Principal Investigator s Handbook

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Principal Investigator’s Handbook

Grants/Contracts Compliance Management

Policies & Procedures

for

Office of Sponsored Programs

Langston University Langston, Oklahoma 73050

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Each year, Langston University receives awards for research, training, and technical assistance from outside sources, including the federal government and private organizations. Sponsored programs are diverse and complex, and those planning a funded project should become familiar with this Handbook.

This Handbook will guide faculty, staff, and administrative officers from the development of a research idea through the submission of the proposal. In addition to answering the most common questions, this Handbook list several policies affecting sponsored programs.

Its flexible design allows occasional updating and its index enables users to locate pertinent information quickly. For additional information, call the Office of Sponsored Programs (OSP) 446-2039 or 466-2038. The Office of Sponsored Programs is the only office principal investigators need to call for most technical and procedural questions related to sponsored projects. The Office of Sponsored Programs staffs are trained to answer questions, find solutions to unusual problems, and work with principal investigators to follow existing University policies and procedures that apply to sponsored project activities. Schools and Teaching Units, however, should be contacted for questions related to university resource allocation.

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OFFICE OF SPONSORED PROGRAMS

Purpose

Federal, state and governments, along with numerous private and nonprofit entities, provide a range of funds for colleges and universities to create new programs, expand research opportunities, and undertake developmental activities that benefit both the general public and the educational institution itself. The Office of Sponsored Programs (OSP) provides services and support to encourage faculty and staff to obtain such outside sponsorship. Among its various functions, OSP:

• Serves as the University’s focal point for all external programs and as official Liaison between the University and the sponsor;

• Assists in locating potential funding sources;

• Disseminates on a routing basis information to faculty and staff pertinent to the availability of (and deadlines for) external funding opportunities for research, training and services;

• Maintains applications, source materials, bulletins, announcements and guidelines for use by faculty and staff;

• Guides faculty in preparing proposal applications, including budgets, to ensure conformity with University policy, sponsor criteria, and federal, state and local regulations;

• Negotiates terms and conditions of grants and contracts, in coordination with the principal investigator, and prepares such grants and contracts for acceptance by an official authorized to commit the University to the performance of the proposed projects;

• Prepares administrative briefs of awards for distribution to appropriate Faculty and staff;

• Maintains official University award files;

• Assists in matters relating to patents, copyrights, and publication agreements;

• Coordinates matters of compliance with regulations relating to the use of Animals, human subjects, and radioactive and hazardous materials; and

• Directs faculty in compliance with sponsor requirements regarding the Administrative (but not financial) close-out of awards

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PROPOSAL AND DEVELOPMENT ACTIVITY

A proposal is a request for external financial support of a research, training or technical assistance project. Staff in the Office of Sponsored Programs (OSP) assist faculty with some phase of proposal preparation and submission, including:

• identification of potential funding sources;

• pre-submission procedures;

• internal review, routing and approval; and

• timely submission to a sponsor.

Individuals are encouraged to contact the Office of Sponsored Programs when first considering external funding for research or training projects.

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OFFICE OF SPONSORED PROGRAMS MISSION STATEMENT

The Office of Sponsored Programs (OSP) provides a supportive, proactive, and dynamic environment for conducting research projects and sponsored programs by:

• stimulating interests in the intellectual life of the Langston University Community;

• encouraging creative approaches to the development of new opportunities;

• promoting interdisciplinary and interdepartmental cooperation; and

• fostering the enrichment of student, faculty and staff.

Office of Sponsored Programs is committed to reducing the administrative burden of faculty, administrators, and staff by providing efficient, effective and personal service. Finally, through the interaction of pre-award knowledge and skill, OSP seeks to safeguard the University by ensuring the compliance with internal and external regulations, policies and procedures

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THE PRINCIPAL INVESTIGATOR

The individual responsible for conceiving and enacting a sponsored project is known as the principal investigator. When this individual takes on the task of preparing a proposal for submission to an outside source, he or she agrees to manage the ensuring grant or contract in compliance with the terms, conditions and policies of both the sponsor and the University.

Only one principal investigator should be named to permit clear lines of responsibility for project management. In some instance, a colleague central to the project may be named co-principal investigator or be given another appropriate title.

University Affiliation for Institutional Awards

The principal investigator must be a member of the faculty, professional staff or be an administrative officer of the University. Depending on the nature of the proposal, individuals with other University appointments may serve as principal investigators with approval of that operating unit. Naming an individual in the proposal who is not already an employee of the University does not commit the institution to employing that individual.

Individual Awards

Faculty and staff members may submit proposals for individual awards and fellowships, such as the Fulbright Scholar Program. Unless specified by the sponsor, these awards generally provide remuneration for research being conducted during sabbatical leaves, leaves without pay, or in addition to regular University responsibilities. The OSP is available to assist faculty in identifying potential source of funding, obtaining guidelines and application materials, and securing letters of nomination from the University administrators when necessary.

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PROPOSAL DEVELOPMENT AND SUBMISSION RESPONSIBILITIES

In the course of developing and preparing a proposal, principal investigators, the school Dean, the Vice President for Academic Affairs, the OSP and the Office for Fiscal Affairs work together to ensure that a complete product is submitted to the sponsored agency. Specific responsibilities are delineated below.

The Principal Investigator:

• Contacts OSP at early stage of project conceptualization;

• Writes technical narrative;

• Discusses with teaching unit chair and school dean the intent to submit a proposal, its benefits and application and secure preliminary approvals;

• Secures approval of compliance committee(s) for animal subjects, human subjects, or hazardous/radioactive materials;

• Prepares capability statements appropriate to the project;

• Draft transmittal letter to the proposed sponsor;

• Compiles complete proposal packages;

• Copies proposal package and binds for submission;

• Submits proposal and copies to sponsor;

• Arranges for courier service, hand delivery, or express mail;

• Makes follow-up phone calls to monitor status of proposals; and,

• Arranges for debriefings with prospective sponsors as appropriate.

The School Dean:

• Reviews substantive content of proposal and examines proposal objectives in terms of goals of the school and teaching unit;

• Allocates cost share resources for direct and facilities and administrative cost items;

• Allocates school resources to ensure that adequate space, facilities, equipment and support services are available; and

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The Vice President for Academic Affairs

• Approves exception to academic policy ( currently only the President can approve exceptions);

• Confirms all faculty appointments with the Dean, pursuant to existing appointment procedures; and

• Reviews proposal to determine that academic and legal interests of the Universities are preserved.

The Office of Sponsored Programs:

• Identifies possible funding sources;

• Assists with development of budgets within appropriate guidelines, verifying salaries and confirming costs;

• Coordinates with the University Development Office (subcontracts, corporations, organization, etc.);

• Completes proposal forms required by the University and the sponsor;

• Coordinates the University review process, securing necessary approvals and signatures; and,

• Coordinates budget revisions and resubmissions as necessary; and

The Office of Fiscal Affairs:

• Helps to shield the University from any potential liability that might arise during execution due to incorrect interpretation of the terms or through possible negligence in the execution.

• Assist in matters relating to patents, copyrights, and publication agreements;

• Coordinates matters of compliance with regulations relating to the use of animals, human subjects, and radioactive and hazardous materials;

• Gather and maintain all the relevant documentation and information needed by external or federal auditors for completion of an A-133 audit;

• Monitors the allocation of expenses; and

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DEVELOPMENT AND MARKETING ACTIVITY Funding Sources

The identification of potential funding sources for a research, training or technical assistance project is the first step in designing a funding strategy. OSP provides a number of valuable services to faculty at this stage of securing outside support.

OSP maintains a formal information library of source material on private and federal sponsors. Many program descriptions, bulletins, newsletters, annual reports and announcement, including Commerce Business Daily and the Federal Register, are received regularly and are available for review. Faculty may request the OSP to provide a report on potential funding sources. For an overview of the general funding information publications, federal program guidelines and private program guidelines are available.

After a library review or computer search, faculty may choose one or more sponsors from whom they wish to request financial support. In most cases, copies of programs descriptions, application guidelines and application forms will be available in OSP. Otherwise, staff in the OSP will request the necessary application information from the sponsor. Individuals interested in conducting sponsored research, training, or technical assistance projects are advised to visit OSP to discuss their interests. If they advise OSP of the sponsor or approach, OSP can inform them of funding opportunities in their areas of interests as these opportunities arise.

Proposal Types

A proposal to a funding agency for sponsored research may be either solicited or unsolicited. Solicitations are usually government generated “Requests for Proposal’’ (REP) or “Requests for Quotation’’ (RFQ) on a specific research, training or technical assistance project. In such cases, the intended scope of work is predetermined by the soliciting agency and specific requirements for the format and content of both technical and cost proposals are presented in the published requests. The successful solicited proposal may result in either a contract or a grant. Government RFPs and RFQs are widely advertised (in sources such as the commerce Business Daily) and are monitored regularly by OSP staff.

Unsolicited proposals may be initiated by individuals at any time. Many funding entities have general requirement for the format of unsolicited proposals. OSP can contact the sponsor for guidelines or other indications of sponsor requirements.

Pre-Submission Procedures

Particularly when solicited proposals are involved, it is wise to contact a program officer within a government or private funding agency to discuss a project idea before actually submitting a formal proposal. Most program officers welcome advance contact of this nature since it allows them to help potential principal investigators focus their research on

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areas of interest to their organizations. In no case, however, should a private foundation or corporate funder be contacted for a donation without consulting Office to Sponsored Programs.

Agency contacts are made through:

o a telephone inquiry or agency visit; o a letter of inquiry;

o a letter of intent; or o a preliminary proposal.

Individuals are encouraged to make telephone inquiries on their own after discussing their projects with OSP staff. When a request is made, OSP will make the initial agency contact on behalf of the faculty or staff member. Likewise, an individual may visit a potential sponsor alone or accompanied by a representative of OSP. Throughout the course of such calls or visits, no commitments of University resources should be made, nor should detailed budget figures be discussed.

A letter of inquiry is a general presentation of a project data designed to elicit feedback from a potential sponsor. As in telephone inquiries or agency visits, no commitments should be made. Individuals need not process such letters through OSP and no formal routing or review is necessary, unless required by teaching unit chairs or school deans. Individuals are encouraged, however, to forward a copy of such correspondence to the OSP office so that staff may be prepared for proposal development resulting from inquiries.

A letter of intent expresses the intention to submit a proposal in response to a particular program announcement or RFP. Letters of intent are generally solicited by the sponsor in conjunction with announcements expected to generate widespread interest. Agencies generally require that such letters present only a general statement of the intended research theme. If the letter of intent contains budget estimates or ranges, it should be reviewed by and filed with OSP prior to submission.

Preliminary proposals, like letters of intent, are generally solicited by sponsor agencies. A pre-proposal usually includes a one to five (1-5) page description of the project. It may also require an outline budget and some indication of the University’s willingness to support the project through a commitment of resources. Any document that mentions budget figures or commits University space and other resources is subject to the review and approval of teaching unit chairs, school deans, the Vice President for Academic Affairs and the Vice President for Fiscal Affairs. The review and approval process is coordinated through OSP.

Note Note Note

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Compliance Issues

Important restrictions govern the use of human and animal subjects, radioactive isotopes, controlled substances, toxic materials, and hazardous chemicals. Research involving such items must adhere to federal and University policies. For more information and for the full texts of relevant policies, contact the Office of Fiscal Affairs.

Classified Research

The University does not accept sponsorship of research projects restricting publication of the results of the project or prohibiting the free exchange of ideas. Investigators, however, may be required to protect product or by-product proprietary rights against disclosure.

Many funding agencies require that results and reports be submitted to the sponsors for their information, review and comment before publication. The University accepts this practice provided that such comment time does not prevent publication for more than sixty (60) days. The University does not accept contracts requiring sponsor review and approval of proposed publications resulting from research projects.

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PRE-AWARD PROCEDURES

(Note: Awards, Contracts, and Grants differ in concept but for the purposes of these procedures the acronym ‘ACG’ will be used.)

1. University policy requires that a Pre-Application Notice (appendix, page 32) be completed by the principal investigator (PI) and filed with the Office of Sponsored Programs (OSP) when they decide to seek an ACG. Relevant data includes the following:

a) Principal investigator name and department

b) ACG sponsor, including the CFDA (catalog of federal domestic assistance) number.

c) Purpose of the ACG d) Total amount of ACG ** e) Start and end date of ACG f) Application deadline

g) Documentation required for application

h) Signature of the relevant department head / dean

** some ACG’s are a fixed dollar amount from the Sponsor, while some require submission of a proposal with the amount the PI is seeking to fund the work. In either case a detailed budget plan must be submitted to the OSP.

If the pre-application notice is not filed with the OSP prior to the ACG application being submitted for approval, the signatures of the appropriate University officials will be withheld from the ACG application until the pre-application notice is filed and approved by the OSP.

The University wants faculty and staff to be aggressive in the identification and pursuit of ACG’s, but committing the University to contract terms should remain a Fiscal Affairs department function. These types of agreements must be subject to oversight with respect to incurring obligations for the University (ex: cost sharing, matching funds, reporting deadlines, etc.).

Therefore any ACG that is signed without the approval of the school dean, Vice President of the originating area, the OSP and the Office of Fiscal Affairs will not be recognized as valid, and will not be activated in the University accounting system. Any unauthorized funds received for the execution of said ACG will not be disbursed. It is important that all faculty and staff be reminded of this policy at least once a year, preferably at the beginning of each academic year.

2. Once the pre-application notice has been received by the OSP, an LU information packet and an Application Worksheet (appendix, pages 33-34) will be provided to PI. This document must be completed and returned with the actual ACG

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application. The OSP will provide reasonable assistance to the PI in completing the budget.

Although each ACG sponsor will have their own rules about indirect cost allocation, Langston University’s stated goal is to allocate to any ACG an amount of indirect costs equal to 45% of the salaries and wages of the employees engaged in the execution of the ACG. Whenever possible the University will actively negotiate for this rate. If the ACG sponsor offers a fixed rate below our stated goal, with no negotiation, it will be a factor considered during evaluation of the application.

3. The application worksheet requires much of the same information as the pre-approval notice (to cross check/confirm the previous submittal) but will also include a list of the University personnel and physical assets that will be utilized in completing the ACG’s objectives and a list of any additional equipment or supplies necessary, including price and availability from local vendors. Also required at this stage will be a Detailed Budget Plan (appendix , pages 35-37), which reflects the ACG sponsor’s position on the allocation of indirect costs, matching funds percentages or amounts, as well as any special requirements unique to the ACG. If the sponsor does not have a set amount or percentage of indirect costs that can be allocated the budget will be based on the University’s indirect cost rate of 45% of salaries and wages for the employees engaged in the work. The budget plan must also include specific goals and/or stages of completion for the ACG, along with a timetable and estimated expenses for each goal.

4. Once the worksheet, application, and budget plan are completed they should be attached to the Grants/Contract Request Routing Sheet and submitted to the OSP for review, along with a copy of the solicitation and proposal. If any discrepancies are found between the pre-application notice and the application worksheet, the application and worksheet will be returned to the PI for correction/explanation. If a correction/explanation is not forthcoming within 5 working days the application will be considered inactive and no further action will be taken.

Note: If a proposal is rejected at any level it goes back to the applicant for correction/explanation.

5. If the PI cannot reach an accord with the OSP over inconsistencies between the notice and worksheet, they are eligible to appeal the decision to the Office of Fiscal Affairs for review.

6. If, after review, the Office of Fiscal Affairs finds the application to have merit, it will be forwarded to the President’s Office with a recommendation for approval. If the Office of Fiscal Affairs does not recommend approval, the application will

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be returned to the PI with specific reasons given for the rejection. Again the PI has the option of reworking the ACG proposal, and submitting it again.

7. Responsibility for follow-up inquiries on the status of the application will rest with the PI. Inquiries are encouraged at 15, 30, and 45 days after mailing. If the follow-up reveals a need for more information or clarification the PI will send a request to the OSP detailing what information is needed, and why. Approval for the release of additional information must come from the Fiscal Affairs Office.

After approval is given the PI will forward the supplemental information to the ACG sponsor, and the follow up procedure will begin again. The application will either be approved or denied by the ACG sponsor. If it’s denied the process ends. If it’s approved, the process continues to the next step, finalizing the agreement.

8. To finalize the agreement, approval will only be given if the ACG reflects the information previously approved on the pre-application notice and the application worksheet. If there are any discrepancies between the final agreement and these two internal documents, the PI will have 3 working days to submit in writing the reasons for the differences. If the explanation is not forthcoming or is deemed to be a material change in the ACG, the application will become inactive, and the process must begin again.

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PROPOSAL APPROVAL PROCESS

Principal Investigator

Department/Unit/Vice President

Office of Sponsored Programs

Prepares/Complies

• Technical proposal

• Curriculum vitae, publications, biographical sketches of investigators

• Budget and budget narratives

• Grant/Contract Request Routing Sheet (GCRRF)

Submit to Department Chair /Unit Head/V.P. For

• Approval for: matching funds/cost sharing, indirect cost rate variances, use of college or department resources

• Chairman/Unit Head signature

• Dean’s signature on memorandum of understanding for cost sharing or use of other college resources • Vice President’s signature

Submits to Office of Sponsored programs:

• GCRRF, sponsor application forms, abstract, budget, and budget narrative

Checks

● GCRRF completeness ● Approval of cost sharing/

and accuracy matching funds

● Budget calculations ● Appropriate agreement ● Use of proper ICR rate ● Special clearances

● Use of current fringe ● Acquire necessary signatures benefit rates on GCRRF and all grant

certifications

● Distribution of credit and ICR allocation

Principal Investigator Mails to Sponsor

or Mailed by OSP

• Original, number of copies required by sponsor, plus one copy for OSP & FA

• OSP mails proposal package to sponsor. Notify Fiscal Affairs Office Completes and Mails Proposal Package to Sponsor

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THE TECHNICAL PROPOSAL Preparation of the Technical Proposal

(Note: follow specific sponsor instructions regarding length, subject matter, and organization.)

In general, proposals consist of two parts; 1) the technical proposal, and 2) the cost proposal or budget. The principal investigator is responsible for preparing the technical proposal in accordance with sponsor guidelines and requirements. Cost proposals are prepared by the PI with in put from the OSP and the approval of the teaching unit chair and the school dean.

A good technical proposal is concise and coherent explanation of a research or programmatic plan with specific and reasonable goals. These goals and the methods that will be used to achieve such goals must be stated clearly. Project objectives should conform to the interests and guidelines of the sponsoring agency. The technical proposal must also demonstrate a convincing need for the proposed activity, either by showing that it fills an important gap in existing knowledge, or by showing that it serves the needs of a specific clientele of particular concern to the funding source.

Concurrent with preparation of a technical proposal, the principal investigator should contact the teaching unit chair and school dean to seek approval and support for the project. Issues of time commitment, space, facilities, course releases and overload situations should be resolved prior to submission. OSP can aid the principal investigator on issues such as hiring additional staff or consultants, leasing space off campus, or entering into sub contractual agreements. Some of these issues require liaison between OSP and other University offices.

In addition OSP can assist in getting subcontract documents in accordance with applicable sponsor policy. For example, the federal government mandates that certain terms and conditions must be included in all subcontracts involving federal “pass-through” funds; other sponsors may have similar requirements. In such instances, OSP transmits relevant material to the subcontractor for review and signature. OSP also can prepare “teaming agreements.” These are understandings between two institutions working together on a project.

In the absence of sponsor guidelines, the introduction should not exceed two pages leading into the next section to the proposal. This introduction should mention your previous accomplishment; describe your ability to carry out the project; and give a detailed description of proposed research.

Description of Proposed Research

The description is a detailed extension of the proposal abstract. It should include a statement of past work that has suggested or made possible the proposed study, as well as a specific description of recent research. Indicate how the research will relate to and

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reflect the current state of the art. Explain the project goals and methodology carefully. To the extent possible, describe in detail a research plan for six to twelve months. This will serve as justification to budget requests in the technical proposal. Also describe specifically any unusual or expensive requests such as equipment that reviewers might expect to be a part of the University’s facilities. Indicate clearly any research that requires an unusual amount of travel. Include a list of publications and /or supplies needed.

Explain the tasks to be completed by all project personnel. Include current vitae for all senior project personnel. If graduate or research fellows are known, submit their vitae as well. OSP recommends that curricula vitae submitted follow a similar format.

Bibliographies tables, charts, illustrations, reprints and other supplementary materials may be included if they enhance the effectiveness of the presentation. The sponsor instructions or requirements may limit the number of pages of text; refer to the instructions for supporting documents above –mentioned to be included in page limit.

Proposal Typing

Most proposals are prepared by faculty on University or personal word processing equipment. It is most helpful for the PI to provide the OSP office with a 3x5 HD diskette, e-mail copy or hard copy for final editing and printing. OSP uses the software “WordPerfect 6.1” for professional documents, but arrangements can be made in conversion or use of other software. When submitting proposal electronically, an USB drive will be needed.

After an initial draft of the technical proposal has been completed, the cost proposal or project budget can be formalized.

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THE COST PROPOSAL Procedure

Cost proposals detail the budget necessary to meet the objectives of the project (Sample

Budget, appendix, pages 33-34). OSP, in cooperation with the principal investigator is responsible for preparing the budget to ensure that it complies with specific sponsor requirements and University policies and practices. Budget formats vary according to sponsor guidelines. OSP can assist in preparing an internal budget that adheres to the University’s format.

The internal budget may include more categories than the sponsor’s form and is often submitted with the full proposal. The internal budget is used if the sponsor does not provide any budget forms.

The principal investigator should begin estimating costs as soon as the parameters of the technical proposal are established. OSP can assist in preparing a draft budget based on specific information in the description of the technical proposal. University guidelines are in place for the preparation of the budget summary. The component of the budget includes two categories of costs: direct and indirect cost. An annotated sample budget is attached as guide.

Budgets for instructional programs (using the U.S. Department of Health and Human Services approved indirect cost rat of 45%) or projects that provide training and University credit are developed with the consultation of the Office of Fiscal Affairs. The OSP can assist in such instances.

Direct Costs

Salaries and Wages:

All personnel who will devote time to the project are to be listed in the budget. Include titles, the percentage of time to be spent on the project, base salaries and the amount the sponsor is asked to pay to support each person for the budget period or their individual period of performance. Proposed salaries are estimates beyond the current fiscal year and should include merit increases (which are not guaranteed) based on the approved budget assumptions. Pursuant to federal regulations issued by the Office of Management and Budget (OMB) salaries charged to sponsored agreements may never exceed the proportionate share of the employee’s base salary for the period based on the level of effort applied to the project. OMB regulations further instruct that rates of pay may not be other than the employee’s base salary with the University.

Staff positions committed at 100% or more of time to a sponsored project is considered full time and permanent. New staff must be classified and recruited by the Office of Human Resources. OSP can assist in obtaining a “provisional” classification and salary base from the Human Resources’ Office. The twelve month salary for a staff person is the based salary.

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Faculty salaries are based on a nine-month academic year. The income earned during the nine-month period is the base salary. Sponsors differ on providing funds for the summer salary. In general, the University permits faculty members to earn up to 133% of the base salary in a twelve-month period, which includes summer teaching, summer research and administrative stipends. Therefore, a faculty member who works during the three summer months may earn up to one-third of the base salary from the nine-month period.

Some proposals involve course releases, a reduced workload or a workload reallocation for a faculty member to work on an externally funded grant or contract. The faculty member’s time may be paid for by the funding source or may be cost-shared by the University. For budget preparation and research planning purposes, the OSP recommends using the following assumptions about the allocation of a faculty member’s time: teaching 70%, research 20%, service10%.

Example: If a faculty member is scheduled to teach three courses in a semester, he or she would have to commit to 20% level of effort on a sponsored project to be eligible for one course release. When the teaching load is two courses per semester, a 30% level of effort on a sponsored project may result in one course release. Final decision of course releases, based on the need, are made by the Dean.

Fringe Benefits:

These benefits consist of the University’s contributions to Social Security (FICA), retirement programs (such as Oklahoma Teachers Retirement System, OTRS), health insurance, disability insurance, life insurance, workers’ compensation, and unemployment compensation. Fringe benefits are calculated as a percentage of salary. A fringe benefit rate of 43.5% is charged on the salaries of full-time faculty and staff and 5% of student employees. The fringe benefit rates are predetermined for a specified period.

Consultants:

Consultants provide expertise from outside the University. For federally sponsored projects, consultants, compensation is typically limited by the University to $300 per day. Actual daily rate allowable by a sponsor may be less than the University rate and should be determined in advance. The daily rate applies to the preparation time, the time spent on specific activities and time spent in writing reports and analyzing data. Each consultant must sign a consultant agreement. Additional clauses necessary for an effective agreement vary, depending upon services provided and /or circumstances.

Intra university consulting is normally undertaken as a University obligation, with no additional compensation. In some instances, when consulting is performed in addition to one’s regular teaching unit load, compensation above base salary may be possible if approved in writing by the sponsor and the Vice President for Academic Affairs.

Any payments of consultant fees through the University must not result in an overload situation. Income form the University and sponsored projects cannot exceed 133% of the

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faculty member’s base salary and a faculty member may not commit more than 100% of his or her time to teaching, research and consulting.

Accounting Definitions

The following are some helpful definitions that are used for accounting purposes or purposes of negotiating grants and contracts. These definitions do not apply to non-sponsored arrangements such as occasional overload teaching.

Base Salary - Amount of salary a faculty member is paid for the nine month academic year.

Overbase Situation - When a faculty member works during the summer months (June, July and August ) for a maximum of 33% of his or her base salary, resulting in payment of 133% of base. Overbase beyond the 133% is not permitted.

Overload Payments - When a faculty member commits more than 100% of his or her time to teaching, research and consulting activities. While overload payments for teaching are discouraged, overload payments for research are not permitted during the academic year.

Capital Equipment - Principal investigators should discuss potential equipment purchases with the OSP and/or the Office of Fiscal Affairs to ensure adherence to University and sponsor policies.

Travel - Sponsors will generally pay international or domestic airfare if such travel is necessary to the project and is so justified and approved. For federally sponsored projects, all international travel must be on U.S. flag carriers. In accordance with University policy, food and lodging must be shown as reimbursable expenses. Also included should be local transportation costs, such as mileage and parking.

Other Direct Costs may include:

• Supplies and other expendable materials, such as film • Computer software

• Equipment maintenance and repair • Printing and Publishing

• Photocopying

• Publications cost, such as page charges and reprints

• Communication such as telephone, postage, express mail, fax, and courier service

• Meeting expenses

• Conference registration cost

• Space (lease or rental of off-campus space) • Insurance

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Indirect Cost

Indirect costs are expenses included by the University for its facilities and administrative services (F&A). F&A indirect cost are not profit, but are real costs to the University to support sponsored activities. The University attempts to recover all of these support costs, in accordance with guidelines in the OMB circulars, through the inclusion of indirect cost in proposal budgets.

Examples include: building maintenance and operation, utilities. libraries, computer services and other facilities, payroll, accounting, purchasing, research administration, departmental administration, personnel services and general administration.

F&A indirect cost must be included in the budget of every proposal. The University uses different F&A indirect cost rates for research projects on and off campus, instructional programs and other agreements. The University and the U.S. Department of Health and Human Services (DHHS), its cognizant federal agency, have agreed on the current negotiated indirect cost rate for federal contracts and grants in specified fiscal years. An equivalent rate must be applied to projects that are funded by private and nonfederal sources, pursuant to the agreement with DHHS and the OMB Circulars A-21 and A-110. These guidelines are available in the OSP and the Office of Fiscal Affairs.

Some sponsors, particularly some foundations, have specific written policies that prelude the use of the full indirect cost rate. Some agencies limit indirect costs for instructional (or training) programs. The OSP will honor sponsor prohibitions or limitations on indirect cost recovery that represent the written regulations of the sponsor. For unilateral waivers of all or part of indirect costs by the University, written justification from the principal investigator must be submitted to the OSP through the established process, which includes support of the request by the school dean. Budgets with less than full indirect cost recovery must be justified on the basis of their special value to the University or the resulting competitive advantage.

Cost Sharing

Occasionally sponsors require the University to make a contribution to a project’s total. Cost sharing must have the concurrence of the teaching unit chair and school dean since their budgets bear such direct cost. Each school has a budget to cost share new expenses and the authority to commit existing “on-budget” resources for sponsored projects. OSP has no resources for direct cost-share or tuition remission.

Since cost sharing is examined and audited by the sponsor organizations, the budget proposal must specify the exact amount of contributions anticipated. The term “in-kind services” (for example: in the case of faculty time donated to the project) is difficult to audit and should be avoided. Instead, the budget proposal should include the dollar value of all such services to ensure the project receives full credit. Contact the OSP for assistance with cost-sharing issues.

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Sub-Agreements

A sub-agreement may be either a subcontract or a sub-grant. Each one is an agreement between the University and a third party to transfer a portion of the University’s obligations on a sponsored project to that party.

If a proposal includes the use of sub-agreements, the principal investigator should include an explanation of why the price to be paid to the subcontractor or sub-grantee is appropriate and reasonable. Estimates obtained should be attached to the budget proposal. Federal agencies often require a separate Cost and Pricing Proposal and appropriate Subcontractor Certifications in accordance with the Truth-in-Negotiations Act.

Principal investigators should identify each sub-agreement separately in the budget proposal. Sponsor approval of the proposal normally constitutes approval of the sub-agreements that are included in it.

Sub-agreements are not executed until the grant or contract has been awarded. Sub agreements are undertaken through the University’s regular procurement process.

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PROCESSING THE PROPOSAL

After the technical and cost proposals are complete, the principal investigator prepares the other forms required in the application kit. Proposals are submitted with a transmittal letter form the President to the sponsoring agency. Transmittal letters often clarify the University policies on budgeting or other issue. The principal investigator prepares the transmittal letter and processes the proposal through the University’s routing and approval procedure.

The University has a standard Sponsored Programs Approval form, which must accompany each proposal through the University’s approval process. A copy of the form is attached or may be obtained by going to www.lunet.edu.

Routing Through the University

Once the approval form, the technical proposal, the budget proposal and all attachments are prepared, OSP can assist in obtaining the required signatures.

The final submission represents an offer by the University to perform the activities specified in the proposal. The review and approval process ensures compliance with both sponsor and University policies.

To ensure a timely submission, you should allow a minimum of five days for the review and signing of the approval form.

Signatures required vary with the type of project being proposed. When the principal investigator signs the approval forms, he or she is approving the entire proposal and assuming responsibility for the scope of scientific and technical effort, preparation of the required technical reports and management of the project within the budget and time constraints of the proposal in compliance with sponsor regulations and University policies.

Teaching unit chairs and school dean certify the academic soundness of the project, facility and space availability, cost sharing (other than any OSP indirect cost waiver) course release arrangements and the compatibility of the project’s goals with the teaching unit’s objectives.

Proposals are usually routed through the teaching unit, school dean, the Director of OSP and the President. A project involving faculty or staff from more than one unit must be routed through all units involved. Projects that provide credit as part of the overall project must be priced by the University Fiscal Affairs as well as approved on the routing form.

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Submission of Proposal

After a proposal has been reviewed and approved, OSP will work with the PI to forward the required number of copies to the sponsor along with a transmittal letter signed by the President. Copies of the completed proposal package will be distributed internally to each university signatory after submission to the sponsor.

While unsolicited proposals may be submitted at any time, principal investigators should allow six to nine months between the date of submission and the anticipated starting date for the project. In general, proposals to be funded in a particular federal fiscal year (which ends September 30) should be submitted no later than February of that year.

Responses to REPs or special program notices must be sent to the address indicated on the cover sheet of the REP and must be received by the time and date indicated on the REP. Sponsors can reject late proposals.

Delivery

The letter of transmittal, the original signed proposal and budget and all the required copies are forwarded to the sponsor via first class and/or certified mail with return receipt requested or electronically.

Submissions or Revisions

Revisions to the cost proposals are often necessary as a result of negotiations with sponsor prior to the award of the grant or contract. Sometimes the technical proposal must also be revised. Review and approval of budget and technical revisions should follow the same procedures as indicated for the original submission.

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CHECKLIST for Principal Investigators Developing Proposal:

• What Title or Project Name will reflect the nature of the proposed research?

• What is the research problem or need for this activity? Have you reviewed current literature to determine the need for such a project or conducted a needs assessment?

• What do you hope to accomplish specifically as a result of this project?

• How will you accomplish the project goal? Why your approach is particularly suited to the problem? Discuss the activity concept, project structure and/or formal methodology.

• Can you justify the results? An Evaluation Plan, complete with measure of effectiveness or outcomes appropriate to the project design and methodology, should be described

• What special compliance issues and risks are associated with the project? Discuss plan for IRB and/or Animal Care and Committee Approval use of Hazardous/radioactive materials or other risk management issues.

• Where will the project be conducted? Have space needs been evaluated?

• When will project begin? When will it conclude?

• What are your qualifications for serving as the principal investigator on this particular project? Did you identity other skills and qualifications necessary to the activity and where/how you will provide that expertise?

• Is the estimated Cost justifiable?

• Have you completed necessary forms and follow all instructions from sponsor/agency?

• Have all support letters been prepared. And mailed to arrive before the deadline?

• Have you filed supporting documents and have them available?

• Are all authorized Faculty, Staff, and University officials available for final review and signature?

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POST-AWARD PROCEDURES

The purpose of post-award policies and procedures is to maintain institutional control over the expenditure and reporting of awards, contracts, and grants (ACG’s). Virtually all ACG’s have restrictions of one type or another. Federal ACG’s sometimes have different restrictions than state sponsored ACG’s, while privately funded ACG’s can come with an entirely separate and unique set of restrictions. LU’s post award procedures are designed to follow the rules affecting allowable and allocable expenditures as defined by OMB Circular A-21. “Cost Principles for Educational

Institutions.” Adherence to these principles will result in the creation of an audit trail and supporting documentation required to be in compliance with OMB Circular A-133, “Audits of States, Local Governments and Non-Profit Organizations.

The first step in developing post award procedures was to identify the areas that need to be closely monitored, to include:

1) Creation of Sub-Ledger accounts with budgets 2) Encumbrance and expenditures of ACG funds 3) time / effort reporting

4) billing ACG sponsors for reimbursement 5) final reporting on completed ACG’s

6) maintaining documentation of ACG activity for use in an audit

1. Creation of sub-ledger accounts with budgets. Once the pre-award process has been completed and we have a fully executed and signed ACG in hand, the University

accounting department will create a sub-ledger account in which to record the activity of that ACG. There are currently only two individuals (comptroller and accounting clerk) authorized to establish a sub-ledger account. By restricting access to this function the University helps ensure that no erroneous / fraudulent accounts are created.

2. Encumbrance and expenditures of ACG funds. The first line of post award compliance monitoring begins in the University Purchasing office. When a PI wants to expend grant funds they are required to submit a requisition (req) to the purchasing office. Req’s are date stamped when received, and at that point checked for the proper authorizing signatures, including that of the relevant vice president. Some sub-ledger accounts are frozen for budgetary reasons, and require a freeze form explaining why the expenditure is needed before the hold is released. Examples of frozen accounts are:

1) all state funds (290) (account numbers starting with 1.) 2) all auxiliary funds (711) (account numbers starting with 3.)

3) all federal funds (430 &711) that are signed by the research department (Dr. Burns)

After verifying that all signatures are present, the purchasing office assigns the correct sub code (object code). After assigning the code, purchasing checks all extensions on the

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requisition. If the req is for on-campus services a copy of the workers comp insurance with Langston University as certificate holder must be on file in the purchasing office Once all the required signatures and documents are present the purchasing office will attempt to fund the requisition, using SCT screen 019 to determine if there are sufficient funds in the object code. If there is a conflict between what the PI is requisitioning and what the budget says the ACG can be spent on, the purchasing office notifies the

compliance office. At this point the compliance office will research the grant documents to determine if the requisition is for a valid expenditure. If there is a conflict between the two documents the purchasing office will return the req to the PI, with a note indicating the issues and a request to contact the compliance office to resolve the matter.

At this point the PI will have to provide documentation to the compliance office proving the expenditure is necessary and falls within the bounds of the ACG budget. If the compliance office is not convinced of the validity of the expense the PI is allowed to appeal the decision to the Comptroller. If the Comptroller is convinced of the validity of the expense he will notify the compliance office of his decision. Once the compliance office has been notified, a memo will be sent to the purchasing office authorizing the expenditure, and detailing the reasons for this exception. Until the purchasing office receives this authorization they will not process the requisition.

3. Time / Effort reporting. One of the most crucial needs for post award compliance is the monthly time/effort report. As a PI performs the tasks required by the ACG they should maintain a record of time spent on the project. The auditors look for the

time/effort worksheets to reconcile them with the amount requested for reimbursement. At the end of the month the PI must submit a “confirmation of reimbursable and

contributed direct labor” report to the compliance office. (appendix, pages 43-44) This report is due in the compliance office within three (3) working days of the end of the month. Failure to submit the report in the required time frame will result in a freeze being placed on the ACG account, which will be lifted only after the confirmation report is submitted and accepted by the compliance office. Many ACG’s contain funds for the salary and fringe benefits of the PI. Failure to file timely reports may impact their monthly compensation.

The compliance office must review the time/effort worksheet to determine:

A) the amount of reimbursable labor to the ACG; B) the amount of contributed labor to the ACG; and, C) the actual FTE hours worked on the project.

These three items are essential in the next step, the monthly billing.

4. Billing ACG sponsors for reimbursement. Not all grants are awarded on a

re-imbursement basis. Some come in a lump sum, others are drawdown. For those that do operate on a reimbursement, once the monthly time / effort reports have been received, the compliance office can begin the billing process. During the billing process the compliance office reviews the month end sub code totals for each reportable grant,

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providing another opportunity to review expenditures and find anything that might have gotten past the previous safeguards. If the expenditures are found to be allowable and correct they are included in that month’s billing.

There are several different formats for the monthly billing, some of which are specific to individual grants. Other formats are specific to the sponsoring agency, while yet another format is a generic invoice (appendix, page 45), for use when a format is not specified. The various forms are kept on a network drive rather than on a PC so as to be accessible even if an individual computer should crash. Access to the network drives is controlled through the Information Technology Systems office, which limits the use of the

documents to those authorized to view and update them.

Once the billings are created and have been approved by the University Comptroller a cover letter is printed containing the name and address of the ACG contact. Two copies of the letter and invoice are placed in the ACG file and the original letter and invoice are mailed out. The compliance office will review accounts periodically during the month to ensure payment is received.

5. Final reporting on completed ACG’s. As a general rule the final billing on a completed ACG is due within 90 days of the end date. This is to allow time for any outstanding expenses or purchase orders to be brought to completion. Just before the end date of the ACG the compliance office will contact the PI to ask if there are any

outstanding items that they’re waiting on. If the answer is yes the compliance office will require a list of the items and a timetable for their resolution. If the answer is no the compliance office will contact the purchasing department to see if there are any open purchase orders. If the answer is no the compliance office will prepare a preliminary final report, but take no action beyond that.

Thirty (30) days after the end of the ACG the compliance office will again contact the purchasing department to see if there were any unexpected items that came in or if everything still looks complete. At this point the compliance office will prepare a draft final billing, and forward it to the comptroller to be approved. Once approval has been received the final billing will be sent to the ACG sponsor, with two copies put in the file.

6. Maintaining documentation of ACG activity for use in an audit. According to the Consolidated General Records Disposition Schedule for State Universities and Colleges ACG files fall into category 5.11 (Grants File). The description is as follows: “File contains all financial documents concerned with the administration of a grant.” The disposition of these records reads:

Retain in office until three (3) years after completion of grant activity, then destroy provided all audits have been completed and all applicable audit reports have been accepted and resolved by all applicable federal and state agencies and provided no legal actions are pending. If legal action is pending, destroy two (2) years after the exhaustion of all legal remedies provided records meet all

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Pre-Application Notice

Langston University

Application Worksheet

Langston University

Detailed Budget Plan

Langston University

3:

__________________________________________________________ ________________

Travel # people destination cost

Domestic 1: _______ _________________________________ _______________ 2: _______ _________________________________ _______________ Foreign 1: _______ _________________________________ _______________ 2: _______ _________________________________ _______________

Other direct costs item cost

Materials 1: __________________________________________________________ _________________ 2: __________________________________________________________ _________________ 3: __________________________________________________________ _________________ Supplies 1: __________________________________________________________ _________________

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3: __________________________________________________________ _________________ Printing 1: __________________________________________________________ _________________ 2: __________________________________________________________ _________________ Other 1: __________________________________________________________ _________________ 2: __________________________________________________________ _________________ 3: __________________________________________________________ _________________

Total Direct Costs: __________________

Indirect Costs: 45% x total direct costs __________________

If the ACG sponsor has their own % please use it _____%

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Anticipated Anticipated Percentage

Goal / Stage name Completion Costs to of Project

Date Complete Complete Goal/Stage #1__________________________________ __________ __________ _______ % Goal/Stage #2__________________________________ __________ __________ _______ % Goal/Stage #3__________________________________ __________ __________ _______ % Goal/Stage #4__________________________________ __________ __________ _______ % Goal/Stage #5__________________________________ __________ __________ _______ % Goal/Stage #6__________________________________ __________ __________ _______ % Goal/Stage #7__________________________________ __________ __________ _______ % Goal/Stage #8__________________________________ __________ __________ _______ % Goal/Stage #9__________________________________ __________ __________ _______ % Goal/Stage #10__________________________________ __________ __________ _______% Signature: __________________________________ Date: _______________ Principal investigator

Principal Investigator s Handbook

Principal Investigator’s Handbook

Grants/Contracts Compliance Management

Policies & Procedures

for

Sponsored Research Projects

Office of Sponsored Programs

Table of Contents

PROPOSAL APPROVAL PROCESS

Principal Investigator

Department/Unit/Vice President

Office of Sponsored Programs

Pre-Application Notice

Langston University

Sponsored ACG

Application Worksheet

Langston University

Sponsored ACG

Detailed Budget Plan

Langston University

Sponsored ACG

3: