federal government for license and royalty income, and income received after the termination of a project.

If you anticipate any form of income from a sponsored project, contact ORSP to confirm how these funds should be handled.
The manner in which income from federal projects is managed is determined by federal circular OMB A-110, Section 24.

According to OMB A-110, in general, program income earned during the project period can be retained by the recipient and used in one of the following ways (as specified by the terms and conditions of the specific award):

(1) added to the federal funds and used to further eligible project or program objectives (always applies to research awards); or

(2) to finance the non-Federal poriton of the project or program (not budgeted in the federal award); or

(3) deducted from the total project or program allowable cost (reduces the federal cost).

Also, unless stated otherwise in the terms and condition of a federal award, the recipient may keep program income earned from license fees and royalties for copyrighted material, patents, patent applications, trademarks, and inventions produced under an award. Patent and Trademark Amendments (35 U.S.C. 18) do apply to inventions made under federal awards.

Changes in Projects that Require Explicit Sponsor Approval

In circumstances where Principal Investigators (PI) or Project Directors (PD) wish to make a change in a project that requires the sponsor’s explicit approval, they are to prepare the request to the sponsor, providing necessary justification, obtain division/college approval, and submit the request to ORSP using a Project Revision Form.

ORSP will review the request to make sure the content and justification are suitable, and then either forward it to the sponsor , or pass-through entity in cases where SFA is a subawardee, or approve it for transmittal to the sponsor by the PI/PD.

Since the sponsor may reply directly to either the PI/PD or to ORSP, each should inform the other when they receive a reply from the sponsor.

Changes that can never be made without a federal sponsor’s explicit approval are:

• Change the scope or the objective of the project or program;
• Change a key person specified in the application or award document;
• Absence of the project director/principal investigator for more than three months;
• Reduction in time devoted to project by 25% or more;
• Additional compensation that has not been explicitly approved by the sponsor; and
• Additional funding is needed to complete the project .

For allowable revisions to non-federal projects, refer to the award document and contact ORSP for assistance.

Some changes do not require prior sponsor approval, but do require that notification be sent to the sponsor and ORSP.

• Summary of "Expanded Authorities" Amendment - for projects funded by the US Department of Education (EDGAR)

See also Revisions

Sponsorship Acknowledgment and Disclaimers

All publications arising from work supported by the federal government must acknowledge support by the agency and award number, and provide a disclaimer that findings do not necessarily reflect the views of the awarding agency, and/or as provided for in the terms and conditions of the award.

Non-federal sponsors may also have requirements for acknowledgments and/or disclaimers. Principal Investigators and Project Directors must review the terms of their awards to determine if the sponsor requires disclaimers or additional acknowledgments, and to determine if the sponsor requires any specific wording.

Technical Reports and Other Deliverables

Federally funded projects typically require a final technical report within 90 days of the termination of the project, and many also require interim progress reports. Refer to OMB Circular A-110 for more information. Non-federal sponsors typically have reporting requirements as well. Principal Investigators (PI) and Project Directors (PD) are reminded of the need to submit reports required under the terms of the awards they receive or obtain formal approval to submit them at a later date.

Similarly, PIs/PDs must submit other deliverables according to the timetable established for the project, seek an extension through formal channels, or formally explain why the deliverable cannot be provided.

See also Reports

Intellectual Property and Publications

The University encourages participation by faculty, staff and students in scholarly research and creative activities that support and enhance teaching in its classrooms and laboratories. While research conducted at SFA is aimed at discovery and dissemination of knowledge, rather than profit from commercial application, the SFA Board of Regents recognizes that questions regarding intellectual property rights may arise from such activities. The Board seeks to balance the interests of the public, the University and the inventor, author, or creator in intellectual property arising from research and creative activities conducted by employees of the University. The Board further seeks to ensure that inventions, discoveries and creative works are used and controlled in an efficient and prudent manner which will result in maximum benefit to the public, the University and the inventor, author, or creator.

Contracts must be reviewed by the University's General Counsel for intellectual property and confidentiality clauses before they are forwarded to the President for signature.

For more information, see Policy D-20, Intellectual Property

Award Acceptance and Post-Award Administration

Award documents take many forms depending upon the type of sponsor and project. These documents require review and signature by the official institutional representative authorized to sign on behalf of the institution. At SFA, this is the President (or his designated representative). ORSP is responsible for processing all award documents.

Upon receipt of fully executed award documents or other proof of award, ORSP forwards information to the grants accountant in the Controller’s Office for assignment of an account number along with a Request to Establish an Account (REA) provided by the Principal Investigator (PI) or Project Director (PD). Once the PI/PD receives notification of the project account number, funds may be encumbered or expended against the project.

In addition, the REA outlines the responsibilities of the PI/PD for the responsible conduct of the award. When signed, the PI/PD is acknowledging and accepting the following responsibilities:

Principal Investigator (PI)/Project Director (PD) Acceptance of Responsibility

The Principal Investigator/Project Director is responsible for the programmatic management of the grant or contract and conducts the project activities as approved by the funding agency to meet project goals and objectives while adhering to sponsor guidelines and policies and procedures of the University. My signature below acknowledges that I understand that I am responsible for ensuring:

• Project expenditures are directly related to the project, reasonable, and necessary to meet project goals and objectives.
• Project expenditures are processed in accordance with University policies.
• Personnel paid from grant or contract funds perform at the level of effort stated in the grant/contract and effort is reported as required by University policies.
• Subcontracts, subrecipients, and consultants are monitored and reporting requirements are met.
• Compliance with policies for human subjects in research, animal use and care, and use of biohazards.
• Technical reports required by the sponsor are submitted in a timely basis and copies or notification of submission sent to ORSP.
• Amendments requiring sponsor approval are routed through ORSP for institutional approval.

After the REA is processed and and account number is assigned by the Controller's Office, ORSP will provide to the PI/PD an award letter that points out specific terms of the award, includes award information provided by the sponsor and a copy of the signed REA, and additional information to help the PI/PD manage their award. These enclosures may include:

• Allowable, allocable and reasonable costs for federal awards
• How to develop and process subcontracts using grant funds
• Employment paperwork (Personnel action requests, additional compensation, etc.) for grant employees
• Rules concerning non-per-diem food purchases
• Human subjects requirements

Project files and support for expenditures are retained for a minimum of three years (unless otherwise noted) after the grant or contract has been officially terminated by the sponsor.

See also Request to Establish an Account and Establishing an Account

Areas of Post-Award Grant Administration

Area of Administration	Responsible Parties
Contract negotiation Preparation of subcontracts	Preparation - Principal Investigator/Project Director with ORSP Assistance - ORSP Review - General Counsel Approval - President
Set-up of awards (FRS account set-up)	Request - Principal Investigator/Project Director Set-up - ORSP and grants accounting
Monitoring cost-sharing	Principal Investigator/Project Director
Sub-recipient monitoring	Principal Investigator/Project Director
Time and Effort Reporting	Principal Investigator/Project Director Assistance - ORSP/Controller's Office After-the-fact - Auditors
Compliance with human subjects, animal use and care, and biosafety requirements	Principal Investigator/Project Director See Safety in Research
Monitoring awards for compliance with applicable regulations or guidelines	Principal Investigator/Project Director After-the-fact - Auditors
Obtaining agency approvals for budget or programmatic modifications	Principal Investigator/Project Director with prior approval from ORSP
Obtaining agency approvals for no-cost extensions (NCE)	Principal Investigator/Project Director with notification to ORSP
Notifying ORSP of programmatic or budget amendments or extensions	Principal Investigator/Project Director
Project reports	Technical - Principal Investigator/Project Director with notificaiton to ORSP Financial - grants accounting
Assisting the PI/PD with administration of their projects	ORSP and grants accounting

Establishing a Grant Account
See also Grant Accounts and Forms

1. Submit a Request for a New FRS Account for External Grants and Contracts
   After notification from a sponsoring agency that a grant or contract has been awarded the budget manager, most often the Principal Investigator/Project Director, will complete a Request to Establish a FRS Account for External Grants and Contracts form and submit it to the Office of Research and Sponsored Programs (ORSP). ORSP will attach the required grant award and budget documentation and send it to the Controller’s Office for processing. (See related Policy C-34, Request to Establish an Account)
   
   
2. Meet with ORSP Staff - Optional but recommended
   On completion of a request to set up a new grant account, you may request for ORSP to set-up an orientation meeting with the project director(s), grant account manager(s), and administrative assistant(s) who will process the grant-related expenditures.
   
   The purpose of the meeting is to provide general information related to management of the specific grant award and to provide technical assistance to departmental grant personnel, as needed. A representative of ORSP and grants accounting will meet with project representatives. During the orientation meeting, ORSP staff will:
   • Provide a Technical Assistance Manual;
   • Outline specific grant requirements;
   • Provide information on time and effort reporting requirements;
   • Discuss audit issues;
   • Establish contacts for future questions; and
   • Establish a relationship with grant staff for future technical assistance.
     
     To request a technical assistance meeting, please contact ORSP.

Budget Changes
See also Revisions

If you want to revise your budget and the sponsor guidelines allow for it, you will need to request your revisions to ORSP using the Budget Revision Request Form.

ALL budget changes that move funds from one category to another must be submitted in this manner so they can be entered into the accounting system. Changes will not be made withour prior approval of ORSP. ORSP will not approve a change that is not explicitly or inferentially approved by the sponsor.

If you have questions about what is allowed, please refer to your award document, sponsor policies for budget amendments, the section on allowable costs, and/or contact ORSP or the Grants Accountant for assistance.

Some budget changes do not require prior sponsor approval and these are generally noted in the award document; however, ORSP still must be notified of the changes. Please contact ORSP for more information.

In most cases, if sponsor approval is required for a budget amendment, the PI/PD is responsible for submitting the request in writing, either by e-mail or by formal budget amendments as required by the individual sponsor. For assistance with this process, please contact ORSP.

ORSP and the Grant Accountant are available to help you set up your budget, set up a shadow budget, and to reconcile your records with those in the FRS.

To assist you with budget management, ORSP has developed a budget template ( Excel and PDF) to help you to place your grant-approved expenditures into the correct SFA object codes, and a "shadow budget" template in Excel. The "shadow budget" allows you to independently track your grant expenditures and to compare your record to the University's record of your account in the FRS.

**NOTE: Most expenditures cannot be obligated if funds are not available in an account, or in an account category (for example purchase orders, travel, and payroll). In the event that cost overruns on projects do occur, it is the responsibility of the department of the PI/PD to absorb those costs.

Supplemental Funds Requests

Requests for additional funding on an existing project are processed as proposals through ORSP. You will need the following items: 1) Revision Clearance Form; 2) revised budget; 3) statement of work for the additional effort; and 4) updated certification for all compliance issues if necessary. Please make a notation of your current grant number on the Revision Clearance Form. Submit the form to Box 13024, SFA Station.

Change of Principal Investigator

If a change of principal investigator is required on a project, a letter must be sent to the sponsor. The letter should be endorsed by the current PI and the proposed PI and should outline the qualifications of the new PI. A copy of the letter must be sent to ORSP, Box 13024, SFA Station.

Leave of Absence

If you plan to be away from the University for a period of 90 days or more and you have a sponsored project, you will need to notify your sponsor in writing of your absence. Your letter will need to address how you plan to maintain oversight of your project during your absence. A copy of the letter must be sent to ORSP, Box 13024, SFA Station.

I'm leaving SFA. Can I take my grant with me? If so, how?

Transferring a grant to another institution is a complicated process and requires proper timing to allow for the transfer and to allow for start-up at the new institution. Some grants cannot be transferred. Some sponsors have specific forms which must be completed to obtain a transfer (e.g., NIH Relinquishing Interests Form, NSF Grant Transfer Form). Other sponsors may not have formal guidelines for transfers . There are general procedures that need to be followed here to prepare for a transfer. Please note the following steps in preparing for a grant transfer. First, select an arbitrary expiration date for your project. You may need to submit non-competing continuations for the next year's funds through your new institution.

In order to relinquish the project, the Controller’s Office must be able to determine the residual funds remaining after all obligations have cleared. It takes at least 30 days after the expiration date to obtain this information.

If you purchased equipment, have been approved to take the grant with you, and want to take equipment purchased by the sponsor for this specific grant activity with you when you move, you must obtain prior, written approval from the sponsor, your Chair, Dean, and the Vice President of Business Affairs.

Please contact ORSP as soon as you know you are leaving so we can guide you through this process.

Effective Grant Management

Key Questions for Principal Investigators and Project Directors

• Are all activities appropriate to the grant, as funded?
• Do you have an effective process to manage grant funds?
• Is there adequate documentation on file to support appropriate expenditure of grant funds?
  • Time & effort reporting
  • Travel requests
  • Contract documents
  • Cost sharing
  • Program reports
• Are project files and support for expenditures in a location (i.e., the departmental office) that allows them to be maintained for a minimum of three years (unless otherwise noted) after the grant or contract has been officially terminated by the sponsor?

Audit Considerations

In conducting an audit of externally funded grants and contracts, auditors will look for documentation to verify the following:

1. Conditions of the grant are being followed.
2. Matching funds have been received and non-cash cost sharing commitments have been honored.
3. Personnel paid by grant funds actually worked on the grant.
4. Faculty salaries paid from grants are consistent with limitations included in grant conditions, if any.
5. Equipment purchased with grant funds was specifically listed, pre-approved, actually needed to conduct grant activities, and actually used during conduct of grant activities.
6. Travel paid from grant funds is actually related to and supports grant activities.
7. Budget transfers in excess of those authorized by grant conditions received prior approval from the funding agency.

Audit Alerts! There is inadequate documentation to justify payment of project personnel (effort reports). Project activities are not outlined in the agency-approved statement of work. Project funds are expended for items not included in the agency-approved budget. Travel is not within the scope of the project. Subrecipients are not monitored to ensure compliance with agency regulations. Changes are made to project budget, key objectives, and/or subcontracts without prior agency approval.

 

Responsibilities of Principal Investigators and Project Directors In the Conduct of a Grant or Contract

In the conduct of a grant or contract, the Principal Investigator or Project Director (PI/PD) has the following principal responsibilities.

Principal Investigator (PI)/Project Director (PD) Acceptance of Responsibility

The Principal Investigator/Project Director is responsible for the programmatic management of the grant or contract and conducts the project activities as approved by the funding agency to meet project goals and objectives while adhering to sponsor guidelines and policies and procedures of the University. My signature below acknowledges that I understand that I am responsible for ensuring:

• Project expenditures are directly related to the project, reasonable, and necessary to meet project goals and objectives.
• Project expenditures are processed in accordance with University policies.
• Personnel paid from grant or contract funds perform at the level of effort stated in the grant/contract and effort is reported as required by University policies.
• Subcontracts, subrecipients, and consultants are monitored and reporting requirements are met.
• Compliance with policies for human subjects in research, animal use and care, and use of biohazards.
• Technical reports required by the sponsor are submitted in a timely basis and copies or notification of submission sent to ORSP.
• Amendments requiring sponsor approval are routed through ORSP for institutional approval.

Prevent grant fraud, waste, and abuse

1. Project Management
   The PI/PD is responsible for the programmatic management of the contract or grant, conducting the project to meet project goals and objectives as approved by the funding agency while adhering to agency guidelines and university policies and procedures.
   
   In addition to University purchasing and travel policies, the PI/PD is responsible for compliance with all applicable University policies related to the research or sponsored project in question, including:
   • Conflict of Interest in Sponsored Activities (A-11.5);
   • Intellectual Property (D-20);
   • Misconduct in Science (A-31.5);
   • Human Research Subjects Protection (A-62);
   • Property Management and Inventory (C-42);
   • Departmental Accounting Responsibilities (C-11); and
   • Grants and Contracts Administration (A-56).

   Copies of all applicable documents are available on the University Web site.

   The PI/PD is similarly responsible for ensuring compliance with federal, state and agency regulations, such as OMB Circulars A-21, A-110, and A-133, and the Federal Acquisition Regulations and Supplements (FARS), which are applicable to the grant or contract award. In addition, the PI/PD is responsible for ensuring compliance with any specific requirements of the grant or contract.

2. Budget Management

   The PI/PD is responsible for the financial management of the contract or grant and is responsible for ensuring that all expenditures are directly related to the project, are necessary to meet project goals and objectives, and are approved by the funding agency.

Resources for the PI/PD include:

• Award documents - ORSP staff is available to help you interpret allowable costs for your award
• Allowable, Allocable and Reasonable and OMB Circular A-21 -- Expenditure guidelines for federal projects
• Budget changes - Make sure changes you make to a budget are allowable under the award
• Changes in the FRS - Contact ORSP and/or the Grants Accountant to make sure sponsor-approved changes are entered into the financial system (FRS)
• Revision Clearance Form
• Shadow Budget Template - The "shadow budget" allows you to independently track your grant expenditures and to compare your record to the University's record of your account in the FRS.

ORSP and the Grants Accountant are available to help you set up your budget, set up a shadow budget, and to reconcile your records with those in the FRS.

To assist you with budget management, ORSP has developed a budget template ( Excel and PDF) to help you to place your grant-approved expenditures into the correct SFA object codes, and a "shadow budget" template in Excel. The "shadow budget" allows you to independently track your grant expenditures and to compare your record to the University's record of your account in the FRS.

The PI/PD should consult with ORSP and the Grants Accountant for assistance with budget management issues, and for assistance in the completion of interim and final financial reports (as needed by the sponsor).

**NOTE: Most expenditures cannot be obligated if funds are not available in an account, or in an account category (for example purchase orders, travel, and payroll). In the event that cost overruns on projects do occur, it is the responsibility of the department of the PI/PD to absorb those costs.

3. Subrecipient Monitoring

   The PI/PD is responsible for monitoring any subrecipients of the grant or contract to ensure that programmatically and financially the subrecipient is meeting project goals and objectives while adhering to agency regulations.

See also Subawards and Subcontracts

4. Personnel Policies and Procedures

   The PI/PD must have knowledge of University personnel policies and procedures if they will be hiring any personnel on their grant or contract.

Human Resources

5. Cost Sharing and Matching
   
   The PI/PD is responsible for knowing if the grant or contract has any cost sharing requirements and in coordination with the department or college, to ensure that the cost sharing requirements are met.

See also Cost Sharing and Matching

6. Time and Effort Reporting

   The PI/PD is responsible for knowing if time and effort reporting is required or and ensuring that reports are completed, certified, and maintained for the appropriate length of time.

See also Time and Effort Reporting

7. Research Integrity - Misconduct in Research
   
   Scholars and research personnel of the University are expected to adhere to the highest ethical standards for all research and scholarly work. It is the responsibility of every research investigator to maintain the integrity of research projects by keeping accurate, permanent, and auditable records of all experimental protocols, data, and findings. Misconduct in science and allegations of such behavior will be handled promptly. The University's policy regarding research integrity may be found at the following site: Policy A-31.5.

8. Conflict of Interest in Sponsored Activities
   
   The Principal Investigator or Project Director should have no conflict of interest that would affect the conduct of the project.
   
   This policy requires that an employee of the University who applies for grants or cooperative agreements from the federal government for research or other sponsored activities or otherwise submits a proposal for sponsored research finding from any entity insures that there is no reasonable expectation that the design, conduct, and reporting of research will be biased by any significant financial interest of an Investigator responsible for the research or other activity. Based upon federal regulations and the University's objectives to maintain a research environment that promotes faithful attention to high ethical standards, this policy relating to conflicts of interest is to be administered in conjunction with Texas laws setting forth standards of conduct, Texas Government Code, Chapter 572, and SFA Policy A-11.5

Project Closing Procedures - What to do when it's all over

Sponsors have specific guidelines for close-out procedures for grants and contracts. When projects near completion, Principal Investigators and Project Directors should be aware of the following andf take appropriate action:

• Sponsors instructions for positive fund balances after conclusion of the project have been followed.
  • Are there funds that need to be returned? If not, what is the approved method for disposition of account balances?
  • Is the account overdrawn, and if so which non-grant accounts will be used to cover the overages?
• All technical reports have been submitted and accepted by the sponsor.
• Required time and effort records are complete.
• All outstanding encumbrances have been reconciled.
• The sponsor has officially released the project.
  • Financial and technical reports have been accepted.
• Records will be maintained for the time specified by the sponsor.
  • Three years after the final report has been accepted for most federal projects.
  • Some projects specify five years, such as federal Perkins projects funded by the Texas Higher Education Coordinating Board.

The Grants Accountant is responsible for submitting the final financial documents for each project in consultation with the PI/PD and ORSP, as required.

At the conclusion of each project, ORSP staff conduct a close-out Technical Assistance Desk Review (TADR) to identify areas in the project that may need to be addressed. The review includes assessing whether grant funds appear to have been expended according to the sponsor approved budget, project amendments were processed appropriately, reports were filed in a timely manner, etc.

PART II - Internal Funding
See also Internal

ORSP manages two internal funding streams, the Research Enhancement Program and the Research Development Program.

The Research Enhancement Program at SFA has two components: the Faculty Research Grant Program and the Minigrant Program.

Faculty Research Grants

Faculty Research Grants provide substantive support for research and scholarly creative activities. Through an annual competition held during the spring semester, the University Research Council awards funds for the upcoming fiscal year.

Deadlines
Eligibility and Conditions
Criteria for Evaluation
Evaluation Methods
Allocation of Funds

Application Cover Page and Checklist (PDF)
Application Guidelines (PDF)
Budget Justification Sample (PDF)

Minigrants

Minigrants provide an opportunity for faculty to carry out small projects or preliminary research activities that will increase their competitiveness in the acquisition of external funds.

You may apply for a minigrant award of up to $2,500 (effective April 30,2008), or multiple awards not to exceed $2,500 in a single fiscal year. If applicable, please include an estimate of shipping and handling costs for equipment requests in your budget. Further restrictions are placed on travel awards. Please refer to the MInigrant Guidelines (below) for details.

The minigrant application form should submitted to Dr. Carrie Brown, PO Box 13024.

Applicants should review the following guidelines carefully for a complete explanation of constraints and limitations of these awards.

Minigrant Application Form (PDF)
Minigrant Guidelines (PDF)

University Research Council (URC)

The University Research Council, chaired by the Director of Research and Sponsored Programs, is responsible for recommending policies and procedures to encourage research activities and to improve the research environment of the University; developing and recommending University research policies based upon state and federal laws and regulations; recommending adjudication to variances to policies and procedures; and developing guidelines for and recommending awards of University research grants. Of the ten University Research Council members, six members, one from each of the academic colleges of the University, are elected from the full members of the graduate faculty. One member represents the Library. The remaining three members are appointed from the full members of the graduate faculty by the chair of the Council, subject to the principle of proportionate representation from each academic college on the basis of full and associate members of the graduate faculty in the respective colleges, and subject further to the approval of the Provost and Vice President for Academic Affairs.

The Council members from a given college are elected by the faculty - both undergraduate and graduate members - of that college. Both elected and appointed members of the Council serve three year terms. Upon expiration of a term, the Council member is ineligible for re-election or reappointment to the Council until the lapse of three years. A vacancy on the Council is filled either by election or appointment, whichever is applicable to the position vacated.

See the URC Committee Information and Roster

The URC awards Faculty Research Grants as part of the University's Research Enhancement program. These grants are competetive and awarded annually for projects to be completed during the upcoming fiscal year.