Author: Sundara, Anida
New and Revised Policies in August 2023
Academic, Scholarly, and Professional Integrity and Misconduct (ASPIM), Policy on
Title: | Academic, Scholarly, and Professional Integrity and Misconduct (ASPIM), Policy on |
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Policy Owner: | Graduate Faculty Council; University Senate |
Applies to: | All members of the University community |
Campus Applicability: | Storrs and Regional Campuses |
Approval Date: | July 11, 2023 |
Effective Date: | August 28, 2023 |
For More Information, Contact: | For Undergraduate Education: Director or Associate Director, Office of Community Standards (community@uconn.edu)
For Graduate Education: Director of Graduate Student and Postdoctoral Scholar Support, The Graduate School (gradschool@uconn.edu) |
Official Website: | policy.uconn.edu |
BACKGROUND
The University of Connecticut is committed to fostering an intellectual community in which the highest ethical standards of academic, scholarly, and professional integrity prevail. All members of the university community, including administrators, faculty, staff, and students, have a shared responsibility to uphold this commitment. This commitment relates to all aspects of academic, scholarly, and professional activity, which include not only activities related to instruction, but also those related to the production and dissemination of scholarship, research, and creative works, and to professional conduct within clinical and other professional settings. Integrity in all of these activities is of paramount importance, and the University requires that the highest ethical standards in teaching, learning, research, and service be maintained. This includes “ethical aspects of scholarship that influence the next generation of researchers as teachers, mentors, supervisors, and successful stewards of grant funds” (Council of Graduate Schools, 2012).
Issues related to academic and scholarly integrity at the University of Connecticut are governed by the Academic, Scholarly, and Professional Integrity and Misconduct Policy (DATE). To recommend changes to the policy or to the implementing procedures, a committee must be convened that brings together all the above relevant stakeholders, including University Senate and Graduate Faculty Council. The committee must then bring those changes to the University Senate and Graduate Faculty Council, and each body must vote to approve any changes.
Students’ responsibilities with respect to academic and scholarly integrity are described in the following documents: Responsibility of Community Life: The Student Code.
PURPOSE
To ensure a commitment to academic, scholarly, and professional integrity in all levels of the university community.
Such a commitment ensures that:
- all individuals accept full responsibility for their own work and ideas;
- all academic/scholarly credit awarded to an individuals represents the work of that individual;
- no student benefits from an unfair advantage;
- faculty, staff, advisors and others who support the intellectual development of students are committed to fostering, guiding, and monitoring students for adherence to all principles of academic and scholarly integrity;
- the grades earned, the degrees or certificate conferred were appropriately earned by the individual;
- the reputation of the University with respect to academic and scholarly integrity are protected
- faculty, staff, and students adhere to the professional standards of conduct specific to each program offered at the university;
- this policy is used consistently across the University, including undergraduate and graduating students and schools/colleges.
APPLIES TO
This policy applies to all members of the University Community engaged in academic and scholarly efforts in, but is not limited to, the following contexts in undergraduate and graduate education:
- courses, including online courses (e.g., assignments, exams, projects, thesis);
- experiential and service-learning courses and activities;
- study abroad programs;
- clinical and practice placements, internships, and externships;
- program assessments (e.g., comprehensive exams, thesis, program reviews);
- research, including undergraduate, graduate, postdoctoral scholar, and faculty research; and
- processes involving submitting information (i.e., admissions, for scholarships/fellowships, for competitions, for awards, or other university programs); and
- professional events and conferences
All members of the University community are responsible for ensuring that the principles of academic and scholarly integrity are upheld.
This policy applies to graduate students and postdoctoral scholars, with the exception of PharmD students in the School of Pharmacy and professional students with degrees conferred by the Schools of Dental Medicine, Medicine, or Law.
This policy does not apply to legal, regulatory, or compliance requirements that fall outside the Academic and Scholarly Integrity Policy. In addition, this policy does not remove any reporting requirements to the appropriate oversight authority in instances of noncompliance or alleged noncompliance.
DEFINITIONS
Academic Integrity: a commitment by the University Community to uphold just and ethical behaviors, which includes truthfulness, fairness, and respect (ICAI, 2021).
Scholarly Integrity: a commitment by the University community to both ”… research integrity and the ethical understanding and skill required of researchers/scholars in domestic, international, and multicultural contexts. It is also intended to address ethical aspects of scholarship that influence the next generation of researchers as teachers, mentors, supervisors, and successful stewards of grant funds.” (p. xix, Council of Graduate Schools, 2012).
Professional Integrity. Standards of behavior defined by the various professions in which students are prepared through their degree or certificate programs.
Academic, Scholarly, and Professional Integrity Misconduct is defined as unethical academic and scholarly behavior during a course (e.g., on an assignment or exam), as part of other degree requirements (e.g., requirements regarding placement, capstone or comprehensive exams, or placement exams), or at other times during undergraduate, graduate, or professional study and performance, including during engagement in fieldwork, clinical placements, or research. These behaviors include:
- Cheating: Unauthorized acts, actions, or behaviors in academic or scholarly areas. Examples of cheating include, but are not limited to:
- providing or receiving help on an assignment or exam intended to reflect the individual student’s work product when not authorized to do so by the instructor.
- buying, selling, circulating, or using a copy of instructional materials, assignment or test, including uploading such information to online services, or using materials prepared by services that sell or provide papers or other course materials.
- asking someone to complete an assignment, exam, or other requirement on your ones behalf or completing an assignment, exam, or requirement for another student.
- Failure to disclose unauthorized assistance on work submitted for evaluation, i.e., assistance obtained outside channels approved by instructors, that is used to complete a course, program, or degree requirement. This includes assistance from other students, teaching assistants, Quantitative Learning Center, Writing Center, or mediated support from the Center for Students with Disabilities.
- Plagiarizing: Using one’s own previously published, presented, or disseminated material, or another person’s language/text, data, ideas, expressions, digital/graphic element, passages of music, mathematical proofs, scientific data, code, or other original material without authorization of the originating source or proper acknowledgement, attribution, or citation of the originating source. Examples of plagiarism include but are not limited to:
- submitting as one’s own any work (in whole or part) completed by another individual, including any work that has been purchased from an individual, commercial research firm, or obtained from the internet.
- submitting for evaluation or credit any work that was previously used or submitted for credit in another course or as part of a degree requirement (e.g., a thesis or dissertation) without authorization to do so from the instructor. (This includes self-plagiarism in the form of re-using, in part or whole, the content of a paper from another class or context.).
- submitting any work prepared for or used in a previous publication, academic competition, clinic, or other activity (e.g., grant or application submission) without prior approval and full disclosure or when permitted by established editorial or other policy. (This includes self-plagiarism in the form of using, in part or whole, the content of a paper that was previously published without attribution).
- unauthorized use of previously completed work or research for a thesis, dissertation, or publication.
- Misrepresenting: Deliberately knowing and providing false or misleading information, including information about oneself or others. Examples of misrepresenting include but are not limited to:
- engaging in “any omission or misrepresentation of the information necessary and sufficient to evaluate the validity and significance of research, at the level appropriate to the context in which the research is communicated” (D. Fanelli, Nature 494:149; 2013).
- making unauthorized alterations to any document or digital file pertaining to academic or scholarly activity, including assignments, exams, and research data.
- making up information for the purpose of deception (e.g., fabrication of data in research).
- making false, inaccurate, or misleading claims or statements, including claims/statements made when asking for assistance (e.g., requesting an extension on an assignment), applying for admission to an undergraduate or graduate program, applying for a scholarship or an academic, scholarly, or research award, or submitting manuscripts for publications.
- allowing someone to use one’s identity or using someone else’s identity for academic or scholarly advantage (e.g., signing in electronically for an absent student).
- accepting credit for work for which the individual did not contribute (e.g., misrepresenting an individual’s role in a group assignments).
- Noncompliance: Failure to conform with codified and publicly available academic, scholarly, or professional standards, processes, or protocols.Examples of noncompliance include but are not limited to:
- not attending to the professional standards governing the professional conduct of students in particular fields (e.g., pharmacy, nursing, education, counseling, and therapy).
- violating protocols governing the use of human or animal subjects.
- breaching confidentiality in academic and scholarly activity (e.g., disclosing the identity of study participants).
- disregarding the applicable university, local, state, or federal regulations that guide academic or scholarly activities.
Instructor: any faculty, teaching assistant, or any other person (e.g., lab supervisor, clinical supervisor, professional staff) authorized by the University to provide educational services (e.g., teaching, research, advising)
POLICY STATEMENT
All members of the university community, including administrators, faculty, staff, and students, have a shared responsibility to uphold the highest ethical standards of academic, scholarly, and professional integrity and to report any violations of those standards of which they are aware.
Instructor Expectations: To foster a culture of academic integrity, instructors are responsible for communicating the expectations for academic and scholarly integrity to students and for engaging in practices that mitigate violations of this policy. Specifically, instructors are expected to:
- include a link to the Academic, Scholarly, and Professional Integrity and Misconduct policy as part of course syllabi or documentation for any other academic/scholarly activity and include any additional unit-specific expectations.
- review academic and scholarly integrity policy and any other disciplinary- or activity-specific expectations.
- provide clear guidance for all assignments, activities, and assessments, including noting what resources can be used and whether collaboration is permitted.
- ensure individuals engaged in research, creative, or professional activities understand the standards, protocols, and guidelines to which they must adhere.
- adhere to the University processes for reporting misconduct, engaging in the review process, and assigning consequences to address violations, which should include opportunities for education and remediation.
Student Expectations: To uphold the principle of academic and scholarly integrity in all aspects of their intellectual development and engagement at the University, students are expected to:
- be responsible for their own work and their own actions related to all academic and scholarly endeavors.
- assume they are to do independent work and seek clarification prior to collaborating with others or using outside resources.
- understand and abide by the standards, protocols, and guidelines to which they must adhere in research, creative, or professional activities .
If students witness or become aware of a violation of academic or scholarly integrity, they are encouraged to communicate this to the appropriate university representative (e.g., faculty, staff, advisor).
A cumulative record is maintained of all academic or scholarly integrity violations and such record will be reviewed and considered as part of subsequent incidences. Individuals engaged in research are expected to follow all standards, rules and regulations that guide the proper conduct of research or creative activity.
ENFORCEMENT
Violations of this policy and its related procedures may result in appropriate disciplinary measures in accordance with University By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, and the University of Connecticut Student Code.
Notes: Student misconduct is governed by the University’s Student Code, which is administered under the direction of the Division of Student Affairs. Enforcement of its provisions is the responsibility of the Director of Community Standards (for undergraduate students), The Graduate School (for graduate students), and the Office of the Vice President for Research (for research misconduct). Identified misconduct will be routed to the appropriate unit.
Faculty misconduct is also governed by the Code of Conduct and misconduct is addressed by the appropriate university administrative unit(s) (e.g., School/College, Provost Office, Office of the Vice President of Research, Human Resources).
REFERENCES
International Center for Academic Integrity [ICAI]. (2021). The Fundamental Values of Academic Integrity. (3rd ed.) https://academicintegrity.org/images/pdfs/20019_ICAI-Fundamental-Values_R12.pdf
Council of Graduate Education (2012). Research and Scholarly Integrity in Graduate Education: A Comprehensive Approach. https://cgsnet.org/research-and-scholarly-integrity-graduate-education-comprehensive-approach-2
Responsibilities of Community Life: The Student Code
PROCEDURES/FORMS
Undergraduate Education: Academic, Scholarly, and Professional Misconduct
Graduate Education: Academic, Scholarly, and Professional Misconduct
[Note: UConn will continue to use the existing procedures administered by Community Standards for undergraduate education and The Graduate School for graduate education until such time that the university transitions to the new Procedures for Addressing Alleged Violations of the Policy on Academic, Scholarly, and Professional Integrity, which was approved by Graduate Faculty Council and the University Senate.]
POLICY HISTORY
07/11/2023 Approved by the President (06/26/2023 Approved by Senior Policy Council; 05/01/2023 Approved by University Senate; 10/26/2022 Approved by Graduate Faculty Council)
Restriction on Lithium-Ion Battery Motorized Personal Transportation Vehicles (MPTV) Policy
Title: | Restriction on Lithium-ion Battery Powered Motorized Personal Transportation Vehicles within University Owned and/or Managed Buildings |
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Policy Owner: | University Safety |
Applies to: | Students, Workforce Members, and Visitors |
Campus Applicability: | All Campuses |
Approval Date: | August 30, 2023 |
Effective Date: | August 31, 2023 |
For More Information, Contact: | University Safety, University of Connecticut Fire Department Deputy Fire Chief & Executive Officer |
Contact Information: | UConnFire@uconn.edu |
Official Website: | https://universitysafety.uconn.edu/fire/safety/ |
BACKGROUND
The proliferation and utility of lithium-ion battery powered motorized personal transportation vehicles (MPTVs) (e.g., mopeds, scooters, e-bikes, etc.) throughout the University of Connecticut (UConn) has led to a significant community safety concern as these devices are charged, stored, and utilized within University owned and occupied buildings.
Lithium-ion and lithium metal batteries, when incorrectly charged or stored, can create thermal runaway in which the lithium-ion cell enters an uncontrollable, self-heating state, resulting in the ejection of gas, shrapnel and/or particulates, extremely high temperatures, smoke, and fire. This can result in high intensity flame and noxious gases that pose a serious risk to life safety, and can cause catastrophic property damage.
PURPOSE
To reduce the risk of safety hazards, property damage and potential disruption to business continuity by enacting a University-wide restriction on the charging, storage, and use of lithium-ion battery-powered motorized personal transportation vehicles (MPTVs) within all University-owned and/or managed buildings and the University’s electrical infrastructure. The storage, charging, and maintenance of Motorized Personal Transportation Vehicles within University owned or managed buildings, or through use of the University’s electrical infrastructure, is strictly prohibited.
APPLIES TO
All University students, staff, faculty, and visitors, and University-owned and/or managed buildings across all campuses.
DEFINITIONS
Associated Electrical Infrastructure: the equipment and services necessary to take electrical energy generated and transmitted for end-use. Charging MPTVs within University owned and/or managed buildings and their associated electrical infrastructure transfers the risk of life safety hazards and property damage to areas that may directly impact business continuity (e.g. academic and operational buildings). A building’s interior and exterior electrical infrastructure may not be rated to handle such electrical demands.
Motorized Personal Transportation Vehicle (MPTV): a vehicle or device used for human transport that does not require a license to operate and utilizes a fuel or battery driven motor for propulsion (e.g., electric bicycle, electric skateboard, hoverboard, self-balancing electric scooter, gasoline powered scooter, moped, etc.).
Lithium-Ion (Li-ion) Battery: a type of rechargeable battery composed of cells in which lithium ions move from the negative electrode through an electrolyte to the positive electrode during discharge and back when charging. These cells use an intercalated lithium compound as the material at the positive electrode, and typically graphite at the negative electrode.
POLICY STATEMENT
The storage, charging, and maintenance of MPTVs within University-owned and/or managed buildings, or through use of the University’s electrical infrastructure is strictly prohibited. Exceptions to this Policy are MPTVs that are used for medical purposes (e.g., lithium-ion battery powered wheelchairs) and items used in approved and supervised research activities.
ENFORCEMENT
Violations of this policy may result in appropriate disciplinary measures in accordance with University By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, and the University of Connecticut Student Code.
PROCEDURES
University Building owners and stewards (e.g., Residential Life, School of Engineering, Student Union, Athletics, etc.), and their designees, will support compliance and enforcement of this policy by notifying occupants and visitors through messaging (e.g., signage, internal email communication, etc.). University Building owners will direct removal of MPTVs from within buildings when device owners are unresponsive to compliance.
Any lithium-ion batteries, or powered devices that display signs of pending Thermal Runaway (e.g., bulging, off-gassing, high temperature production, etc.) are an immediate danger to life and health, and shall result in a notification to University Safety/public safety authorities via 9-1-1.
REFERENCES
Residential Life, University of Connecticut (2022). 2022-2023 Housing Contract. https://reslife.uconn.edu/wp-content/uploads/sites/3384/2023/03/UConn-Reslife_Housing_Contract-2022-2023-.pdf
POLICY HISTORY
Policy created: August 30, 2023 (Approved by the Senior Policy Council and the President)
Finance Capital Projects Policies and Procedures Manual
Title: | Finance Capital Projects Policies and Procedures Manual |
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Policy Owner: | Finance |
Applies to: | Staff and Faculty on Storrs and Regional Campuses and UConn Health |
Campus Applicability: | Storrs, Regionals, and UConn Health |
Effective Date: | June 13, 2023 |
For More Information, Contact | Budget, Planning and Institutional Research – Project Accounting/Accounting Office |
Contact Information: | (860)486-6288/BPIR@uconn.edu (860)486-1366/AccountingOffice@uconn.edu |
Official Website: | https://bpir.uconn.edu/ |
The Finance Capital Projects Policies and Procedures Manual are available for download as a PDF.
POLICY HISTORY
Revisions: June 13, 2023 (Approved by BGE, President, and Senior Policy Council); September 11, 2019; February 2015
Revised and Decommissioned Policies in April 2023
Health and Safety Policy (Revised): There’s been a non-substantive revision to the Health and Safety Policy for changes under Administrative Oversight. The revised policy has been approved by the Senior Policy Council.
COVID-19 Immunization Record Requirement for Students (Decommissioned): The COVID-19 Immunization Record Requirement for Students has been approved to be decommissioned by the Senior Policy Council (3/13/23) and the Board of Trustees (4/19/23).
New and Revised Policies in March 2023
Policy on Multi-Factor Authentication (New): This new policy, approved by the Senior Policy Council, supports the University’s change in login services, which aims to mitigate risk associated with theft of credentials and to align the University with industry best practice.
Controllable Property Policy (Revised): The Controllable Property Policy has been revised for added clarity and approved by Senior Policy Council (SPC). The requirement for a department to identify and inventory controllable property changed from “regular basis” to “annually”. The definition of “Custodian” was updated to include “whose NetID is associated with the asset record” (based on current procedure).
Policy and Procedure on Endowed Chair and Professorship (Revised): The revised Policy and Procedure on Endowed Chair and Professorship has been approved by the Senior Policy Council and the Board of Trustees. The editorial revisions were made for clarity and for a consistent use of terms.
Board of Trustees Conflict of Interest, Policy On
Title: | Board of Trustees Conflict of Interest, Policy On |
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Policy Owner: | Office of the Board of Trustees |
Applies to: | Trustees, Non-Trustee Members of Board Committees |
Applicability: | The Board of Trustees |
Effective Date: | February 22, 2023 |
For More Information, Contact | Executive Secretary to the Board of Trustees |
Contact Information: | boardoftrustees@uconn.edu |
Official Website: | http://boardoftrustees.uconn.edu/ |
PURPOSE
Per the By-Laws of the University of Connecticut, the Board appoints the President; determines the general policy of the University, including the establishment of new schools and colleges; makes laws for its government; manages its investments; and directs the expenditure of funds (see Article I). As such, in carrying out its public trust, the Board of Trustees has adopted this Policy to enhance public confidence in the Board. Nothing in this Policy shall supersede any responsibilities a Board member may have under the State Code of Ethics for Public Officials.
APPLIES TO
This Policy applies to all members of the Board of Trustees, including appointed, ex-officio, and elected members as well as non-Board of Trustee voting members of a Board Committee (“Board Members”). In addition to this policy, a Board Committee may adopt their own policy to guide the identification and review of conflicts of interest.
POLICY STATEMENT
Fiduciary Responsibilities. Board Members will act in a manner consistent with their fiduciary responsibilities to the University. Board Members will place the University’s interests ahead of their private interests. Board Members will exercise their powers and duties in the best interests of the Board and the University and for the public good.
Use of Authority/Information. Board Members will not use their positions, or any privileges or information attendant to their offices, to obtain or provide others with a benefit that is inconsistent with the policies of the University. No Board Member will solicit or accept any gift, loan, or other item of value, or the promise thereof in the future, which would tend to influence improperly the manner in which the Board Member performs their duties.
Competition or Diversion of Opportunity. No Board Member will knowingly compete with the University for any property, asset, or opportunity that may be of interest to the University unless the University has been informed of the opportunity on a timely basis and has declined to act on it. No Board Member will divert to another individual or entity an opportunity that may be of interest to the University unless the University has first been informed of the opportunity and has declined to act on it.
Conflict of Interest. (a) A conflict of interest exists when financial interests or other opportunities for the personal benefit of a Board Member, member of their immediate family or an associated business may compromise the Board Member’s independence of judgment in fulfilling their Board duties. (b) Board Members will endeavor to remain free from the influence of any conflicting interest in fulfilling their Board duties. Board Members will exercise care that no detriment to the University results from conflicts between their interests and those of the University.
Disclosure of Conflicts. If a Board Member believes that they may have a conflict of interest or is notified of a complaint of non-compliance with this Policy, the Board Member shall promptly and fully disclose the potential conflict to the Executive Secretary to the Board of Trustees and shall refrain from participating in any way in the matter until the conflict question has been resolved. The Executive Secretary to the Board of Trustees shall inform the Chair of the Board, the President, the General Counsel, and the Chief Compliance Officer of any conflicts of interest which have been disclosed to the Executive Secretary.
Determining Conflicts. The opinion of the Chief Compliance Officer, following consultation with the Executive Secretary of the Board of Trustees and General Counsel, shall be final in regard to determining compliance with this Policy. The Executive Secretary to the Board of Trustees may consult with the remaining members of the Board, or other appropriate University personnel, in making the determination.
Addressing Conflicts. If it is determined that a conflict of interest exists, the Chair of the Board, the President, the Executive Secretary of the Board, and the General Counsel shall work with the affected Board Member to address the conflict and explore alternative arrangements that would eliminate the conflict. If after reasonable efforts, it is not possible to reach a mutually acceptable alternative arrangement, the Board Member shall be excluded from participating in the transaction or matter relating to the conflict. If it is determined the Chair of the Board has a conflict, the same process outlined above will be followed, without participation of the Chair.
Violations. If a Board Member fails to disclose a conflict of interest or a conflict is otherwise discovered after the fact, the matter shall be forwarded to the Executive Secretary to the Board of the Trustees for review. The full Board of Trustees shall review the matter and determine corrective action, which may include, but is not limited to, termination of a contract or other appropriate measures.
The Chief Compliance Officer, in consultation with the General Counsel, may develop guidelines and procedures to implement this policy.
POLICY HISTORY
Policy created:
12/16/2022 (Approved by Joint Audit & Compliance Committee)
02/22/2023 (Approved by the Board of Trustees)
Instruction and Training for Newly Appointed and Elected Members of the Board of Trustees, Policy On
Title: | Instruction and Training for Newly Appointed and Elected Members of the Board of Trustees, Policy On |
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Policy Owner: | Office of the Board of Trustees |
Applies to: | Appointed or Elected Trustees |
Applicability: | The Board of Trustees |
Effective Date: | January 3, 2023 |
For More Information, Contact | Executive Secretary to the Board of Trustees |
Contact Information: | boardoftrustees@uconn.edu |
Official Website: | http://boardoftrustees.uconn.edu/ |
PURPOSE
To establish uniform and consistent training for newly appointed and elected members of the Board of Trustees in areas related to the University’s academic, physical, and financial operations.
APPLIES TO
This policy applies to all members of the Board of Trustees appointed by the Governor or elected by student or alumni constituencies.
POLICY STATEMENT
In accordance with Public Act 22-16, the Executive Secretary to the Board of Trustees will provide training, mandated for all newly appointed and elected members of the Board, within twelve (12) months of the Trustee’s appointment or election.
As mandated by the public act, Trustees will receive instruction or training in the following:
- Duties to the state and the University, including methods for meeting associated statutory, regulatory, and fiduciary obligations.
- The functions and purviews of all the Board’s Committees.
- Professional accounting and reporting standards.
- Applicable provisions of the Freedom of Information Act, as defined in section 1-200 of the general statutes.
- Institutional and statutory ethical responsibilities and obligations, including the Board’s Policy on Conflicts of Interest.
- University process for the development and implementation of policies.
- Higher education business and administrative operations, including budgeting, financing, financial reporting and services, and endowment management.
- Student tuition, mandatory fees, and student debt trends.
- Planning, construction, maintenance, expansion, renovation, and oversight related to projects and plans that impact the infrastructure, physical facilities, and natural environment under the Board’s jurisdiction.
- Workforce planning, strategy, and investment.
- Institutional advancement, including philanthropic giving, fundraising initiatives, alumni engagement and programming, communications and media, government and public relations, and community affairs.
- Student welfare issues, includes academic studies, curriculum, residence life, student governance and activities, and the general and overall physical and mental well-being of students.
- Current and anticipated issues in higher education.
- Other topics as the Board Chair, Executive Secretary, or President deem necessary and appropriate.
The Executive Secretary to the Board of Trustees, in consultation with General Counsel, may update this policy to reflect any future statutory changes.
POLICY HISTORY
Policy created:
12/16/2022 (Approved by Joint Audit & Compliance Committee)
02/22/2023 (Approved by the Board of Trustees)
Subrecipient Monitoring, Policy on
Title: | Subrecipient Monitoring, Policy on |
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Policy Owner: | Office of the Vice President for Research, Sponsored Program Services |
Applies to: | All faculty, staff, and students |
Campus Applicability: | All Campuses |
Effective Date: | December 22, 2022 |
For More Information, Contact: | Office of the Vice President for Research, Sponsored Program Services |
Contact Information: | 860-486-3622 (Storrs and Regional Campuses) 860-679-4040 (UConn Health) |
Official Website: | https://ovpr.uconn.edu (Storrs and Regional Campuses) https://ovpr.uchc.edu (UConn Health) |
PURPOSE
The Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200), commonly known as “Uniform Guidance”, requires pass-through entities to: (i) evaluate each subrecipient’s risk of noncompliance in order to determine the appropriate monitoring level; (ii) monitor the activities of subrecipient organizations to ensure that the subaward is in compliance with applicable Federal statutes and regulations and the terms of the subaward; and (iii) verify that subrecipients are audited as required by Subpart F of the Uniform Guidance.
For non-federal awards, the University may also be required by the sponsor to provide evidence of due diligence in reviewing the ability of a subrecipient to properly meet the objectives of the subaward and account for the sponsor’s funds.
Failure to adequately monitor the compliance of subrecipients could result in reputational damage to the University and jeopardize current and future funding. As the prime recipient of sponsor funds, it is the University’s responsibility to ensure the good stewardship of sponsored funding.
This policy lays out the requirements for the oversight of subrecipients.
APPLIES TO
All faculty, staff, and students involved in the administration of sponsored projects at University of Connecticut and all regional campuses, and UConn Health (“University”).
DEFINITIONS
Uniform Guidance: Uniform Guidance is a government-wide framework of authoritative rules and regulations for federal awards that is issued by the Office of Management and Budget (OMB). The full title is the “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.”
Subaward: An enforceable agreement, issued under a prime sponsored project, between a pass-through entity and a subrecipient for the performance of a substantive portion of the program; these terms do not apply to the procurement of goods or services from a contractor (vendor).
Subrecipient: A non-federal entity that receives a subaward from a pass-through entity to carry out part of a federal program. The subrecipient has responsibility for programmatic decision-making and for adherence to applicable program compliance responsibilities. Subrecipients are responsible for performing a substantive portion of the program, as opposed to providing goods and services. Subrecipients must adhere to the terms and conditions of the prime award passed down to the subrecipient organization in the subaward agreement. (Subrecipient may also be referred to as subawardee, subgrantee, or subcontractor).
Subrecipient Monitoring: Activities undertaken by the prime recipient (the University) to mitigate financial and/or programmatic risk, including reviewing the subrecipient’s financial status, management controls, financial stewardship of subaward funds, and completion of the scope of work.
Catalog of Federal Domestic Assistance (CFDA) Number: A unique five digit number assigned to each federally funded assistance program. The first two digits identify the agency and the last three digits identify the program.
POLICY STATEMENT
As a recipient of federal funds, it is the responsibility of the University to ensure that its subrecipients meet the terms and conditions, as well as the regulations of sponsors from which funds are received. As a condition of accepting funding from a sponsor, the University is obligated in its role as prime recipient to undertake stewardship activities as well as comply with federal and state laws, sponsor requirements and University policy. When the University issues a subaward to a subrecipient, the University remains responsible to the sponsor for the management of funds and for meeting project performance goals. Thus, the monitoring of technical and financial activities associated with a subrecipient is an integral part of the University’s stewardship of sponsored funds. To comply with these responsibilities, the University assigns subrecipient monitoring activities to its Principal Investigators, department administrators and SPS administrators.
ROLES AND RESPONSIBILITIES
Principal Investigator (PI):
Note: A significant financial interest held by the PI in the subrecipient entity must be disclosed to the Conflict of Interest Office and the Director of Pre and Post Award in the Office of Sponsored Program Services.
- Prior to proposal submission and in collaboration with the Fiscal Officer or Department Administrator, obtains proposal-relevant documentation from subrecipient and makes initial determination as to whether a subrecipient or vendor relationship exists.
- Submits documentation with proposal for review and approval to Sponsored Program Services (SPS).
- Monitors the technical progress of a subrecipient’s performance as defined in the subaward to ensure that performance goals articulated in the statement of work are achieved and that all deliverables have been met.
- Monitors expenditures of the subaward to confirm that funding provided to the subrecipient is used for purposes authorized in the subaward.
- With guidance from SPS, as needed, reviews invoices for cost allowability. In addition, ensures that the amount billed is consistent with technical/progress reports and production of deliverables.
- Approves invoices for payment. Delegation of this approval may be assigned to a programmatic responsible individual who is managing the subrecipient.
- Notifies SPS when problems arise regarding invoicing or performance.
Fiscal Officer (FO)/Department Administrator (DA):
- Assists PIs with administrative tasks associated with their monitoring responsibilities, as specified
above.
Sponsored Program Services:
- If not yet submitted by PI and/or FO/DA, collects necessary forms and information, when applicable, from subrecipients.
- Initiates a pre-qualification review of subrecipient, and verifies subrecipient/vendor determination.
- Performs a risk assessment of the subrecipient’s financial and internal controls to determine whether additional terms and conditions should be included in the subrecipient agreement, given the level of risk identified.
- Advises subrecipients of requirements, including, but not limited to, financial and non-financial reporting imposed on them by federal laws, regulations, and the flow-down provisions of the prime award, and any supplemental requirements imposed by SPS based on level of risk as determined by SPS.
- Provides information to describe a federal award to each subrecipient, including, but not limited to, the CFDA number, prime award number, award year, and the name of the sponsor as required by OMB Uniform Guidance.
- Negotiates and executes subaward agreements between the University and subrecipients, including appropriate language requiring adherence to federal regulations and other sponsor requirements, as applicable.
- Confirms that subrecipients expending $750,000 or more in federal awards during the subrecipient’s fiscal year are compliant with Uniform Guidance audit requirements. Reviews audit results to determine whether material weakness or other reportable conditions exists. When necessary, issues management actions, including management decision letters and/or adjustments or termination of the agreement.
- Documents compliance certifications.
- Coordinates changes to project budgets or expenditures that require University or sponsor prior approval.
- Performs a final review of costs charged and facilitates proper close-out of all commitments.
- Assists with resolving financial questions related to invoices, including the review of invoices for cost allowability, compliance with federal regulations, and prime award and subaward terms and conditions.
- Ensures that the University’s subrecipient monitoring procedures are compliant with Federal, non- Federal, and other applicable regulations.
- Provides training and guidance in interpreting regulations, subaward terms and conditions and executing these guidelines and requirements.
- Files required Federal Funding Accountability and Transparency Act (FFATA) reporting for first-tier subawards and subcontracts.
ENFORCEMENT
Violations of this policy may result in appropriate disciplinary measures in accordance with University Laws and By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, and the University of Connecticut Student Code.
PROCEDURES/FORMS
UConn Storrs and Regional Campuses:
Information and Compliance Form for Subrecipients
OVPR SPS Subaward Website
UConn Health:
Subaward/Project Agreement Request Form
Information and Compliance Form for Subrecipients
OVPR SPS Subaward Website
POLICY HISTORY
Policy approval date: December 12, 2022 (Approved by Senior Policy Council)
This policy combines previous policies at Storrs/regional campuses, and UConn Health to create one common policy at Storrs/regional campuses, and UConn Health:
Storrs/Regional Campuses Policy, “Subrecipient Monitoring,” created on 3/22/2013, and revised on 6/18/2015
UConn Health Policy 2002-27, “Compliance with Subrecipient Standards of OMB Circular A-133,” created on 2/25/2002, and revised on 11/8/2016
Revisions: Non-substantive revision 09/05/2024