ORSP Grants and Contracts Procedures Manual
Stephen F. Austin State University

Effective: February 2005 - Last Revised: May 9, 2012
Adopted by SFA policy A-56

Download PDF version (8-2-2011)

TABLE OF CONTENTS

I. General Information

A. Overview of ORSP Services
B. Definitions

1. Types of Sponsored Projects
2. Research and Development
3. CFDA
4. Restricted Gifts

II. Standard Proposal Information

A. Important Information (Addresses, EIN, DUNS, etc.)
B. Fringe Benefit Calculations
C. Indirect Cost Calculations
D. Tax Exempt Status: SFA and the SFA Foundation, Inc.

III. Description and Purpose of Forms

A. Proposal Clearance (PCF)
B. Cost-share Detail (CSR)
C. Subawardee Certification for Federal Projects (SUB)
D. Request for Indirect Cost Reduction or Waiver (ICW)
E. Additional Compensation Eligibility Verification (ACV)
F. Request to Establish a Banner Fund (REF - grants & contracts)
G. Budget Set-up and Revision (BUD)
H. Cost Transfer Request (CTR)
I. Revision Clearance (RCF)
J. Research Gift Notification and Statement of Compliance Form (RGN)
K. Contract Request (CRF)
L. Grant Mailing Request (GMR)

IV. Compliance and Safety in Research

A. Introduction: Ethics in the conduct of sponsored projects
B. Responsible Conduct of Research (RCR)
C. Protection of Human Research Subjects (IRB)
D. Animal Care and Use (IACUC)
E. Export Control Regulations
F. Biosafety and Select Agents
G. Environmental Safety and Health/Radiation

V. Regulations, Policies, and Procedures

A. Role of University Offices in Sponsored Projects
B. ORSP and Grant-related Procedures
C. Responsibilities of the Principal Investigator (PI) or Project Director (PD)
D. SFA Policies Governing External and Internal Funding
E. Federal and State Regulations

VI. Internal Grant Funding

A. Research Enhancement Program (RHP)

1. Faculty Research Grants (FRG)
2. Minigrants (MG)

B. Research Development Program (RDP)
C. University Research Council (URC)

VII. Find External Funding

A. Benefits of External Funding
B. How to Find External Funding
C. Federal, State, and Private Funding Sources

VIII. Apply for a Grant

A. Proposal Processing and Submission Procedures, & PI/PD eligibility guidelines
B. Contracts to SFA: Development, review, and approval
C. Tips for Project Planning and Proposal Writing
D. Special Proposal Requirements: Data management, current/pending support, mentoring, subawardee certifications
E. Develop a Budget

1. Direct and Indirect Costs
   * Salaries and wages
   * Additional compensation
   * Fringe benefits
   * Subawards and subcontracts
   * Equipment
   * Supplies and materials
   * Travel
   * Participant costs - scholarships and stipends
   * Other direct costs
   * Indirect costs
2. Matching and Cost-sharing Commitments
3. Budget Justifications

IX. Manage a Project

A. Award Process: Request a fund, award orientation
B. Budget Management: Banner funds, invoicing, cost transfers, insufficient funds/overruns
C. Project and Budget Amendments
D. Subawards, Participant Agreements, and Contracts for Services: Development, approval, and management
D.1 Contract Templates
E. Cost-sharing and Matching: Documenting expenses
F. Personnel Policies and Procedures
G. Effort Certification (Time and effort reporting)
H. Technical Reports and Other Deliverables
I. Program Income and Other Credits
J. Sponsorship Acknowledgement and Disclaimers
K. Intellectual Property and Publications
L. I'm leaving. Can I take my grant with me?

X. Project Close-out

A. Close-out Procedures
B. Disposition of Supplies, Materials, and Equipment
C. Records Retention, Inquiries, and Audit Considerations

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I. General Information

A. Overview of ORSP Services

The principal responsibility of Stephen F. Austin State University (SFA) to sponsoring agencies or individuals is to ensure that projects are conducted and funds are spent according to the award terms and conditions, applicable state and federal regulations and guidelines, and university policies and procedures. To facilitate these processes and to help ensure successful project outcomes, the Office of Research and Sponsored Programs (ORSP) provides the following services and activities.

Administration of Internal Grant Programs

• Manage Faculty Research Grants (FRG)
• Award and manage minigrants (MG)
• Manage the Research Development Program (RDP)

Pre-award Technical Assistance

• Identify external funding sources
• Interpret proposal guidelines and contract terms
• Assist with proposal organization, and review and edit proposal format and text
• Develop and review proposal and contract budgets
• Identify and advise on cost-sharing and matching commitments
• Complete standard application forms
• Conduct contract reviews in coordination with the University's general counsel
• Coordinate the University's proposal clearance process
• Manage and coordinate proposal submissions (paper and electronic)

Post-award Technical Assistance

• Process award documents
• Facilitate grant and contract budget set-up
• Interpret contract and award terms and conditions
• Provide new award orientation sessions
• Provide information and training on compliance requirements of awards
• Manage the effort certification process for state and federal awards
• Develop, review, and route subawards and contracts to the University's general counsel
• Review and submit budget and project revisions to sponsors
• Assist with submission of project technical and financial reports

Data Collection and Reporting

• Maintain application and award information in the ORSP database
• Maintain subaward and contract information in the ORSP database
• Prepare and submit reports concerning state, federal, and private awards
• Coordinate Federal Transparency Act (FFATA) and Recovery Act (ARRA) compliance and reporting
• Prepare and disseminate information to the SFA administration, faculty, departments, and organized research units and other interested parties

Professional Development and Networking

• Conduct workshops and forums to provide pre-award and post-award information and promote grantsmanship
• Maintain a database of faculty research interests

Committee Service

• Chair the University Research Council (URC)
• Serve on the Institutional Review Board for Protection of Human Subjects (IRB)
• Serve on the Institutional Animal Care and Use Committee (IACUC)
• Serve on additional university committees, as required

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B. Definitions

1. Types of Sponsored Projects - The term "sponsored projects" encompasses externally funded research, scholarly, and public service activities supported by entities outside the University. They result from proposals submitted by SFA or the SFA Foundation, and/or contracts offered to SFA, and funded by external organizations. Sponsors may be a federal, state, local, or foreign unit of government, a foundation, an association, or a commercial entity or individual.

Sponsored projects are solicited and/or accepted for purposes that are consistent with and enhance the teaching, research, and public service mission of SFA. Sponsored projects usually include a defined scope of work or set of objectives and technical and/or financial reports are usually required by the sponsor. All types of sponsored projects must be routed through and submitted by ORSP per university policy.

Sponsored project award agreements vary and usually follow one of the formats described below.

• Grants are used when the principal purpose of the award is to accomplish a specified public purpose, or support or stimulate initiatives authorized by federal or state statute (grants from state and federal governmental entities). Grants are also used by local governments, foundations, associations, corporations, and other private entities. Most federal and many state grant award documents are in the form of a Notice of Grant Award (NOGA) and grant terms and conditions usually consist of sponsor or program regulations that are referred to but not included in the grant document itself. Some grant awards take the form of contracts.

• Subawards are pass-through awards from an entity using funds it received from a prime sponsor rather than its own funds. Subawards are 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 adds to ensure effective administration of the subaward.

• 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 sponsor (thus a cooperative arrangement).

• Contracts and subcontracts are used when the principal purpose is procurement (acquisition of property or services for the direct benefit of the sponsor) and constitute a vendor relationship, although as noted above, contracts may be used to outline the terms of a grant award. Contracts usually detail specific deliverables, and terms and conditions are incorporated directly into the contract document.

• Interagency and interlocal agreements are used to establish terms and conditions between two state agencies (interagency) or between a state entity and a local government entity (interlocal). These agreements include legal language specific for these two types of contractual relationships.

• Fixed-price agreements are awards where the University agrees to perform work or deliver a product within a specified period at a price agreed to in advance that is payable in full regardless of actual costs incurred. They usually take the form of a contract.

• Scholarships are considered sponsored projects and are covered under sponsored project policies if they require a formal grant application and are: (1) received as all or part of a sponsored project and awarded to eligible students selected by the sponsor, or (2) received as all or 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 the University selects the recipient.

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2. Research and Development 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).

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). (Standards and Accounting Methods, Texas Higher Education Coordinating Board)

A project is classified as "restricted research" if:

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 restricted. A contract from a private sector company would typically be considered restricted. 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.

The purpose is primarily research - The primary purpose will normally be demonstrated by the sponsor's statement of purpose or other documented evidence, such as the statement of work or other documented evidence, and for projects with multiple goals may be demonstrated by more than half of the funds (equal to or greater than 50%) budgeted for research.

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3. 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 and is used for grant applications and reporting purposes. CFDAs are assigned to a grant competition and award by the federal awarding agency. CFDA

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4. Restricted Gifts are targeted contributions made to the University for which the donor receives no direct benefit and provides the support with minimal requirements (i.e., no terms, conditions, or other obligations, no authorized signature required, no financial or programmatic reports required, and no intellectual property, confidentiality, or publication conditions). Gifts do not require specific deliverables.

Gift letters and checks should be forwarded to The Office of Development for processing. Unrestricted gift funds are generally placed in "various donors" gift accounts. ORSP should be notified of all gifts desingated for research to aid in accurate reporting of research expenditures.

If one or more of the following apply, the award is not a gift and ORSP must be involved the submission process:

• a specific program of work or research is proposed to, or required by the sponsor;

• the sponsor requires an authorized institutional signature;

• 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; and/or

• there are intellectual property, confidentiality, and/or publication conditions associated with the receipt of funds.

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II. Standard Proposal Information

A. Important Information

The following information is needed for the submission of some grant applications. Contact ORSP if you need any information not provided below.

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B. Fringe Benefit Calculations

For each dollar paid as salary or wages to an employee, the University incurs associated costs for non-optional fringe benefits. These benefits include F.I.C.A., worker's compensation, unemployment compensation, retirement matching, and health insurance. SFA Human Resources Benefits

Fringe benefits are treated as a direct cost to a sponsored project and are shown as a separate entry in the budget. The actual costs for fringe benefits are charged to a sponsored project fund at the time the costs are incurred. The amount charged is based on salary, the selected benefit package, and other variables applicable to the individual employee. Calculations for full-time employees include withholding taxes, retirement contributions, and health insurance.

As a general rule, benefits can be determined using an estimated calculation if the staff member to fill a position has not been identified at the time of proposal submission.

• Effective FY 2012 the estimate used for unspecified employees is 28% of salary or wages (full benefits) for faculty and staff and 2% of salary or wages (unemployment insurance and worker's compensation) for graduate and undergraduate students. One-half of health insurance benefits may be added to accommodate graduate students who elect to pay the balance of the premium.

• Additional compensation is calculated at 16.29% of salary (all but health insurance).

• Benefits for casual employees and retirees are calculated at 9.65% of salary or wages (FICA/Medicare, unemployment insurance, and worker's compensation).

• Accrued compensation for end-of-year vacation and non-exempt staff comp time balances is charged at the end of the fiscal year for project personnel who leave university employment during the year. Since these charges are usually not budgeted they can result in an unexpected deficit. Please contact ORSP if you anticipate this type of situation.

The table below outlines rates for each category of benefit.

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C. Indirect Cost (IDC) Calculations – aka  Facilities and Administration, F&A, Overhead Costs

All proposals and contracts submitted on behalf of the University must include indirect costs at the maximum rate allowed by the sponsor.

• SFA's Negotiated Indirect Cost Rate Agreement: NICRA

• Cognizant Agency: Department of Health and Human Services (DHHS)

• Effective Dates: September 1, 2010 to September 1, 2013 (until amended)

• Indirect Cost Policy: SFA policy A-51 (Indirect Cost Recovery, Distribution, and Use)

In addition to costs directly related to a project, the University incurs costs that are indirectly related to all projects. These costs include:

• building space and utilities;

• departmental administrative and clerical services; and

• the services of ORSP, general counsel, payroll, travel, purchasing, university security, and custodial staff.

In other words, indirect costs encompass all elements that support sponsored activities that cannot be directly associated and charged to a specific grant or contract. The recovery of these costs is essential because these costs don't go away, and if unrecovered, are paid for by tuition and other non-grant sources.

Indirect costs are allowable, necessary and expected. Sponsors that allow indirect costs DO NOT preferentially fund proposals that request less than the maximum allowed IDC rate and including indirect costs in a budget does not negatively affect the outcome.

Indirect cost rates are determined for each institution using a standardized, detailed cost accounting procedure. Representatives of the federal government (the cognizant agency) audit and approve IDC rate calculations.

SFA’s current negotiated indirect cost rates are:

• 28.3% Modified Total Direct Costs (MTDC) (on-campus).

• 8.5% MTDC (off-campus) - The off-campus rate is 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. The use of the off-campus rates presumes that no staff being paid by the project are on campus and that there is limited or no access to campus facilities for the project, including cost-sharing of such facilities. Therefore, costs which are incurred in the field may qualify for the off-campus rate depending on a project's scope of work. Off-campus rates do not apply to projects structured with day-long or short-term field trips. In rare occasions, a proposed budget may include both on and off campus budget items. Prior to selecting the off-campus rate, please contact ORSP for assistance.

• Fixed-price agreements will be assessed the full on-campus indirect cost rate. When developing budgets for such agreements, be sure to include indirect costs in order to arrive at the total cost to SFA (direct plus indirect) before providing the estimated cost of services to a sponsor. Contact ORSP for assistance.

To calculate IDC on MTDC:

• Exclude capital equipment with a unit value of >/=$5,000;

• Exclude payments to students or program participants in the form of scholarships or stipends; and

• Exclude all but the first $25,000 of each subaward or subcontract (to conduct a substantive portion of the project as approved by the sponsor). This does not apply to vendor contracts (contracts for services). Indirect costs included in a subaward or subcontract must be in compliance with the sponsoring agencies guidelines. Subawardees may recover indirect costs on the amount of their subaward at the organization's negotiated rate. If the subcontracting organization does not have a negotiated rate, no indirect costs for the organization should be included.

IDC must be included using SFA's federally-negotiated rates unless the sponsor has a written policy that specifically limits IDC for all applicants. Sponsor guidelines or policies that document limitations on IDC must be included with the Proposal Clearance Form (PCF). Requests for voluntary IDC reduction must be approved by SFA administration before a proposal or contract budget is presented to a sponsor. These requests must be justified using a Request for Indirect Cost Reduction or Waiver Form (ICW) and submitted with the PCF.

Only the President of SFA can waive indirect costs (SFA policy A-51). Any under-recovery of indirect costs due to grantor restrictions must either be treated as cost-sharing on behalf of the University or supplied from other funds.

IDC Recovery and Distribution:

After IDC is charged to sponsored projects based on the approved rate, the resulting revenue is placed in a campus fund for distribution by campus administration based on SFA's IDC policy. Any questions about the collection and distribution of recovered IDC should be directed to ORSP.

Indirect Cost Distribution Formula - as of January 2011

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D. Tax Exempt Status and the SFA Foundation, Inc.

SFA is a state agency and therefore is a tax-exempt, non-profit institution; however, SFA does not have IRS 501(c)(3) status.

The Stephen F. Austin State University Foundation, Inc., is a 501(c)(3) organization; therefore, proposals that require submission by a 501(c)(3) organization must be submitted through the SFA Foundation rather than the University. These applications are coordinated efforts of ORSP and the Office of Development that follow all standard SFA grant procedures, and are routed through ORSP with a Proposal Clearance Form (PCF).

If you are seeking a gift, you should contact the Office of Development. Gifts are defined as:

• cash gifts designated for generic research (no specific statement of work) or general program support;

• donations of equipment and other non-cash items; and

• assistance with solicitation of philanthropic gifts from foundations and individuals.

Gift or Grant? Brochure :: Research Gift Notification and Compliance Information Form

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III. Description and Purpose of Forms

ORSP Forms

A. Proposal Clearance Forms (PCF) are used to route pre-proposals, proposals, and collaborative grant applications and contracts from external sponsors for administrative signature approvals. All applications and contracts from SFA and the SFA Foundation (regardless of the source of funds) should be approved in advance of submission by the appropriate chair, dean, vice-president(s), and the President.

Deans and academic chairs/directors are responsible for reviewing grant proposals and contracts and for assuring that the proposed commitments of unit resources are feasible and realistic and that they support the mission of the university. This includes confirming that the following are appropriate, as applicable: (1) faculty and/or staff time commitments; (2) cost-share or matching commitments; (3) use of university facilities; (4) required facility modification or remodeling; and (5) overall cost of equipment to be purchased, including shipping, set-up, and maintenance.

The completed PCF should be submitted to ORSP for routing with:

• a final budget;

• a final or final draft of the pre-proposal, proposal, SFA's portion of the collaborative application, or contract;

• a cost-share detail form and/or IDC waiver form, as applicable;

• a copy of sponsor guidelines documenting IDC limitations, as applicable; and

• required department and college signatures.

To ensure that signatures can be obtained before the proposal deadline, the completed PCF and related materials should be submitted to ORSP for review and routing at least three working days before the submission deadline.

ORSP cannot guarantee submission of a proposal that does not adhere to this time line.

The Proposal Clearance Form documents the following:

• Disclosure of involvement of human subjects, vertebrate animals, biohazards, or recombinant DNA in research;

• Disclosure of significant financial interests of the Principal Investigator (PI) or Project Director (PD) and termination of public transactions by cause of default;

• Certification that the PI/PD has read and understood the SFA policy on conflicts of interest in sponsored projects, has made the required financial disclosures, and will work to manage, reduce, or eliminate potential conflicts of interest;

• Certifications that for federal applications the PI/PD is not delinquent on any federal debt, including student loans, and is not presently debarred or suspended or voluntarily excluded from federal transactions;

• Assurance that no federal funds have been or will be paid to influence the granting of the award;

• Assurance that the PI/PD is not delinquent in submitting final project reports to sponsors for previous awards;

• Certification that the PI/PD will assume full responsibility for ensuring project compliance with sponsor requirements and stipulations; and

• Approval of the PI/PD, the chair(s), and dean(s) of the of cost-sharing or matching commitments listed in the proposal and permission to transfer cost-shared funds to a grant-specific FOP (see B, below).

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

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B. Cost-share Detail Forms (CSR) are used to provide detailed information on cost-shared, matched, and/or in-kind contributions to a sponsored project. In addition, completion of the form provides the SFA source of funds to be used to account for the cost-share commitment. Completed CSR forms should be submitted to ORSP.

Signatures are not required on the CSR. Administrative signatures on the Proposal Clearance Form (PCF) confirm that, upon award, SFA finance departments are authorized to transfer committed funds to a cost-share FOP (fund, organization, program) specific for a grant. Cost-shared expenses, such as salaries and purchases, are subsequently pulled from that FOP. This clearly delineates and documents cost-shared expenditures.

Note that Electronic Personnel Action Forms (EPAFs) for cost-shared salaries must be completed for all individuals who are cost-sharing salary (using the cost-share FOP).

For more information on cost-sharing and matching, see section VIII D2.

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C. Subawardee Certification for Federal Projects Forms (SUB) are used to obtain standard proposal information and to pre-certify potential subrecipients for federal and federal pass-through awards at the pre-award stage. This ensures that the subawardee listed in an SFA grant application has provided information required for federal awards, including federal assurances, program compliance, and A-133 audit requirements. Pre-certification will streamlines development and execution of subawards.

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D. Request for Indirect Cost Reduction or Waiver Forms (ICW) are used to request a reduction in the indirect cost (IDC) rate applied to a proposal or contract when the reduction is voluntary, rather than the result of a sponsor-imposed limitation. The Principal Investigator (PI) or Project Director (PD) must justify the request for IDC reduction and provide calculations that demonstrate the resulting loss in IDC revenue to the University.

IDC waiver requests with adequate and compelling justification may be recommended by the Director of ORSP and the Provost/VPAA, but must be approved be the President.

ICW forms are not required if sponsor guidelines limit IDC. Attach a copy of the sponsor's IDC guidelines in lieu of this form.

If an IDC waiver is granted for a fixed-price award, the amount of waived IDC will be deducted from any balance remaining at the end of the project period.

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E. Additional Compensation Eligibility Verification Forms (ACV) are used to confirm that requests for SFA employees to receive payments in excess of their base salary: meet the terms of the sponsor and university policies and guidelines; outline specific terms for payment in sponsor-approved grant applications or contract terms or in subsequent documents from the contracting official; and provide sufficient detail to confirm sponsor approval of extra pay for specific activities performed by SFA employees.

Federal and state sponsors have strict regulations concerning additional compensation. For specific language, refer to Federal OMB Circular OMB A-21, Section J.10.a.&d., and the State of Texas Uniform Grant Management Standards (UGMS), Attachment A, Section A.3.

For more information, refer to SFA policy E-74, Compensation from Grants, Contracts, and Other Sponsored Agreements and SFA policy E-9, Salary Supplements, Stipends, and Additional Compensation.

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F. Request to Establish Banner Fund Forms (REF) for Grants and Contracts are required to set up a Banner fund. After receiving notice of award and/or receipt of funds, an REF Form must be submitted to ORSP for routing through the Controller's Office. ORSP must have a copy of the award notice, grant terms and conditions, and a detailed budget (either agency approved or internal for fixed-price awards) before the REF will be processed.

The REF also serves as a vehicle for the PI/PD to acknowledge and accept responsibility for the programmatic and fiscal management of the grant or contract. These are outlined in the TAM section E., Responsibilities of the PI or PD.

The PI/PD receives a copy of the form once all signatures have been obtained and a Banner fund number (FOP - fund, organization, program) has been assigned.

As soon as the PI/PD completes the required new award orientation session with ORSP staff and receives the grant FOP number, funds may be expended within the grant period and according to the sponsor and SFA-approved budget.

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G. Budget Set-up and Revision Forms (BUD) are used in two instances: 1) to set up the initial project budget using SFA account codes; and 2) to request a budget revision during the grant period. The form aids in translating the budgets submitted to the sponsor into SFA budget categories. They also detail budget revision requests and accompany a Revision Clearance Form (RCF) for any budget changes.

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H. Cost Transfer Request Forms (CTR) for grants and contracts are used to request the transfer of allowable and allocable charges to/from one fund to another. Acceptable purposes may include clerical errors, inappropriate charges, late awards or pre-award costs, or transfers among interrelated projects. Not all transfers are appropriate or allowable. Incomplete forms or forms with inadequate justification or documentation will be returned to the PI/PD or other fund manager. For more information, refer to Budget Management. Sample Completed CTR Form

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I. Revision Clearance Forms (RCF) are used to obtain ORSP review and approval of project and budget revisions or amendments that require internal review and/or sponsor approval. ORSP must review all amendments that require sponsor approval or that will require budget modifications. If you are not sure if sponsor approval is required, please contact ORSP.

The following revisions are typically required for federally funded projects and must be reviewed by ORSP before they are submitted to the sponsoring agency (ORSP submits most amendments to the sponsor):

• Change a project's scope or time line;

• Change in PI/PD or other key personnel, such as the absence of a PI/PD for more than three months or the reduction of PI/PD effort by 25% or more; and

• Budget changes, such as addition of a new budget line item, moving funds between line items, additional or different equipment, changes in indirect cost matching, etc.

For any budget change, ORSP must receive the revised budgets to enter into the Banner accounting system and to coordinate the changes with grant accountants.

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J. Research Gift Notification and Statement of Compliance Forms (RGN) are used to notify ORSP that a gift designated for research purposes has been received by the Office of Development. This notification helps to ensure that SFA is accurately recording and reporting research expenditures, which in turn increases state research funding to the University from the Research Development Fund. The form is also used to inform gift recipients of potential compliance requirements associated with research conducted using a gift award.

All gifts must be coordinated through the Office of Development.

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K. Contract Request Forms (CRF) are used to request assistance from ORSP to develop a grant-related subaward or contract. The form requests standard information that is needed to complete an SFA contract template. Alternately, a PI/PD may select a contract template (see link below) and develop the contract themselves. Regardless of who develops the contract, ALL contracts must be reviewed and routed to General Counsel by ORSP. (Refer to section IX. D. Developing Subawards and Subcontracts.)

Contract Templates

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L. Grant Mailing Request Forms (GMR) are used to request that paper copies of grant applications be mailed by ORSP, rather than the PI/PD. If they are to be mailed by ORSP, copies of all documents required for submission must be received by ORSP by noon the day before the submission deadline (earlier if the deadline is before noon).

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IV. Compliance and Safety in Research

A. Introduction: Ethics in the conduct of sponsored projects

Stephen F. Austin State University (SFA) strives to create a climate that promotes faithful adherence to high ethical standards in the conduct of scientific research, scholarship, and creative activities without inhibiting the productivity and creativity of the academic community.

Faculty scholars and other personnel at SFA 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, including maintaining an auditable record of experimental protocols, data, and findings.

Misconduct in research or scholarly/creative activity is a major breach of the relationship between a faculty or staff member and the University. Co-authors on research reports or scholarly/creative works of any type must have a bona fide role in the research or scholarly work and must accept responsibility for the quality of the work reported.

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: SFA Policy A-31.5, Misconduct in Research and Scholarly Activity

A Principal Investigator (PI) or Project Director (PD) should have no conflict of interest that would affect the conduct of a project.

SFA's 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 activities to any entity, ensures that there is no reasonable expectation that the design, conduct, and reporting of research will be biased by any significant financial interest of a PI/PD responsible for the research or other sponsored activity. Based upon federal regulations and the University's objectives to maintain an 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, Conflict of Interest in Sponsored Activities

SFA also has adopted the Collaborative Institutional Training Initiative training modules (CITI) for Responsible Conduct in Research (RCR), and strongly encourages the use of CITI training modules for IRB and IACUC members.

Biosafety Considerations - Individuals proposing research projects that 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 (see section IV.F.) and/or ORSP for further information.

Compliance and safety in research also applies to research activities funded by gifts.

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B. Responsible Conduct of Research (RCR)

In compliance with the National Science Foundation’s (NSF) policy in response to provisions of the America COMPETES Act, SFA developed a plan to provide appropriate training and oversight in the responsible and ethical conduct of research to undergraduate students, graduate students, and postdoctoral researchers participating in NSF-funded research.

Training is applicable to all new NSF awards applied for and/or received after January 1, 2010.

Each individual subject to this requirement will be required to complete the free, online RCR course offered by the Collaborative Institutional Training Initiative (CITI).

CITI web site
RCR Training Verification Form

The Principal Investigator (PI) or Project Director (PD) is responsible for ensuring that the appropriate topic(s) for the on-line training program are completed in a timely manner and that the appropriate documentation is forwarded to the Office of Research and Sponsored Programs for record retention.

Discipline-specific RCR topic areas include: biomedical; social & behavioral research; physical sciences; humanities; engineers; and administrators. The RCR topic areas include: research misconduct; data management; conflict of interest; collaborative science; responsible authorship; mentoring; peer review; lab animals; and human subjects.

The PI/PD is encouraged to provide mentoring to students in the following areas as applicable to the specific research or program design in addition to the online program and to refer the student to applicable resources (SFA policies, procedures, committees, etc.):

• Data acquisition, management, sharing, and ownership;

• Publication practices and responsible authorship, and collaborative research;

• Conflicts of interest;

• Human subjects protection;

• Animal use and care/animal welfare; and/or

• Research misconduct.

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C. Protection of Human Research Subjects (IRB)

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

Many agencies require documentation of IRB approval, or that the IRB process has been initiated, in the funding application.

Copies of IRB approval letters and/or e-mails for all externally funded projects must be provided to ORSP.

IRB Committee
IRB-H - Application for Approval of Research Involving Human Subject
SFA Policy A-62, Human Research Subjects Protection
SFA Policy A-72, Payments to Human Research Subjects

IRB Chair: Dr. Pauline Sampson (effective June 1, 2011)
Phone: 936.468.2908, SFA Box 13018, sampsonp@sfasu.edu

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

U.S. Department of Education's web site on protection of human subjects in research.

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D. Animal Care and Use (IACUC)

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 must be 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 (Section IV. G.). The use of radioactive materials in animal research must be approved prior to submission of a research protocol to the IACUC.

Most federal agencies require that protocols using animals be reviewed and approved by the IACUC prior to submission.

IACUC Committee
Animals in Research Protocol - Application for Approval of Research Involving Animal Subjects
SFA Policy A-77 - Institutional Animal Care and Use Committee (IACUC)

Committee Chair: Dr. Chris Comer
Phone: 936.468.2317, comerce@sfasu.edu

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

Guide for the Care and Use of Laboratory Animals, Eighth Edition, NIH
Office of Laboratory Animal Welfare (OLAW) web site, Public Health Service
IACUC.org web site for guidance on the protection of animal subjects in research

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E. Export Control Regulations

Export control regulations are federal laws that prohibit the unlicensed export of certain goods, products, or information for national security and to protect trade. The interpretation of these regulations requires a certain level of expertise because they require classification of commodities, and export and licensing determinations.

Export controls are usually associated with the destination of the export (country, organization, etc.) and the potential use of the export (military or economic use). Exports can occur through shipping, oral communications, written documentation (including e-mails), and visual inspections of any technology, software or technical data to any non-U.S. citizen, whether here in the U.S. or abroad. 

Most, if not all, research activities at SFA are exempt from export control regulations because the results meet the definition of fundamental research (e.g., the results will be in the public domain, and published or otherwise shared broadly in the scientific community).

Export Administration Regulations (EAR) - U.S. Department of Commerce
http://www.access.gpo.gov/bis/ear/ear_data.html  (Commerce Control Database or List)

International Traffic In Arms Regulations (ITAR) – U.S. Department of State
http://www.pmddtc.state.gov/regulations_laws/itar_official.html (Defense-related items/services)

However, you must contact SFA’s General Counsel to determine if you have an export control issue if one or more of the following applies to your research:

• You are working on controlled proprietary technology found on the EAR or ITAR lists (you must have a plan to limit access to U.S. citizens and foreign nationals with a green card).

• You have a foreign national working with controlled proprietary technology found on the EAR or ITAR lists.

• SFA accepts any restrictions on the publication of the information resulting from the research, other than limited prepublication reviews by research sponsors to prevent inadvertent divulging of proprietary information provided to the researcher by sponsor or to ensure that publication will not compromise patent rights of the sponsor;

• The research is federally funded and specific access and dissemination controls regarding the resulting information have been accepted by the University or the researcher.

• Project staff will travel abroad or will ship items abroad.

Travel outside the U.S. also can present export control issues for SFA employees, specifically if you take items from work such as lap tops, data, technology, blueprints/schematics, and similar items. The destination country and the individuals or entities you interact with also may present export control issues and may require a license from the Departments of Commerce, State, or Treasury. Shipping certain items outside the U.S. also could require a license.

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

General Counsel: Damon Derrick
Phone: 936.468.4305, derrickdc@sfasu.edu

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F. Biosafety and Select Agents

Select agents include biological agents and toxins that have the potential to pose a severe threat to public health and safety or pose a potential threat to animal and plant health or to the safety of animal or plant products. These items are regulated by the Centers for Disease Control (CDC) and the U.S. Department of Agriculture (USDA).

Select Agents and Toxins List

Biosafety Committee - Research involving biohazards, such as novel recombinant DNA, blood-borne pathogens, and carcinogens (including select agents) requires protocol review in compliance with National Institutes of Health (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

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G. Environmental Safety and Health/Radiation

The University's 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.

There are two additional safety officers that can provide information regarding environmental safety, emergencies, and the handling and disposition of hazardous materials.

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, higginsjkg@sfasu.edu

Hazardous Materials and Chemical Removal
Contact Officer: Sunil Chithiri
Phone: 936.468.6034, chithiris@sfasu.edu

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V. Regulations, Policies, and Procedures

A. Role of University Offices in Sponsored Projects

• Office of the President - Delegates responsibilities of the authorized certifying official (organizational representative) to approve applications and accept external awards; signs all contracts; approves application before submission

• Office of the Provost/Vice President for Academic Affairs - Reviews and approves approves applications before submission and contracts

• Office of the General Counsel - Reviews all grant-related contracts and modifications; legal consultations and opinions

• Office of Development - Consultation and review of proposals to private sponsors and from the SFA Foundation; accepts and processes gifts

• Office of the Controller - Banner fund set-up; project invoicing; financial monitoring and reporting; and maintenance of financial records

• Human Resources - Employment and benefits, including management of Electronic Personnel Action Forms (EPAFs)

• Internal Auditor - Coordination of internal and external audits

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B. ORSP and Grant-related Procedures

The following are categories of procedures related to the processing of grants, contracts, and other types of external awards. Each is linked to the appropriate indexed section(s) of this manual.

1. Proposal Processing and Submission Procedures
   Primary ORSP contact: Ashley Gillespie

2. Contracts to SFA
   Primary ORSP contacts: Jennifer Hanlon and Carrie Brown

3. Award Process: Request a fund and award orientation
   Primary ORSP contacts: Ashley Gillespie (award orientation) and Carrie Brown (grant funds)

4. Project and Budget Amendments
   Primary ORSP contacts: Jennifer Hanlon and Carrie Brown

5. Subawards, Participant Agreements, and Contracts for Services
   Primary ORSP contacts: Jennifer Hanlon and Carrie Brown

6. Budget Management
   Primary Controller contact: Letitia Hamilton; Primary ORSP contact: Jennifer Hanlon

7. Effort Certification and Training (time and effort reporting)
   Primary ORSP contacts: Jennifer Hanlon and Carrie Brown

8. Internal Grants (Faculty Research Grants and minigrants)
   Primary ORSP contact: Carrie Brown

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C. Responsibilities of the Principal Investigator (PI) or Project Director (PD)

Awards from external sources (grants, contracts, and cooperative agreements) are made to SFA, not the PI or PD who prepared the proposal.

The President of SFA, or his/her designated signature authority, is the only individual who can commit the University to the terms of a sponsored agreement, as indicated by the approved signature on a proposal or a contract.

Pre-award: A PI or PD should notify ORSP as early as possible in the application/proposal phase so that ORSP staff can assist with the proposal. Specifically, the PI/PD should complete the following prior to project submission:

• Provide ORSP with program guidelines and other information required for successful submission of the proposal by ORSP.

• Develop a budget with assistance from ORSP that meets sponsor and university requirements.

• Complete a Proposal Clearance Form (PCF) and submit with the proposal and other forms as needed (ICW, CSR); obtain chair and dean signatures and route to ORSP no later than three working days before the due date.

Post-award: The PI/PD has overall responsibility for the successful conduct of the project, including the responsibility to:

• Conduct the project according to the terms outlined in the agreement, agency guidelines, and applicable regulations;

• Adhere to compliance requirements (such as human or animal subjects in research and responsible conduct of research);

• Monitor subawards and subcontracts;

• Adhere to the budget as approved by the sponsoring entity;

• Complete interim programmatic reports in a timely manner;

• Monitor grant funds regularly to ensure that all charges, both salary and non-salary, are appropriate to the award (reasonable, allowable, allocable) and directly support the project's objectives or scope of work;

• Process cost transfers, budget and project amendments, and “no cost extensions" (NCE) through ORSP;

• Develop and submit technical and programmatic reports;

• Report and certify effort accurately, including cost-shared effort; and

• Establish and maintain contact with the program officer, as applicable.

Close-out: The PI/PD has the responsibility to:

• Complete final programmatic reports in a timely manner;

• Reconcile grant budgets, including account-level overages and budget overruns;

• Involve of ORSP in the preparation and submission of sponsor-required close-out documents (equipment disposition, intellectual property, etc.); and

• Maintain project records for the required time (a minimum of three years after formal closing of the project by the sponsor) and correct disposition of equipment.

The language that follows is found on the Request to Establish a Banner Fund for Grants and Contracts (REF), which is signed by the PI/PD:

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 I am responsible for ensuring:

• Project expenditures are directly related to the project, reasonable, allowable, allocable, 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 certified 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; and

• 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.

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D. SFA Policies Governing External and Internal Funding

Research and sponsored project funds awarded to and administered by SFA must conform to university policies and guidelines, as well as those of the sponsor. Projects where SFA is a subawardee are subject to applicable policies of the prime sponsor, as well as whatever other terms and conditions are specified by the entity that provides the funds to SFA.

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E. Federal and State 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 federal requirements. Be sure to check the award document and/or check with state funding entities for any specific additional requirements.

These compliance requirements include:

• Statutory Requirements, which are created when laws are enacted. These requirements take precedence over all other policies and regulations related to sponsored projects.

• Office of Management and Budget Circulars (OMB) for government-wide sponsored project management.

• Uniform Grant Management Standards (UGMS) for state-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 federal regulations that provide guidance in the financial and programmatic management of awards to universities:

2 CFR Part, 220 (OMB Circular A-21), Cost Principles for Educational Institutions - 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.)

2 CFR Part, 215 (OMB Circular A-110), Uniform Administrative Requirements for Grants and Other 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).

OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations, March 2011 Compliance Supplement

EDGAR - Administrative regulations for the U.S. Department of Education grants.

FAR - Federal Acquisition Regulations 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 Federal Demonstration Project (FDP) terms and conditions (FDP is not applicable to SFA). Federal contracts typically incorporate all of the FAR clauses applicable to a given project.

OMB Circular Side-by-Side Allowable Expenditures - TEA

Allowable, Allocable, and Reasonable - Quick decision guide to allowability of federal expenditures

State Regulations and Guidelines - Each state agency provides regulatory guidance in requests for proposals, in award documents, and/or in contract terms. In addition, the Governor's Office has adopted standards that apply to most grants and contracts awarded by state of Texas agencies. In practice, they apply OMB Circular A-21 to universities.

UGMS - State of Texas Uniform Grant Management Standards (UGMS)

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VI. Internal Grant Funding

A. Research Enhancement Program (RHP)

The purpose and guidelines for the management of the Research Enhancement Program (RHP) are outlined in SFA policy A-39. RHP funds are managed by the director of the Office of Research and Sponsored Programs. Guidelines for the award of RHP funds are developed by the University Research Council (URC, see section VI.D).

Research proposing the use of human subjects, laboratory animals, or hazardous materials must be submitted to the appropriate university committee for approval prior to the initiation of the research project. In addition, projects awarded through the RHP must conform to all other applicable SFA policies and guidelines, and local, state, and federal regulations.

There are two categories of RHP awards: 1. Faculty Research Grants (FRG, annual competition) and 2. Minigrants (MG, open submission).

To assess effectiveness of awards, each recipient should provide to ORSP any time there is a presentation, publication, or grant that is a direct result of a Research Enhancement Program award.

Sample Reporting format for 2008-2010 awards

1. Faculty Research Grants (FRG)

Faculty Research Grants provide substantive support for research and scholarly/creative activities. The annual competition is held during the spring semester. Based on recommendations of the University Research Council (URC), with approval of the Provost/VPAA projects are funded for the upcoming fiscal year. In alternate years (2011, 2013, 2015, etc.), faculty may apply for a two-year award. The amount of awards vary with the scope of each project, although awards typically average $17,000 (including faculty summer salary).

Faculty Research Grant funds must be expended in accordance with the approved budget and all FRG activities and expenditures are subject to applicable state and federal laws and regulations, as well as university policies and procedures.

The general time line for FRG competitions is as follows:

January - February: Faculty prepare project drafts and receive input from faculty, ORSP and the URC members.
March: Faculty receive administrative approval (chair, dean) for proposals and final format review by ORSP.
Friday before Spring Break: Final, signed copies due to ORSP from the deans.
April: Proposals are reviewed by the URC and funding recommendations presented to the Provost/VPAA for approval.
By May 15: Faculty are notified of proposal status.
July: The SFA Board of Regents approves the annual budget, which includes funding for the RHP.
August - September: Faculty receive final award information and attend a brief orientation session.
September 1 - August 31: Term of awards.

Competition Information and Forms

FRG Panel Discussion: 2013 competition - TBD
2013 Application Guidelines and Evaluation Criteria
2013 Application Cover Page
Application Checklist
2013 Competition Deadlines & 2012 URC Members

Tentative deadlines for the FY 2013 award cycle are:

• Friday, February 10, 2012 - Principal Investigator submits one complete copy to the appropriate academic department chair(s); may submit a copy to the Office of Research and Sponsored Programs (ORSP) for review of content and format. No administrative signatures are required at this stage.

• Friday, February 24, 2012 - Department chair submits one signed copy to ORSP and one signed copy to the dean, unless additional copies are required for college committee review. Project directors or chairs should contact their dean to determine how many copies are required.

• February 10 - March 9, 2012 - During this time frame the Chair, Dean and college committee (if applicable) review the proposal content and provide feedback to the PI. ORSP is available to review proposals for content through February 28; after that time ORSP only reviews proposals for format.

• Friday, March 9, 2012 - ABSOLUTE DEADLINE - College dean submits 12 copies of the final proposal to ORSP (for the Research Council) and keeps 1 copy for their file.

FRG Awards Listed by Fiscal Year

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2. Minigrants (MG)

Minigrant awards are provided to help faculty members with unforeseen expenses in creative and scholarly work, to enhance research opportunities for faculty members by supporting innovative research, and to serve as seed money to increase a faculty member's competitiveness in the acquisition of external funds.

There are several minigrant programs at SFA.

The first two programs are managed by the Provost/VPAA, and provide support that targets innovation in instruction and research involving undergraduate students and excellence and innovation in assessment: Click here for a link to the Provost's minigrant guidelines and application process.

The third is administered by ORSP using Research Enhancement funds.

Faculty members may apply for a single minigrant award of up to $2,500 annually, or multiple awards not to exceed $2,500 in a single fiscal year. Except in unusual circumstances, a faculty member can not receive a FRG, MG, and RDP award in the same fiscal year.

Minigrant funds must be expended in accordance with the approved budget and are subject to all local, state, and federal regulations, as well as university policies and procedures.

Proposals are accepted any time, but the funds must be expended in the semester indicated in the award notice. All funds must be expended prior to August 31st of each fiscal year.

When preparing budgets for MG applications, please consider the costs of fringe benefits and include estimates of shipping and handling costs for equipment requests in your budget, as applicable. Note that there are restrictions on the amount and purpose of travel awards.

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

Minigrant Application and Guidelines

MG Awards Listed by Fiscal Year

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B. Research Development Program (RDP)

The purpose of the Research Development Program and guidelines for the management of Research Development Funds are outlined in SFA policy A-65. RDP funds are managed by the director of the Office of Research and Sponsored Programs. Priorities for the award of RDP funds are based on a Research Development Program plan developed with input from deans, chairs, faculty, and members of the University Research Council (URC, see section VI.D).

Funds are provided by the Research Development Fund, created through HB 3526, (78th Regular Texas Legislative session), provides funding to promote increased research capacity at Texas academic teaching institutions.

This purpose of these funds differs from the Research Enhancement Program in that they are used for new, emerging, and innovative research and interdisciplinary collaboration< with individuals or entities that increase the University’s ability to obtain outside funding for research. Requests for RDP funds must address the purpose of the Research Development Fund (i.e., to increase the research capacity of the University; therefore, proposals which would benefit or address only the research interests of a single individual will not ordinarily be considered for funding.

How do I request RDP funds? Faculty members should submit ideas and/or requests for RDP funding to the dean of their college. Equipment purchases that benefit multiple research faculty and lines of inquiry, and that support the Research Development Plan for the University, have the greatest potential for funding.

Please submit questions about the RDP funds to brownch@sfasu.edu.

* All RDP awards are contingent on appropriation of funds by the Texas Legislature.

RDP Award Reporting Form
RDP Awards Listed by Fiscal Year

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C. University Research Council (URC)

The University Research Council, chaired by the director of the Office 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 Faculty Research Grants.

Of the ten URC 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.

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 for three years. A vacancy on the Council is filled either by election or appointment, whichever is applicable to the position vacated.

The URC meets approximately six times a year to advise ORSP on research-related topics and to evaluate and award Faculty Research Grants.

URC Committee Information and Roster

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VII. Find External Funding

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.

Externally funded grants and contracts provide a number of benefits to individual faculty members, as well as to SFA. These benefits include:

• Undergraduate and graduate student support (research experiences, salaries, scholarships, tuition support, etc.);

• Equipment, chemicals and reagents for research laboratories;

• Operating supplies;

• Support for curriculum development and public service activities;

• Project-related travel;

• and Faculty and staff salary support.

In addition, grants bring recognition and prestige to SFA and to faculty members and provide support for and evidence of research, scholarly/creative, and/or service activities for faculty tenure and promotion.

External funding can help faculty members accomplish their professional goals in several ways.

• External funding provides a record of research and involvement in activities that advance a field of study, and builds a vita considered in promotion and tenure decisions.

• Externally funded projects can address a need or solve a problem. There are external funding programs to support a variety of activities across many disciplines.

• External funds can provide the financial means to support a project, interest, and/or program of research.

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Locating funding and matching your project ideas to a funding agency's needs can be a challenge. There are a variety of online publications, searchable databases, and funding notice listservs that can be useful in a grant opportunity search.

ORSP pre-award staff can help you locate external funding review program guidelines and proposal application materials once a potential funding agency and/or program has been identified. See the following section (C) for additional information.

It is highly recommended that you review the following to determine if a funding agency announcement is appropriate for your project:

• Applicant eligibility requirements;

• Agency funding priorities;

• Time line for the project;

• Allowable expenditures and average award;

• Cost-sharing or matching requirements;

• Type and extent of reporting requirements; and

• Possibilities for subsequent funding.

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Federal Resources

There are a number of federal grant resources. The web site, www.Grants.gov, offers a listing of opportunities by agency and is a centralized site for downloading grant application packages for submission in the Grants.gov system. There are subscription listservs, open to anyone, that can be personalized to an individual's interests.

In addition, federal agencies post grant information and grant guidelines specific for grants they fund on their websites. Here is a partial listing of federal agencies that offer sponsored project opportunities:

• National Science Foundation (NSF): Find Funding

• NSF Proposal and Award Policies and Procedures Guide (pdf), October 2010 (effective January 18, 2011)

• National Institutes of Health (NIH): Find Funding

• NIH Grants Policy Statement:10/1/10

• U.S. Forest Service (USFS): Research and Development

• U.S. Department of the Interior, National Park Service (NPS): History and Culture

• U.S. Department of the Interior, Fish and Wildlife Service (FWS): Grants-at-a-Glance

• U.S. Environmental Protection Agency (EPA): Grants and Funding

• U.S. Department of Agriculture (USDA) National Institute of Food and Agriculture (NIFA): Grant Search

• USDA Current Research Information System (CRIS)

• Gulf Coast Cooperative Ecosystems Study Unit (GCCESU) - The GCCESU serves to facilitate grant applications to federal agencies for member institutions with a reduced IDC rate of 17.5% MTDC.

• U.S. Department of Education (ED): Find Funding

• Grantmaking at ED

• U.S. Department of Health and Human Services (DHHS): Grants/Funding

• National Endowment for the Humanities (NEH): Apply for a Grant

• National Endowment for the Arts (NEA): Grant Resources

• Institute of Museum and Library Services (IMLS): Grant Applicants

American Reinvestment and Recovery Act (ARRA) Funding

• Individual agency links to ARRA grant opportunities: http://www.grants.gov/applicants/recovery.jsp

• ARRA Grant announcements: Go to http://www.grants.gov , then click on “Recovery Act Opportunities.”

• New or modified ARRA opportunities: Click here

State Resources

There are a number of state grant resources and several agencies offer listservs for grant notifications. Several agencies post grant information and grant guidelines specific for grants they fund on their websites. Here is a partial listing of state agencies that offer sponsored project opportunities:

• Texas Higher Education Coordinating Board (THECB): Research and Project Grants

• Texas Education Agency (TEA): Grant Resources

• Texas Parks and Wildlife (TPWD): Grants and Assistance

• Texas Commission on the Arts (TCA): Grants Information

• Texas Historical Commission (THC): Grants and Economic Incentives

• Texas Department of Assistive and Rehabilitative Services (DARS): Grants and other Funding Opportunities

Private Resources

If you are seeking cash gifts designated for any type of research, unrestricted cash gifts, or donations of equipment and other non-cash items used in research, you should contact the Office of Development.

If you are seeking private grant funding from individuals, foundations, and/or corporations, contact ORSP for assistance. Note that some foundations limit the number of applications that can be submitted from an institution, so coordination is essential. Also, some proposals are best submitted by the SFA Foundation rather than the University. ORSP can help you with that decision.

For help finding potential sources of private grants, contact:

Office of Development/SFA Foundation
(936) 468-5406
Development Staff

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VIII. Apply for a Grant

A. Proposal Processing and Submission Procedures

Administrative Review and Clearance Process - All external funding proposals must be approved in advance of submission by the appropriate department chair, college dean, vice president and the President. No grants, contracts, or other agreements should be submitted to a sponsor without the prior approval of the President or delegated authority.

Deans and academic chairs/directors are responsible for reviewing grant proposals and contracts and for assuring that the proposed commitments of unit resources are feasible and realistic and that they support the mission of the university. This includes confirming that the following are appropriate, as applicable: (1) faculty and/or staff time commitments; (2) cost-share or matching commitments; (3) use of university facilities; (4) required facility modification or remodeling; and (5) overall cost of equipment to be purchased, including shipping, set-up, and maintenance.

• Prior to routing the Proposal Clearance Form (PCF) and attachments, ORSP reviews all proposal budgets and abstracts.

• Given sufficient time (at least five days), ORSP will assist in the review and editing of proposals.

• The University will not authorize the submission of proposals with budgets that do not meet university requirements.

• The University will not authorize the submission of proposals that ORSP staff, department chairs, deans, vice presidents, and/or the President consider substantially incomplete (non-responsive to the sponsor's RFA/RFP requirements).

• Principal Investigator / Project Director Eligibility Guidelines

If a proposal reaches ORSP with insufficient time for review, or is submitted without prior administrative approvals, ORSP will perform a post-submission review and make the sponsor aware of any needed revisions. Proposals with serious deficiencies may be withdrawn.

For a proposal to be cleared for submission, the Principal Investigator (PI) or Project Director (PD) must submit the following items to ORSP at least three (3) days prior to the date the proposal is due to the sponsor or at least four (4) weeks before the planned start of a contract term:

• A completed (signed through the dean level) Proposal Clearance Form (PCF) with internal budget, cost-share detail, and IDC reduction/waiver request forms attached, as appropriate;

• A final budget that meets university and sponsor requirements; and

• A final or final draft proposal or contract that meets sponsor guidelines.

Electronic Submissions - ORSP submits all applications on behalf of the University, including those submitted electronically (by e-mail or web-based systems). Common web-based systems include:

• Grants.gov

• U.S. Department of Education E-Grants

• National Science Foundation's FastLane

• National Institutes of Health

• Texas Education Agency (e-grants and TEASE)

• Texas Higher Education Coordinating Board

• Hogg Foundation

• Texas Commission on the Arts

• Greater Texas Foundation

Some tips for a successful electronic submission:

• Indicate on the PCF if an application must be submitted electronically.

• Provide ORSP pre-award staff with the program solicitation and/or link to the on-line application, guidelines, and forms. This will allow ORSP staff to preview requirements to ensure a timely and successful application.

• Contact ORSP pre-award staff as soon as possible to 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, PIs and PDs 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 plan to have your application submitted electronically several days before the due date.

• ORSP pre-award staff can help you prepare grant-related documents for uploading into the electronic system prior to submission, can monitor the status of submitted proposal components, and can provide electronic confirmation of proposal submission.

• A cover page with original signatures may need to be submitted after the electronic submission is completed.

• Signed certifications (provisions and assurances) may not be requested by the sponsoring agency until the project is under consideration for funding.

Some additional tips:

• SFA is already registered in Grants.gov - please do not attempt to register for SFA in that system.

• SFA already has a DUNS number - please do not request another DUNS number for the University.

• SFA is already registered in the Central Contract Registry (CCR) - please do not attempt to register SFA in this system.

Copying and Mailing Paper Applications - In instances where a proposal must be mailed, the PI/PD is responsible for making copies and sending the proposal package to the agency. ORSP will provide assistance when requested (please complete a Grant Mailing Request Form to ORSP), but it is the project director’s responsibility for all costs associated with copying and sending to the agency.

All online and paper submissions require prior approval of the Provost/VPAA and the President and require a Proposal Clearance Form. Some applications also may require that a signature page signed by the Authorized Organizational Representative (the SFA President or delegated authority) be submitted after completion of the online submission.

Provisions & Assurances and Terms & Conditions - Federal and federal pass-through applications and awards require that the University agree to specific provisions and assurances. Non-federal contracts and similar agreements include terms and conditions that also must be reviewed by the University's General Counsel and agreed to by the University. Only the President (or designee) may sign provisions/assurances and contracts.

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.

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B. Contracts to SFA: Development, review, and approval

Before contracts, subcontracts, subawards, consulting agreements, interagency, interlocal, cooperative agreements, or other forms of contractual agreements from another entity to SFA can be fully executed, they must be:

• Reviewed by ORSP;

• Reviewed by General Counsel (ORSP will route); and

• Signed by the President or designee (ORSP will route).

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; and

• Required departmental and college signatures, if any.

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 four (4) weeks before the start date of the contract.

• ALL contracts shall have the signature of the President;

• ALL contracts should include contact information for SFA and the contractor.

For SFA, the contact for contractual matters is:

Dr. Carrie H. Brown, Director
Office of Research and Sponsored Programs
P.O. Box 13024, SFA Station
Nacogdoches, Texas 75962

Contracts with Commercial Sponsors - A PI/PD must contact ORSP before beginning contract term and budget discussions with a commercial (private, for-profit) sponsor. These contracts often require modifications and subsequent review by legal departments on both sides. Refer to SFA policy C-9 (Contracting Authority) for more information.

Additionally, these contracts often include one or more of the following special terms or conditions:

• a fixed-price for the development of a product, provision of a service, or conduct of a research activity;

• a confidentiality provision;

• intellectual property and/or technology transfer provisions; and

• restrictions on publications.

Regardless of the source or purpose, no contracts or other binding agreements shall be executed without the signature of the President or delegated authority. Only the President has the authority to make commitments for the University.

Management Responsibilities of the PI/PD - The PI/PD is responsible for the effective management of all awards to SFA in the form of a contract (see section IX. Manage a Project).

Subawardee Certifications - Subawards and subcontracts from federal sources may require completion of one or more subawardee certifications in addition to those included in the body of the contract. ORSP will obtain any required signatures.

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C. Tips for Project Planning and Proposal Writing

Okay, you're ready to begin writing - where do you start?

1. Meet with ORSP - If you have not already done so, you should set up a meeting with ORSP to discuss your project. ORSP can offer insight and assistance in developing your proposal. By contacting ORSP at the beginning of the process, ORSP staff can help make sure you have all the necessary documents in the correct format. ORSP staff can also provide suggestions and basic information for your narrative and budget, or provide suggestions if you are submitting a letter of intent. We encourage you to attend our Proposal Writing Workshops.

2. Plan your Project - Developing a project plan is an essential prerequisite to successfully finding funding for a project. The development of a project plan and proposal is an ongoing process and ORSP can help you every step of the way.

It's generally not a good idea to look for a funding agency and then tailor your project to fit the agency's needs. You may find yourself pursuing a project that is far from your original idea! Instead, develop a project outline first. A written plan can help you get your thoughts organized and can allow ORSP, project staff, potential partners, and management to provide feedback. A good plan includes the following elements, modified to reflect a research, service, instructional, or other purpose:

• How the project meets the goals of SFA;

• A statement of a need or problem;

• A description of clients and service area(s) or geographical study areas;

• Project goals and objectives;

• Methodology and activities;

• A project evaluation plan;

• Estimated resources or needs (budget);

• An estimation of future funding;

• Existing and prospective support from external sources; and

• Strategies for marketing the project to partner and sponsors.

While developing the plan, you should consider the following:

• Does SFA have the infrastructure and expertise to conduct this project (or will partnerships be beneficial)?

• Will more space be needed or any special equipment?

• Is SFA making good use of its resources in the proposed project?

• Does the project constitute a duplication of services?

3. Search for Funding - Requests for Proposals (RFPs), Applications (RFAs) and Program Announcements (PAs) are solicited proposals that normally include representations and certifications to be completed and executed by the University and may include contract terms and conditions. Most of these have firm deadlines applicable to their receipt by the sponsor. Most applications to federal and state agencies are submitted on-line by the authorized organizational representative (AOR, at SFA the AOR is the President) or designee (all electronic proposals are submitted by ORSP). Some proposals may be submitted by e-mail (again by ORSP) or by mail.

A copy of the entire proposal solicitation instruction package (application forms and instructions) should be forwarded to ORSP when it is received by the PI or PD, 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.

4. Read the Project Guidelines - Your primary guide for proposal preparation should be the sponsor's written guidelines, information provided on a sponsor's web site, and any personal advice offered by the program officer or grant contact. The guidelines will tell you what documents you will need to include and how to format your proposal. If you don't understand something in the program guidelines/announcement, you can usually submit questions to the agency's contract or program officer (within specified time lines); however, you should be aware verbal information given to you by the sponsor is not binding, so it's always best to get everything in writing.

Typically a proposal will include a narrative, budget, and budget justification. Many agencies have prescribed formats for text, biographical data, budgets (including cost-sharing and matching), and forms. For agencies that do not have specific formats, we suggest that the project director contact ORSP for sample proposal outlines.

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D. Special Proposal Requirements

Some federal agencies require that the PI address specific areas in a proposal. For example, the National Science Foundation (NSF) requires the following: a Data Management Plan, Current and Pending Support descriptions, and a Post-doctoral Mentoring Plans.

Subrecipient Certification

Any time SFA serves as a subrecipient on a proposal, the lead institution may require SFA to complete a Subrecipient Certification Form. Most institutions will have their own standard form, as does SFA which should be used any time a subcontract/award is budgeted in a SFA proposal (SUB). This document usually requests, but is not limited to, the following information and must be signed by the University's signature authority, Dr. Pattillo or his designee. This document becomes a part of the proposal package submitted to the lead institution.

• Project title; Requested amount and project period; PI name and contact information; university information; ORSP liaison and contact information; Fiscal officer and contact information; Compliance concerns (IRB, IACUC, Hazardous wastes); Most Recent Audit; and Debarment Status

NSF Data Management Plans (DMP)

Effective January 2011, all proposals to the National Science Foundation (NSF) must contain a Data Management Plan (DMP), which describes the plans for data management and sharing of the products of research. The DMP will be reviewed as part of the intellectual merit and/or broader impacts of the proposal. This supplement is limited to no more than two pages and should describe how the proposal will meet the NSF policy on the dissemination and sharing of research results and may include the following:

• The types of data, samples, physical collections, software, curriculum materials, and other materials to be produced in the course of the project;

• The standards to be used for data and metadata format and content (where existing standards are absent or deemed inadequate, this should be documented along with any proposed solutions or remedies);

• Policies for access and sharing including provisions for appropriate protection of privacy, confidentiality, security, intellectual property, or other rights or requirements;

• Policies and provisions for re-use, re-distribution, and the production of derivatives; and

• Plans for archiving data, samples, and other research products, and for preservation of access to them.

A valid DMP may include a statement that no detailed plan is needed but there must be a clear justification. Only one DMP is needed for simultaneously submitted collaborative proposals and proposals that include subawards as they a considered a single unified project. No DMP is needed for proposals for supplementary support to an existing award. Data management requirements and plans specific to the Directorate, Office, Division, Program, or other NSF unit, relevant to a proposal are available at: http://www.nsf.gov/bfa/dias/policy/dmp.jsp. If guidance specific to the program is not available, then the requirements established in this section apply.

For more information, refer to the NSF's Award and Administration Guide.

Current and Pending Support Descriptions

Almost all government agencies require documentation of current and pending support/funding from all sponsor types (federal, state, local, and private). Most have their own form or required format and request the following information for projects that are currently funded or pending applications.

• Sponsor name; Proposal title; Amount funded and funding period; Amount of effort committed each year. (This information is required for PIs, Co-PIs (and often Senior Personnel) even if they do not receive salary support from the funding agency.)

NSF Post-doctoral Mentoring Plans

Any National Science Foundation (NSF) proposal including a postdoctoral researcher must include a one page description of the mentoring activities that will be provided to that researcher, regardless of his or her institutional affiliation. This document is a supplement and not a part of the 15-page project description. Examples of mentoring activities include, but are not limited to: career counseling; training in preparation of grant proposals, publications and presentations; guidance on ways to improve teaching and mentoring skills; guidance on how to effectively collaborate with researchers from diverse backgrounds and disciplinary areas; and training in responsible professional practices. The proposed mentoring activities will be evaluated as part of the merit review process under the Foundation's broader impacts merit review criterion.

For more information, refer to the NSF's Award and Administration Guide.

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E. Develop a Budget

Budget preparation is a critical component of grant applications and contracts. It is important that the budget section of the proposal reflect, as precisely as possible, the funding needed to carry out the project. The Principal Investigator (PI) or Project Director (PD) should neither overestimate the funds required nor underestimate budgetary needs as 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.

Budget Set-up and Revision Form (BUD) - This form is designed to help you plan your budget, including indirect costs, and translate SFA internal accounting codes to sponsor budget categories.

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E.1 Direct and Indirect Costs

Direct costs are costs which can be directly identified with your project. 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. To be eligible as a direct cost, a cost must be allocable to the project, allowable under the cost principles, reasonable, and charged consistently across the University.

On the other hand, indirect costs cannot be directly identified with your project. They include building space, utilities, and related university services, departmental administrative and clerical services, and the services of ORSP, general counsel, payroll, travel, purchasing, university security, and custodial support. In other words, all those elements essential to support sponsored activity which cannot be broken down and directly charged to a specific grant or contract.

Definitions of what are allowable and unallowable direct costs for federal projects are outlined in OMB A-21, Cost Principles for Educational Institutions (OMB A-21).

Most federal and state agencies and private entities define allowable costs specific to their grants within their respective grant guidelines. If you are uncertain or have any questions about what constitutes an allowable direct cost for an application or award, contact ORSP.

Quick Reference Guide: Allocable and Allowable Costs

Before finalizing a project budget, review the budget format, cost categories, and allowable costs for the specific funding opportunity. These will differ significantly from one sponsor/opportunity to another.

In general, categories of direct costs include:

• Salaries and Wages

• Additional Compensation

• Fringe Benefits

• Subawards and Vendor Contracts

• Equipment

• Supplies and Materials

• Travel

• Participant Costs - scholarships and stipends

• Other Direct Costs

Indirect Costs

Salaries and Wages

A project may employ current university employees or may hire new employees with the understanding that their employment is solely for the duration of the grant.

Salaries and wages should be listed by the time to be spent by each person who will work on the project, including faculty, exempt and non-exempt staff, and students (graduate and undergraduate). For faculty, professional staff, and graduate assistants, time commitments are usually expressed 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 commitments and the regular, 9-month academic year for faculty (or for 10- or 11-month appointments). Non-salaried students and casual employees are calculated based on the hourly rate times the anticipated number of hours to be committed to the project.

Sponsored activities may not result in any employees receiving compensation at a rate in excess of their authorized base salary or rate of pay. In other words, under no circumstances can anyone be paid from grants at a rate higher than their regular salary. In exceptional circumstances, exempt individuals may receive additional compensation above their base pay (see below.)

• Some agencies (e.g., NSF) limit the amount of faculty salary to 2/9 of a 9-month contract to be received during the summer months.

• For multi-year projects, the budget should take into consideration any possible salary increases.

• Direct charging of administrative and clerical staff salaries is treated as an indirect cost, although these costs may be appropriate for a major project that requires an extensive amount of administrative, clerical, or technical support. The positions and job responsibilities must be clearly outlined in the application and budget.

Grant Funded Positions

Human Resources (HR) has developed standard classifications for common grant-funded staff positions. You are required to use these classifications except as noted below.

Administrative Assistant – This classification simply uses the same job description and salary grade as other Administrative Assistants across campus. (The use of the Secretary and Senior Secretary classifications may also be used if the proposal does not warrant the level of an Administrative Assistant).

Project Coordinator – This is a generic classification used for a position responsible for coordinating the financial/operational activities of a project, without providing any technical or field-specific assistance. It is an exempt position in a salary grade 9. HR should review the general duties before this title is used in a proposal.

Associate Project Director – This is a specific classification created when a new position is awarded by a grant. This classification is used for a position responsible for assisting in directing project activities, including providing technical or field-specific assistance. Officially, the classification will be ungraded to allow for competitiveness with the market. However, unless justified, the position will be in a salary grade 7. HR should review the general duties before this title is used in a proposal.

Project Director - This is a specific classification created when a new position is awarded by a grant. This classification is used for a position responsible for overseeing the operations of a project. An incumbent in this position should be considered an expert in the field. The classification will be ungraded to allow for competitiveness with the market.

Principal Investigator

**Any other unique or specialist position created by a grant will have a specific classification created when the new position isawarded by a grant. HR should review the general duties before any unique title is used in a proposal.

Contact ORSP for more information.

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In exceptional and unusual circumstances, faculty and exempt staff may be eligible to receive additional compensation for work performed outside of normal work hours and that exceeds normal expectations as outlined in SFA policy, faculty contracts, and/or job descriptions. Non-exempt staff are not eligible to receive additional compensation - they must be paid overtime for work performed in excess of 40 hours a week.

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 and/or receive pay for work on grants during the summer months.

If warranted and approved as outlined below, extra effort expended during the conduct of sponsored projects 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 university duties. Please note that an employee cannot be paid regular salary or cost-share salary on a grant and receive additional compensation pay from the same grant.

Please review the following two policies, Compensation from Grants, Contracts and Other Agreements (E-74) and Salary Supplements, Stipends, and Additional Compensation (E-9) , as well as the sponsor guidelines, before deciding to include additional compensation in your proposal.

In summary, employees may be eligible for additional compensation if the work falls into one of two areas:

• Employee paid for short-term, incidental work on a task basis (less than one month) OR

• Employee from another department paid to provide intra-university consulting services (such as project evaluation).

Terms for the payment of additional compensation to faculty and staff must be specifically outlined in the grant application or contract and approved by the sponsoring agency. The proposal, budget, and/or budget justification must:

• Explicitly state the employee or position who will receive additional compensation;

• Describe the specific work to be performed by the employee;

• State the total dollar amount of the additional compensation to be paid;

• State the percent of additional effort or the hourly rate and number of hours being committed in exchange for additional compensation; and

• Segregate the amount of the additional compensation from regular salary expenses.

All grant or contract budgets must be reviewed by ORSP staff before they are submitted to a sponsor for consideration. This will help to ensure that they meet SFA and sponsor requirements.

The ACV must be submitted with the HR Authorization for Additional Compensation Services. The required HR authorization form must be completed before the work commences. The Director of ORSP approves requests for additional compensation after the recipient of the additional compensation completes both forms and ORSP staff have confirmed the request meets both sponsor and university policies and guidelines.

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Subawards (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.

The PI/PD should incorporate prospective subrecipient's work statements, budgets, and administrative approvals in the sponsor's format if required, 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 application.

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 calculations. Be sure to carefully read the programs guidelines, and request assistance from ORSP, as needed.

Vendor Contracts (Consultants, Lecturers, Workshop Presenters, Mentors, etc.)

Agreements to obtain goods or routine services are purchases (vendor contracts) and not subawards, and are subject to all relevant university procurement policies.

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.

Lecturers, workshop presenters, mentors and other service providers are not ordinarily considered consultants, but must be detailed in the budget to ensure sponsor approval for the proposed services.

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

• Identify the proposed consultant or service provider by name;

• Indicate the number of days to be worked and the daily rate of pay; and

• Include a curriculum vitae (only if required by the sponsor).

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

Contract Payments

Effective August 1, 2011, all payments on grant-related contracts must be approved by the Principal Investigator or Project Director (PI/PD). The process is initiated with the online Receiving Form for Purchase Orders. When the form is submitted, an email will be generated to the PI/PD requesting their approval of the payment by email to Accounts Payable, along with an invoice if required by the contract.

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Most agencies make a distinction between capital equipment, which must be detailed in line items, and minor equipment, which is generally included in the supplies and materials (or operations and maintenance, O&M) budget category.

Most sponsors accept the applicant institution's definition of capital equipment, which for SFA is defined as an 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. Unless otherwise specified by a sponsor, capital equipment is the property of the University and must be inventoried. All capital equipment purchased with federal funds must be identified as such in the institution's property records.

For more information: SFA's Department of Procurement and Property Services

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Materials and supplies, which include expendable, non-capital equipment, 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 as allowed by the sponsor.

Most federal grants generally do not allow the purchase of office furniture and other general purpose equipment unless they are necessary for conduct of the project and are specifically approved in the budget. In addition, some general office supplies are considered part of indirect costs and are not allowable without clear justification.

Note that although they cost less than $5,000, some items are controlled (e.g., cameras, computers, scanners, TVs, and all other digital equipment except cell phones and fax machines) must be inventoried.

For more information: SFA's Department of Procurement and Property Services

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Individuals who travel using grant funds must adhere to university travel policies. (See SFA policy C-49, Travel.)

Travel on official university business, including travel on grants, requires prior approval of university administration and the sponsor. In addition, many sponsors require a detailed estimate of travel plans and expenses (e.g., destinations, hotel, per diem, and transportation) in the proposal. 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 approved by a sponsor, travel to a foreign country may require additional administrative approvals.

Meal and lodging rates differ depending on whether the travel is in-state or out-of-state. Reimbursement for travel on grants is the same as for all other university business, except in instances where the approved grant application or contract specify different rates in the travel justification.

For complete information regarding university travel policies and procedures: SFA's Travel Office

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Participant scholarships and stipends are payments to students to provide financial assistance during the period of their education and training. Scholarships typically pay for tuition and fees, but also may provide for living expenses (paid as a "difference check"). Scholarship funds are classified in the Banner accounting system with account codes 775830 for undergraduate students and 775831 for graduate students. Scholarships are managed by Financial Aid.

Participant stipends are non-scholarship, non-salary support classified in the Banner accounting system with account code 775990. They require a contract with the student that outlines the terms for payment and typically include monetary support for participation in the sponsored project.

If these items are allowed by a sponsor, they must be clearly detailed in the project budget.

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Other direct costs include items that cannot be captured in any of the above categories. As appropriate for the project and as allowed by the sponsor, costs for copying, long-distance telephone calls, postage, reference books and materials, publication costs, and equipment maintenance.

Use caution in this area as some of these costs are considered indirect costs, so the PI/PD must justify the need for these items in relation to the project's scope and desired outcomes.

Quick Reference Guide: What about Food Purchases?

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E.2 Matching and Cost-sharing Commitments

Some sponsors require matching funds or cost-sharing of resources.

Although these two terms are often used interchangeably, matching funds are normally defined as cash (e.g. a percentage of the cost of a piece of equipment or cash donations from a collaborating partner). On the other hand, cost-sharing usually takes the form of contributed time and effort by the PI, PD, or other project staff - faculty release time, graduate student salaries, and student workers.

Some tips on cost-sharing and matching:

• Cost-shared or matched funds/resources must be expended or used during the term of the award.

• Do not include cost-sharing or matching unless it is required and do not cost-share or match at a higher percentage than is required.

• For federal projects, you cannot cost-share federal funds. This includes students paid through the Federal Work-Study (FWS) Program. Only use non-federal sources and only cost-share federally allowable costs.

• For all projects, do not use the exact same funds to cost-share or match more than one project. In other words, don't commit the same funds twice.

• Exercise care not to over-commit cost-shared effort or facility usage. These are areas that are examined closely by auditors.

• Unrecovered indirect costs (IDC) may be included as part of cost-sharing if allowed by the sponsoring agency.

• Cost-sharing and matching commitments must be honored, documented, and reported to the sponsoring agency.

Refer to OMB Circular A-110 Subpart C.23 for federal cost-share requirements.

If cost-sharing and/or matching funds are committed to a project, the PI/PD must include a detailed budget showing these funds with the Proposal Clearance Form (PCF). This detail may be provided within the proposal budget detail and/or attached using the Cost-share Detail Form (CSR). Cost-sharing and matching commitments must be approved by the department chair, the college dean, and the Provost/VPAA, and the President.

When an award is accepted that includes cost-sharing, the University is committed to formally documenting that the cost-sharing was actually applied to the project during the term of the project. If the award level is significantly lower than the requested level, a corresponding reduction in cost-sharing should be negotiated.

Upon award, and annually thereafter for multi-year awards, the budgeted amount of cost-shared salaries and wages, travel costs, and supplies and materials, will be transferred from the designated departmental fund into a Banner cost-share fund (C-S fund, 107600) specifically tied to the grant by way of a unique Banner organization number assigned to the project manager. These expenses will then be pulled from the C-S fund, providing a clear accounting record of these cost-shared transactions. Electronic Personnel Action Forms (EPAFs) are required for all cost-shared salaries and wages to pull the cost-shared salary or wage from the C-S fund for the grant.

Matching funds in the form of cash may be accounted for using this same companion cost-share fund or another, non-federal university fund that is appropriate for the stated purpose of the match. If cash is provided by an outside party to satisfy a matching commitment, it cannot be considered a gift.

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. Written documentation must be kept for such cost-sharing and may need to be submitted to the sponsor.

Suggested cost-sharing or matching items and required documentation.

Quick Reference Guide: Documenting Cost-sharing and Matching

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E.3 Budget Justifications

The budget justification is a narrative explanation of the budget and is either the first item that reviewers see or the last. The budget for the project must be directly related to the scope of work that is to be carried out during the project term.

Every item in the budget should be completely justified in the narrative as to why it is needed and how it is related to the activities proposed. If an item cannot be easily justified and supported in the body of the grant, then that item should be removed from the budget.

Some sponsors explain the detail they expect to see in the justifications. Some limit the number of pages; others do not. ORSP pre-award staff can provide you with sample budget justifications.

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IX. Manage a Grant

A. Award Process: Grant accounts, award orientation

Congratulations! You have been funded; how do you start your project?

The first step is to attend a brief award orientation session conducted by ORSP staff. In this session, ORSP will review the following information specific to each award:

• Terms and conditions of the award and other sponsor-specific requirements;

• General information about grant management (travel, personnel, etc.);

• Budget and accounting procedures;

• Reporting requirements, including effort certification and sponsor-required technical reports;

• An overview of ORSP services and the web site; and

• Any additional, project-specific information.

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. Once the PI/PD receives notification of the project account number, funds may be encumbered or expended against the project.

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B. Budget Management

• Establishing a Fund in Banner

• PI/PD Responsibilities for Budget Management

• Invoicing and Financial Reporting

• Budget Revisions

• Cost Transfers between Two or More Funds

• Insufficient Funds and Cost Overruns

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).

Establishing a Fund in Banner

Each new grant or contract must have its own fund and internal budget based on the sponsor-approved budget.

The paperwork to set up a fund for an award is processed through ORSP. Each new externally funded grant or contract must have its own fund and internal budget. A fund is set up only after receipt of a completed Request to Establish a Banner Fund for Grants and Contracts (REF). ORSP will attach the sponsor-approved budget detail to the REF. If ORSP does not have a budget approved by the sponsor that provides sufficient detail to set up a fund, a completed Budget Set-up and Revision Form (BUD) should be submitted to ORSP. This form lets the Controller's Office staff know how to allocate your award among Banner account codes (salaries, benefits, indirect costs, etc.), based on the terms of the award.

Once a fund has been established and the PI/PD has participated in mandatory new award orientation conducted by ORSP staff, the PI/PD will be provided with the grant FOP (fund, organization, program) number.

• Fund numbers for external grants and contracts begin with a "2" and range between 200000 and 269999. The first 5 digits of the fund number represent the grant number; the sixth digit is used to differentiate between single and multi-year budgets. An "R" in the second position denotes that the award is funded by the Recovery Act (ARRA).

• Unless otherwise specified on the REF, PIs/PDs are designated as the fund managers. Each PI/PD will have a unique 5-digit Banner organization number (org) assigned to them that is used for all of the external awards that they manage.

• In addition, if a PI/PD has an award that includes cost-sharing, a cost-share org will be established for the PI/PD. Unlike the instance above, these orgs are grant-specific. Note that the cost-share fund for all external awards is "107600."

A PI/PD is strongly encouraged to maintain a financial "shadow budget", which allows independent tracking of grant expenditures and comparison of expenditures in grant-approved categories with expenditures in SFA's budget categories.

Return to Budget Management

PI/PD Responsibilities for Budget Management

Expenditures, including requisitions and payments, are made under the authority of the fund manager. Fund managers can access real-time details of their grant expenditure activity through their MySFA Banner Self-Service system. In addition, "grant inception to date" details can be viewed through Internet Native Banner (INB, form FRIGITD) or through SelfService (enter the grant number only). Normally, the person in a department who has purchasing authority can also view grant account activity.

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Invoicing and Financial Reporting

Invoicing - Externally funded, restricted use, grant and contract invoicing and reconciliation is managed by the Controller's Office. The principal grant accountant, Letitia Hamilton (Accountant II, Controller - ext. 2250), is responsible for requesting payments from sponsors, reporting university matches based on information provided by the PI/PD and the Banner finance system, and preparing financial reports for sponsors. In addition, the College of Forestry and Agriculture has accounting staff that assist in the invoicing process in coordination with the Controller's Office. They are Tammy Gibson (Accountant I, Forestry - ext. 2154) and Annie Uhyrek (Accountant II, Columbia Center - ext. 6104).

Departments or individuals should never invoice sponsors. Should a project director or other party receive a check for an award, it should be promptly delivered to ORSP for processing. Normally, checks for awards should be sent to the Controller's Office at the address below:

Office of the Controller
PO Box 13035, SFA Station
Nacogdoches, Texas 75962

Financial reports are prepared and submitted by Controller's Office personnel to ensure accuracy. Please notify ORSP of requests for financial information that are in addition to those explicitly stated in the award document, or those that are part of a programmatic report, so that they can be processed in a timely manner.

Return to Budget Management

Budget Revisions

To initiate budget transfers within a grant fund, first contact ORSP to see if transfers can be requested using the Budget Transfer function of Self-Service Banner finance. This function allows the transfer of money between one existing account code to another existing account code. Once entered into the Banner system, the request will be reviewed by ORSP staff to ensure that the requested changes are allowed in the terms and conditions of the award and/or sponsor guidelines, as well as relevant agency, state, and/or federal regulations. Some changes require prior, specific sponsor approval. ORSP will not approve the addition of an account code to a fund without first verifying that the spending category has been approved by the sponsor. Once approved by ORSP, the budget transfer will appear in the Banner finance system.

Requests for budget transfers also can be made to ORSP using the Budget Set-up and Revision Form (BUD). These requests are similarly reviewed by ORSP to confirm that they are allowed in the terms and conditions of the award and/or sponsor guidelines. Once approved by ORSP, completed forms are forwarded to the grant accountant in the Controller's Office to be entered into the Banner finance system as a journal voucher. These entries are then reviewed and approved electronically by ORSP. Once approved by ORSP, the change will appear in the Banner finance system. Copies of transaction records are maintained in the ORSP and grant accountant's project folders.

No changes will be made in the Banner finance system without ORSP and explicit or implied sponsor approval.

For more information on budget revisions, see section C, Project and Budget Amendments.

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Cost Transfers between Two or More Funds

Cost transfers between funds move recorded expenditures from one fund to another. The transfer may be between a grant fund and a departmental operating fund, or between two different, but interrelated grant funds. Initial charges to an account, such as interdepartmental transfers (IDTs), are not considered cost transfers although they must still be documented, allowable costs.

Costs should be initially charged to the appropriate fund. The need for cost transfers is minimized by the regular review and reconciliation of grant accounts by the PI/PD (fund manager). Only allowable and allocable costs should be charged to a fund. Should a cost transfer be required, the following process should be followed:

Grant Cost Transfer Requests and Time Lines

• All cost transfer requests must be made using the grant Cost Transfer Request Form (CTR). Detailed justification for the transfer is required, in addition to any relevant and supportive documentation (award documents, pre-award authorizations, travel records, etc.).

• Completed forms should be submitted to ORSP. Signatures of the appropriate fund managers involved in the transfer(s) are required.

• Transfer requests should be made within 90 calendar days after the transaction was posted to the Banner finance system or within 60 calendar days from the project end date. In addition, ORSP and/or the Controller's Office may initiate cost transfers if an inappropriate charge is discovered. Late transfer requests will only be processed in extenuating circumstances, which does not include the absence of the PI/PD or other fund manager.

• Transfer requests that rectify postings to departmental or other grant funds due to delays in the execution of a grant agreement or receipt of a notice of award may exceed the 90 day limit, but should be completed within 30 days of receipt by ORSP of the delayed award notice.

• Errors in original charges will be corrected regardless of the timing, but a justification for the lateness of the change request is required. All improper costs must be removed from the grant fund.

• Cost transfers within the University's fiscal year should be requested no later than July 15 of the fiscal year. Under unusual circumstances, cost transfers that involve departmental accounts and that cross the University's fiscal year may be approved up to 30 days after the end of the fiscal year. Transfers for grant funds that cross the University's fiscal years should be initiated no later than September 15 and before a final fiscal report for the grant is submitted.

• Salary cost transfers should be avoided by the timely processing of Electronic Personnel Action Forms (EPAFs) that distribute salary charges that reflect a reasonable distribution of the employee's effort.

• In the event that salary cost transfers are unavoidable, they must be processed within 90 calendar days from the date the charge was posted. Salary adjustments should be completed BEFORE effort is certified in the Banner Self-Service system. Retroactive effort certifications require extensive justification.

Review and Processing Procedures

• Grant Cost Transfer Request (CTR) forms that do not include an adequate justification for the request will not be processed and will be returned to the PI/PD for further explanation.

• Upon receipt of the CTR, ORSP will verify that the charges to be transferred are allowable and allocable to the award. Requests that are unallowable under the terms of the award will be returned to the PI/PD. In this case, the PI/PD may be required to designate an alternate fund for the transfer.

• If approved by ORSP, the CTR will be sent to the Controller's Office for review and if approved, the appropriate changes will be entered into the Banner finance system.

• Frequent and consistently late requests for transfers may result in reports to the proper administrative officials (chair, dean, provost, etc.).

Allowable Cost Transfers (see Federal OMB Circular A-21, C.)

Allowable cost transfers may include:

• Adjustments for erroneous charges and to properly allocate charges to sponsored agreements, such as correcting clerical errors.

• Requests for payroll transfers that involve salary and benefits adjustments. For state and federally funded awards, these transfers directly affect effort certifications; therefore, payroll transfers should be avoided whenever possible by the timely processing of EPAFs.

• Charges to active grant funds when the continuation of an existing award is anticipated (such as multi-year awards with pending grant award notices).

• Sponsor-approved pre-award costs with documentation that an award is forthcoming, although a pre-award grant-specific fund is preferred to pre-award cost transfers.

• Late awards or delayed Banner fund set-ups where delayed charges would negatively affect project outcomes.

• Moving charges from one interrelated project to another, provided that the charge could have appropriately been charged initially to the other grant, and the explanation provided with the CTR clearly justifies why the two projects are related (mutually beneficial).

Some transfers that are never allowable include:

• Using unexpended grant funds to pay for activities conducted for another grant award.

• Alleviating an over expenditure (overrun) on another grant fund, unless directly interrelated. See the next section for more information on cost overruns.

• Circumventing award restrictions by moving the charge to another grant fund.

• Moving charges only for convenience, including moving charges from one grant fund to free up funds in another grant.

• Shifting charges that should be charged to an agreement from a non-federal sponsor to an agreement from a federal sponsor.

Quick Reference Guide: Allowable and Allocable Costs

Return to Budget Management

Insufficient Funds and Cost Overruns

Insufficient Funds result when a PI/PD attempts to place a purchase requisition, purchase order, or other charge against a FOAP (fund, org, account, program) when there are insufficient funds in the overall fund balance.

When ORSP receives e-mail notification that a purchase transaction is in the insufficient funds queue, ORSP investigates the reason for the alert. After review of the grant's budget and award documents, ORSP will contact the PI/PD or appropriate staff to initiate appropriate actions, such as a budget revision, or will disapprove the request.

Although a sponsor may allow some flexibility in expenditures among approved budget categories, such overages at the account level (travel, personnel, O&M, etc.) within a grant fund must be adjusted. This is accomplished by the PI/PD using the budget revision process. All account-level overages should be reconciled before the end of the project term.

Cost Overruns result when the amount charged to a grant fund exceeds the available balance. This results in an insufficient funds alert in the Banner finance system.

• Cost overruns that are the result of inappropriate charges must be removed from the grant fund using the Cost Transfers between Two or More Funds procedure detailed above.

• Cost overruns occurring because charges were incurred after the end of the award term must be removed from the grant fund using the Cost Transfers between Two or More Funds procedure detailed above.

• Cost overruns will be transferred to the appropriate fund by the Controller's Office.

• Cost overruns are not to be charged to another grant fund unless directly interrelated.

• Cost overruns on expired projects should be cleared within six months of the project end date so that the fund can be closed. If necessary, the Controller's Office will initiate transfers from an expired grant fund to a departmental fund through the PIs/PDs chair and dean using the Cost Transfers between Two or More Funds procedure.

Return to Budget Management

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C. Project and Budget Amendments

• A Revision Clearance Form (RCF) is required for all budget and project revisions.

• All requests to sponsors for budget and project revisions must be submitted by ORSP unless specific, prior arrangements have been made with ORSP and the proposed revision has been reviewed and approved by ORSP staff.

Changes in Contracts - All changes to contract terms must be processed as formal amendments. Amendments are developed by ORSP and processed through General Counsel before they are signed by the President.

No Cost Extensions (NCE) - A NCE may be granted to a PI/PD in order to extend the work period without additional funding. Some federal sponsors require notification that you are taking the allowable, automatic one-year extension; others may require that SFA apply for the extension and justify any budget carry-over into the extension period. Contract extensions typically require an amendment (see above). Federal and state sponsors do not allow a NCE simply to spend any remaining budget funds.

NCE requests are time sensitive and procedures vary by sponsor. Please contact ORSP as soon as you anticipate that you will need a no-cost extension. Prior to the end of your award, you should receive a Notice of Sponsored Project End Date form that you can return to inform ORSP of your intentions.

Changes in a Project Budget - Budget changes include an increase or reduction in project budgets, such as any changes in the award total, indirect costs, or cost-sharing/matching commitments. These changes will be reflected in your project Banner fund following the procedures outlined in section B, above. If the budget change is outside of percentage limits established by the sponsor or is not in a sponsor-approved budget category, ORSP will request sponsor approval.

• If you want to revise your budget and the sponsor guidelines allow for it, you will need to request your revisions either using the Banner SelfService budget transfer process or by submitting a Budget Set-up and Revision Form (BUD) to ORSP.

• 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 without 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, 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.

• In most cases, if sponsor approval is required for a budget change, the PI/PD is responsible for requesting that ORSP submit to the sponsor a formal request in writing, either by e-mail or by formal budget amendments as required by the individual sponsor.

Supplemental Funds Request - Requests for additional funding on an existing project are processed as proposals through ORSP. You will need a revised budget, a statement of work for the additional effort, and updated certification for all compliance issues, if necessary.

Changes in a Project's Scope - Any substantive change in a project's scope generally requires prior sponsor approval and must be approved through ORSP as a formal project revision. Please complete a Revision Clearance Form, attach your amendment, and submit to ORSP with the appropriate signatures.

Changes in Project Personnel - In most instances, changes in key project personnel must be approved by the sponsoring agency or the agency must be notified. This includes changing the PI/PD or co-PI/PD, reducing the time of the PI/PD on the project by 25% or more, or the absence of the PI/PD for more than three months.

Federal Projects: When Sponsor Approval is Required - (OMB Circular A-110, C.25)

• Change in the scope or objective of the program (even without an associated budget revision);

• Change in a key person specified in the application or award document;

• The absence of more than three months, or a 25% reduction in the time devoted to the project, by the PI/PD;

• The need for additional federal funding;

• The transfer of amounts budgeted for indirect costs (IDC) to absorb increases in direct costs;

• The transfer of amounts budgeted for direct costs to absorb increases in indirect costs;

• The transfer of funds allotted for training allowances (direct payment to trainees, which includes scholarships and stipends) to other categories of expense;

• Subawards and subcontracts not approved in the application; and

• The inclusion of costs that require prior approval (such as capital equipment, furniture, etc.).

There are other instances when sponsor approval may be required, which may be detailed in specific contract or grant award provisions. Others do not, but may require that the sponsor be notified (e.g., Expanded Authorities, EDGAR, US Department of Education). Please contact ORSP if you have any questions.

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D. Subawards, Participant Agreements, and Contracts for Services: Development, approval, and management

In order to pay any entity (individual, organization, educational institution, etc.) not employed by SFA, an executed contract must be on file before the work is performed.

A Form W-9 must be on file in purchasing for a contractor/subawardee to be paid.

Before contracts, subcontracts, subawards, consulting agreements, interagency, interlocal, cooperative agreements, or other forms of contractual agreements between SFA and another entity can be fully executed, they must be:

• Reviewed by ORSP;

• Reviewed by General Counsel (ORSP will route); and

• Signed by the President or designee (ORSP will route).

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; and

• Required departmental and college signatures on the PCF and the contract, if any.

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. More time may be required if the other party requires legal review of the contract on their end.

D.1. Contract Templates - To assist in the development of contracts to subawardees, consultants and other vendors, and program participants from SFA, ORSP, in consultation with General Counsel, developed several contract templates.

Subaward/Subcontract Templates:

• Federal Subaward Agreement (federal pass through) *To a State Entity – 779780 *To a Non State Entity – 779720

• Interagency Cooperation Agreement – Subrecipient (state pass through) - 776150

Vendor Contracts:

• Interagency Cooperation Agreement (another state agency) - 772530

• Interlocal Cooperation Agreement (local government) - 772530

• Consulting Services Agreement (individuals or firms) *Consultants (evaluators, advisors) - 772400 *Guest lecturers (workshops, presenters) - 772520 *Other professional services (mentors) - 772530 *Info tech services (web developers) – 772750

• Participant Agreements (stipends and travel) - 772991 (NEW account code as of August 17, 2011)

You may use these templates to develop draft contracts that can be sent electronically to ORSP for administrative review and signatures, or you can complete the Contract Request Form and ORSP will develop the contract for you.

• ALL contracts shall have the signature of the President - ONLY the President or his designee can sign agreements on behalf of SFA;

• ALL should include contact information for SFA and the contractor.

For SFA, the contact for contractual matters is:

Dr. Carrie H. Brown, Director
Office of Research and Sponsored Programs
P.O. Box 13024, SFA Station
Nacogdoches, Texas 75962

In order for ORSP to provide you with timely and accurate contracts, please provide the following information at least 14 days in advance of the work to be performed. For agreements with other government and educational institutions, please submit information 30-days in advance as these institutions typically need time to have their legal counsel review the contract terms. If any negotiations need to occur, more time will be needed for ORSP and SFA General Counsel to work with the entity.

If the individual has or will reach $25,000 over the lifetime of all contracts with SFA, a major consulting contract request may be required. Please allow an additional 45-days for this request to be processed by General Counsel.

Regardless of the source or purpose, no contracts or other binding agreements shall be executed without the signature of the President or delegated authority. Only the President has the authority to make commitments for the University.

Management Responsibilities of the PI/PD

The PI/PD is responsible for the effective management of all awards to SFA in the form of a contract (see section IX. Manage a Project). In addition, a PI/PD is responsible for the effective management of grant-related contracts from SFA to a subawardee, consultant, vendor, and participant. These management responsibilities include:

• submission of purchase requisitions and purchase orders for payments;

• receipt, review, and acceptance of invoices; and

• monitoring of contract activities.

Subawardee Certifications - Subawards and subcontracts from federal sources (from SFA to other entities) may require completion of one or more subawardee certifications, such as (1) OMB A-133 audit certification, (2) FFATA reporting, and (3) the federal Subaward Certifications and Standard Terms and Conditions for the American Recovery and Reinvestment Act (ARRA). In addition, if SFA is the recipient of a subaward, similar certifications may be required. Contact ORSP if you have any questions about these subaward/subcontract requirements.

Effective April 1, 2011, ORSP will require subawardee certification at the pre-award stage. Additional post-award certifications may also be required.

Ten Issues to consider when developing contracts
Quick Reference Guide: Navigating Contracts

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E. Cost-sharing and Matching: Documenting expenses

Documentation for cost-sharing and matching should demonstrate that:

• It is verifiable from the recipient's records.

• It was incurred during the period of performance of the award.

• It is not included as contributions for any other project or program.

• It is necessary and reasonable for proper and efficient accomplishment of project or program objectives.

• It is allowable under the applicable cost principles.

• 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.

• It was provided for in the approved budget when required by the federal awarding agency.

• It was consistent with federal cost allocation principles (for example, cannot include costs recovered through facilities and administrative cost pools).

For more information on cost-sharing and matching, and to view a table of suggested cost-share and match categories and related documentation, see section VIII.E.2.

Quick Reference Guide: Documenting Cost-sharing and Matching

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F. Personnel Policies and Procedures

The department of the employee is responsible for completing and routing all personnel forms, including those for grant-paid employees. Please initiate completion of appropriate forms with your department's administrative assistant or other appropriate personnel.

An EPAF must be completed for all grant-paid, SFA employees. There are several types of EPAFs that are needed for grant-paid employees. These include:

• Hire (select from HIRE01-HIRE52): For new staff and student hires, select the correct category (e.g., exempt full-time staff, hourly non-exempt part-time staff, graduate assistant, etc.) hires. Be sure to use the correct grant FOAP.

• Change - Grant and Cost Share Reassignment (select CHNG51): For reassignments and transfers of faculty, staff, and students to grant projects (completed by the receiving department). Be sure to use the correct grant FOAP for each salary reassignment and the correct cost-share grant FOP for each cost-share reassignment.

• Separation (select from TERM01-TERM07): To end a job assignment (completed by the employing department).

Important tips:

• EPAFS must be completed BEFORE the employment or change start date.

• Include the end date of the appointment on the grant in the comment section. This is important because the EPAF does not require an appointment end date.

• Complete a Separation EPAF for all employees WITHIN A WEEK of the end of employment.

• Salary spreads are not allowed for employees paid from grant, contract, or sponsored projects.

• Graduate Assistants must be identified correctly on the EPAF based on their principal assignment (Research = GRA 670110; Admin. Asst = GAA 670111, Teaching = GTA 670090).

• Leave forms are used as needed for grant-paid staff employees.

• Do not use the Additional Pay (ACMP) EPAF categories for grant staff. At the current time, additional compensation cannot be initiated on an EPAF.

• Confirm that employee benefits (health insurance and retirement) and withholding (social security, workers compensation, unemployment compensation) were separately budgeted in the grant budget to ensure that EPAF amounts are accurate and the the grant fund will not be overdrawn.

Additional Compensation Request and Payment Forms

Additional compensation applies only to full-time employees. Payment for extra-duty services for a less-than-full-time employee goes on an EPAF. Note that an alternate payment method may be required for non-exempt (classified) staff eligible to earn time and one-half. Please contact ORSP for more information. See also section VIII.E.1.

Additional compensation must be outlined in the grant application, contract, and/or award document or otherwise approved in advance by all sponsors. ORSP will verify sponsor approval.

• Complete the Human Resources Authorization for Additional Compensation Services form BEFORE work begins for all exempt positions that will be paid additional compensation from a grant, contract, or other sponsored agreement.

• If not already completed at the pre-award stage, complete the ORSP Additional Compensation Verification (ACV) form and route with the HR authorization form.

• Consider employee benefits when preparing additional compensation forms. Although withholding taxes and retirement will be withheld from the payment to the employee, the state match portion of retirement will be charged to the grant fund in addition to the additional compensation payment.

• Complete and submit an Authorization for Additional Compensation Payment form either with the above authorization form to ORSP (when requesting a payment spread) or to HR after work has been satisfactorily completed (single payment).

Human Resources Information and Forms

• Employment Selection Procedures

• EPAF Instructions

• Additional Compensation Forms

• Exit Forms & Information

Please contact Human Resources, ext. 2304, if you have any questions about how to complete their forms.

Quick Reference Guide: Navigating Employment Forms

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G. Effort Certification (Time and effort reporting)

What is effort? What is effort certification?

Effort is defined as the activities, functions, or categories to which an employee directs time and energies, including instruction, sponsored projects, and departmental administration, and other effort devoted to sponsored projects for cost sharing. Effort certification reports confirm, on a best-estimate basis, the percentage distribution of effort for the period reported and serve to substantiate salary and wage charges or contributions to federal or state grants and contracts.

Effort refers only to base salary. Additional compensation is accounted for separately and IS NOT included in effort reports.

View PowerPoint (version 9.27.11)

Who must certify effort?

Any person who is paid by or cost-shares any portion of their base salary on state or federally funded grants or contracts must report effort expended on the project.

• Faculty, professional exempt staff, and graduate students must certify that the average, estimated effort on all activities over each academic term (fall, spring, and summer ) for which effort is expended on a state or federal project matches the percentage salary split for the term. Effort is certified in Banner Self-Service effective spring 2011.

• Non-exempt staff and undergraduate students must certify that the average estimated effort on all activities over each month in which effort is expended on a state or federal project matches the percentage salary split for the month. Effort is certified in Banner Self-Service effective spring 2011.

• Hourly paid staff and students report their actual time on all activities over each pay period in which effort is expended on a state or federal project. This is recorded and verified in the TimeClock Plus System and/or manual university time sheets.

Why must effort be reported?

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

Each grant or contract award budget outlines employee time committed to working on a project. To document that the commitment was honored, SFA must maintain complete and accurate records of effort expended by employees paid from a grant or contract or contributed to a grant or contract as cost-sharing.

Principal investigators or project directors are responsible for ensuring that only legitimate expenses are charged to or contributed to the grants and contracts.

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 or activity for any reason whatsoever.

Mandatory Training Requirements

SFA policy requires training in the effort certification process for all employees with payroll expenses charged to or contributed (cost-shared or matched) to externally funded grants, contracts, or other sponsored agreements subject to effort reporting requirements, and for departmental and other employees involved in the effort reporting process.

The Office of Research and Sponsored Programs (ORSP) will provide and document training activities, beginning in February 2011. Refresher courses will be required every three years.

Principal Investigators and Project Directors are responsible for ensuring that faculty, staff, and students certify effort reports, as appropriate to their position, and revisions promptly at the appropriate time interval.

Guidelines for Effort Certification

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 certification report should reflect how a person spent his or her total time (effort) proportional to each activity (teaching, research, 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 the 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%.

NEW Effort Notification Process (effective spring 2011):

Upon receipt of notification of a federal or state award or contract, ORSP sets up the grant effort certification forms in the Banner Human Resources system and establishes a cost-share Banner fund, if applicable, to account for cost-shared salaries. Reports are generated for each grant employee and are available in Banner Self-Service for certification monthly (non-exempt staff) or by semester (faculty, exempt staff, graduate students). E-mail notification is sent to the employee for electronic approval and/or to the PI or PD, who is designated as the certifying official.

Persons actually working on the sponsored project or a responsible party with direct knowledge of the employee's activities should certify reports and write and sign a full and complete explanation for any previously certified effort reports that require revision.

Changes and Corrections to Time and Effort Reports

It is important to report time and effort accurately 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 Banner fund number because the new fund was not established when the expense was incurred. (See also the cost transfer procedure.)

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.

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H. Technical Reports and Other Deliverables

The majority of externally funded projects require periodic reports, which may include progress reports (monthly, quarterly) and final reports (usually due within one month of the end of the agreement). These allow the funding agency to see detailed progress on all major tasks and track any changes that the investigator might require during the course of the work. Details on report deadlines are usually outlined in the signed agreement.

Federally funded projects typically require a final technical report with 90 days of the termination of the project, and may also require interim progress reports.

PIs/PDs 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, or formally explain why the deliverable cannot be provided.

Please submit a copy of the final project report (if less than 10 pages) to ORSP for our files either paper or via e-mail. Investigators with reports over 10 pages may submit an abstract of the report.

If you need assistance with technical reports, or if you need any financial information in connection with he report, please contact ORSP or Letitia Hamilton (hamiltonlg@sfasu.edu). Financial reports are NEVER submitted by project staff. They are always submitted by the Controller's Office.

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I. 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.

Examples of program income include:

• Conference or workshop fees;

• Income from fees for services provided during the grant term (e.g., map production or chemical analysis);

• The sale of products created under and award (e.g., books, videos, curriculum guides);

• The use or rental of property acquired under an award (e.g., equipment); and

• License fees and royalties related to patents and copyrights.

Program income is deposited in the sponsored project fund 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 fund. 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):

• Added to the federal funds and used to further eligible project objectives (always applies to research awards); or

• To finance the non-Federal portion of the project (not budgeted in the federal award); or

• Deducted from the total project 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.

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J. Sponsorship Acknowledgement 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, in particular private foundations and corporate 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 in the acknowledgement.

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K. 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 (BOR) recognizes that questions regarding intellectual property rights may arise from such activities. The BOR 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 BOR 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 SFA policy D-20, Intellectual Property.

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L. I'm leaving. Can I take my grant with me? Transfer of Awards

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 at SFA 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 SFA obligations have cleared. It takes at least 30 days after the expiration date to obtain this information.

• Have your new institution's research and sponsored programs office contact ORSP, or provide us with contact information, so we can coordinate transfer of the award.

• 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 Finance and Administration.

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

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X. Project Close-out

A. Close-out Procedures

When a grant or contract is nearing completion, it is the responsibility of the Principal Investigator (PI) or Project Director (PD) to ensure that steps are taken for close-out that are required by SFA and the sponsor.

The following actions are required for SFA:

• Submit termination or change EPAFs within one week of the end of their appointment or the end of the project (whichever comes first) for personnel paid or cost-shared on the project.

• Clear outstanding encumbrances, including ProCard encumbrances, standing purchase orders, and encumbrances for subawards and contracts.

• Correct overdrawn Banner accounts and correct fund overages by submitting a cost transfer request within the designated time frame.

Most sponsors also require specific actions for project close-out. When projects near completion, the PI/PD - in coordination with ORSP and the Controller's Office - should take appropriate actions:

• Follow sponsor instructions for positive fund balances after conclusion of the project. Are there funds that need to be returned? If not, what is the approved method for disposition of account balances?

• Submit all technical reports to the sponsor and verify that they have been accepted by the sponsor.

• Verify all required time and effort records are complete.

• Complete any additional forms or reports required by the sponsor (e.g., disposition of equipment).

• Ensure all financial and technical reports have been submitted and accepted by the sponsor.

• Verify official project close-out or release by the sponsor.

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

Before the end of each project, ORSP staff sends a Notice of Project End Date (NOPED) and conducts 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.

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B. Disposition of Supplies, Materials, and Equipment

In general, at the conclusion of a project supplies and materials purchased with grant funds remain the property of the department and/or college that received the funding. For federally funded projects, the first priority for the use of these items are other federally sponsored projects at SFA.

Inventoried equipment (of any value, capital and controlled) 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. Some federal and state sponsors include very specific requirements for the accounting of, and possible return of, inventoried equipment purchased with grant funds.

It is the responsibility of the PI/PD to know and understand the policies and procedures required for their individual projects and to record the disposition of any items for audit purposes. Contact ORSP for assistance.

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C. Records Retention, Inquiries, and Audit Considerations

Records Retention

It is the responsibility of the Principal Investigator or Project Director to ensure that project or program records are maintained for the time specified by the sponsor. Records should be clearly marked with the contents and the disposition date. The best location to keep grant records is in a departmental storage area to ensure that they are not misplaced if a faculty member leaves the employment of SFA.

According to records retention requirements of the State of Texas, grant-related documents must be kept a minimum of four years after the end of the project operiod (non-federal) and a minimum of three years after the final expenditure report has been sent to a sponsor (federal). ORSP establishes this date as three years from the formal closure of a grant fund. However, some state sponsors of federal pass-through funds may require retention periods of up to seven years.

Please work with ORSP to ensure that records are kept for the length of time required by a specific sponsor for a specific award.

For more information on records retention requirements for grtants see Grant Records Retention handout and for SFA in general, see Records Management.

Inquiries

A Principal Investigator, Project Director, and any other grant personnel who receives a request for information from a sponsor should immediately notify ORSP that an inquiry has been made, the nature of the inquiry, and the name, title, institution, and e-mail/phone number of the inquiring individual.

ORSP will, in turn, notify the Internal Auditor and/or the University's General Counsel, if warranted.

ALL inquiries and/or correspondence about an audit (formal or informal) must be directed to the Internal Auditor's office and to ORSP.

Audit Considerations

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

• Conditions of the grant are being followed.

• Matching funds have been received and cost-sharing commitments have been honored.

• Personnel paid by grant funds actually worked on the grant and have payroll and effort certification records as documentation.

• Faculty salaries paid from grants are consistent with limitations included in grant conditions, if any.

• Equipment purchased with grant funds was specifically listed, pre-approved, actually needed to conduct grant activities, and actually used during conduct of grant activities.

• Travel paid from grant funds is directly related to and supports grant activities.

• Budget transfers in excess of those authorized by grant conditions received prior approval from the funding agency.

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