Office of the VP for Research

Malign Foreign Talent Program Participation Policy

Posted on by
Title: Malign Foreign Talent Program Participation Policy
Policy Owner: Office of the Vice President for Research, Research Security Services
Applies to: Covered Individuals, as defined
Campus Applicability: All Campuses, including UConn Health
Approval Date: August 6, 2024
Effective Date: August 7, 2024
For More Information, Contact: Director, OVPR Research Security Services
Director, 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

To maintain the integrity of research conducted at or under the auspices of UConn and UConn Health. This policy establishes the University’s compliance framework for researchers to comply with the requirements set forth in section 10632 of the CHIPS and Science Act of 2022 (42 U.S.C. 19232) related to participation in Malign Foreign Talent Recruitment Programs.

APPLIES TO

This policy applies to Covered Individuals working on Federally Funded Research administered through or otherwise conducted under the auspices of the Covered Individual’s University affiliation, appointment, or employment.

DEFINITIONS

Covered Individual: An individual who— (A) contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a Federal Research Agency; and (B) is designated as a Covered Individual by the Federal Research Agency concerned. Covered Individuals may be named on the Federally Funded Research Award.

Federally Funded Research: Any research for which a grant, contract, or other agreement with any federal government agency exists, including but not limited to, the Department of Defense, the Department of Energy, the Public Health Service, the National Aeronautics and Space Administration and the National Science Foundation.

Federal Research Agency: Any agency of the U.S. federal government that provides funding for research, including but not limited to, the Department of Defense, the Department of Energy, the Public Health Service, the National Aeronautics and Space Administration and the National Science Foundation.

Foreign Country of Concern: A country that the U.S. federal government has designated under the International Religious Freedom Act of 1998 as a country whose government has engaged in or tolerated “particularly severe violations of religious freedom.” The list of Countries of Concern is maintained by the Department of State and is updated annually.

Malign Foreign Talent Recruitment Program (MFTRP):  A talent program requiring one or more problematic actions and having problematic sponsorship (CHIPS and Science Act of 2022, 42 U.S.C. § 19232). A detailed approach to the definition is available here.

POLICY STATEMENT

In accordance with section 10632 of the CHIPS and Science Act of 2022, which prohibits Federal Research Agencies from making awards to individuals who are party to a Malign Foreign Talent Recruitment Program, Covered Individuals listed in a Federally Funded Research award, contract or in a proposal for federal funding, whether directly or through a subaward, are prohibited from participating in a Malign Foreign Talent Recruitment Program. The University of Connecticut continues to support and encourage openness in research and international collaborations that do not take the form of a Malign Foreign Talent Recruitment Program.

UConn Certification

Sponsored Programs must  certify that all Covered Individuals on proposals submitted to a Federal Research Agency have been made aware of the requirements under section 10632 of the CHIPS and Science Act of 2022 related to Malign Foreign Talent Recruitment Programs and are in compliance with those requirements.

Roles and Responsibilities

The Principal Investigator of a Federally Funded Research award will ensure all Covered Individuals on the award understand their responsibilities under this policy and will report any concerns to Research Security Services for review.

Covered Individuals: Each Covered Individual listed in a proposal for a research award from a Federal   Sponsor must certify as part of the proposal submission that they are not currently participating in, nor will they participate in, a Malign Foreign Talent Recruitment Program. Upon receipt of the award, such certification must be renewed annually for the duration of the award.

OVPR Conflict of Interest (COI) Service: Will collect COI reporting forms from Covered Individuals

Office of the General Counsel: Will advise Research Security Services with the review of activities that may be considered Malign Foreign Talent Recruitment Programs.

Faculty Consulting Offices:  Will review consulting requests for involvement in a Malign Foreign Talent Recruitment Program and will facilitate the review of any requests of activities occurring in or with an entity of a maligned foreign country in coordination with Research Security Services

Research Security Services: Will review activities that may be considered Malign Foreign Talent Recruitment Programs in coordination with all relevant offices.

Sponsored Program Services: Will collect certifications from Covered Individuals on a per-proposal basis and for funded awards confirm on an annual basis and will certify to Federal  Agencies that this policy exists and, if required, that Covered Individuals are compliant with this policy.

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.

Participation in a Malign Foreign Talent Recruitment Program will prevent a Covered Individual from participating in a Federally Funded Research award. Covered Individuals who participate in a Malign Foreign Talent Recruitment Program after commencing work on Federally Funded Research will be removed from Federally Funded Research.

REFERENCES

CHIPS and Science Act of 2022, 42 U.S.C. § 19232

POLICY HISTORY

Policy created: 08/06/2024 (Approved by Senior Policy Council and President)

 

Financial Commitments to Institutional Training Grants and Nationally Competitive Graduate Fellowships

Posted on by
Title: Financial Commitments to Institutional Training Grants and Nationally Competitive Graduate Fellowships
Policy Owner: Vice Provost for Graduate Education and Dean of The Graduate School
Applies to: Faculty and Graduate Students
Campus Applicability: All campuses, including master’s and PhD programs at UConn Health, and excluding the UConn School of Law
Approval Date: June 27, 2024
Effective Date: July 1, 2024
For More Information, Contact Office of the Vice Provost for Graduate Education and Dean of The Graduate School
Contact Information: (860) 486-3167
Official Website: http://grad.uconn.edu/

 

BACKGROUND

Institutional Training Grants and Nationally Competitive Fellowships provide essential financial support for graduate students, including Stipends and partial coverage of tuition and health insurance costs. The Institutional Allowance associated with these grants and fellowships for tuition and health insurance often falls short of the total cost. This gap in funding can place a financial burden on students. The University's commitment to providing additional subsidies aims to bridge this funding gap, ensuring that graduate students can pursue their studies without financial hardship.

PURPOSE

To outline the financial commitments from the University that help ensure students supported on Institutional Training Grants or Nationally Competitive Fellowships are not responsible for tuition payments to the University and that they receive a health insurance subsidy equivalent to the subsidy available to graduate students who hold graduate assistantships.

APPLIES TO

This policy applies to all graduate students supported on an Institutional Training Grant or Nationally Competitive Fellowship and to faculty teams to whom an Institutional Training Grant is awarded.

DEFINITIONS

Institutional Allowance: Funds provided by an Institutional Training Grant or Nationally Competitive Fellowship to defray a portion of the tuition for full-time enrollment and the cost of health insurance.

Institutional Training Grant: A competitively awarded grant from an external organization or agency provided to teams of faculty for the purpose of training graduate students in specific disciplines, which often complements faculty research. These grants offer important financial support for graduate students, including Stipends.

Nationally Competitive Fellowship: A fellowship available to U.S. graduate students that is awarded by a federal agency or other external organization to individual graduate students who apply and who are selected by a review panel overseen by the awarding agency or organization.

Stipend: A Stipend is an allowance provided by either an Institutional Training Grant or a Nationally Competitive Fellowship intended to support living expenses of the graduate student supported by the award.

POLICY STATEMENT

The University may provide tuition and health insurance subsidies to bridge the gap between an Institutional Allowance associated with Institutional Training Grants or Nationally Competitive Fellowships and a graduate student’s total cost of tuition and health insurance. To qualify for the tuition and health insurance subsidies available under this policy the following conditions apply:

  1. Institutional Training Grants: Students supported on the Institutional Training Grants listed below will receive subsidies for tuition and health insurance if the Vice Provost for Graduate Education and Dean of The Graduate School has approved the Institutional Allowance in the budget request associated with the grant proposal before the grant has been submitted. The faculty member or team must apply for the maximum Institutional Allowance available under the award. Graduate students supported on Institutional Training Grants not listed below may receive subsidies at the discretion of the Vice Provost for Graduate Education and Dean of The Graduate School provided the Institutional Allowance associated with the grant covers a substantial fraction of the total cost of tuition and health insurance and the faculty applied for the maximum Institutional Allowance available under the award.
    • Department of Education – Graduate Assistance in Areas of National Need
    • National Institutes of Health – Ruth L. Kirschtein Institutional Awards (T32, )
    • National Science Foundation – National Research Traineeship
    • National Institute for Occupational Safety and Health (NIOSH) – Training Grants
    • Department of Agriculture – National Needs
  1. Nationally Competitive Fellowships: Students supported on the Nationally Competitive Fellowships listed below will receive subsidies for tuition and health insurance. Students supported on other nationally competitive fellowships may receive subsidies at the discretion of the Vice Provost for Graduate Education and Dean of The Graduate School provided the fellowship offers an annual Stipend equal to or greater than Level I graduate assistantship (9-month) Stipend as well as an Institutional Allowance determined to be adequate by the VP and Dean.
    • National Defense Science & Engineering Grad Fellowships (NDSEG)
    • National Institutes of Health - Ruth L. Kirschstein Predoctoral Individual National Research Service Award (F31)
    • National Science Foundation – Graduate Research Fellowship
  1. Notification Requirement: Faculty teams leading an Institutional Training Grant and the home departments of students holding a Nationally Competitive Fellowship must notify the Vice Provost for Graduate Education and Dean of The Graduate School of all supported students at least six weeks before the beginning of each semester.
  2. Graduate Students: Graduate students receiving subsidies must register as full-time students. They are responsible for mandatory fees associated with enrollment unless the award specifically mandates that the Institutional Allowance is intended to cover fees as well as tuition. Graduate students must also pay a portion of the health insurance premium equivalent to that charged to graduate assistants in similar circumstances.

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.

POLICY HISTORY

Policy created:   06/27/2024 Approved by the Senior Policy Council and the President

Revisions:                         

Replaces:  Policy on Competitive Federal Graduate Fellowship Awards; Policy on Competitive Non-Federal Graduate Fellowship Awards

Subrecipient Monitoring, Policy on

Posted on by
Title: Subrecipient Monitoring, Policy on
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.

  1. 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.
  2. Submits documentation with proposal for review and approval to Sponsored Program Services (SPS).
  3. 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.
  4. Monitors expenditures of the subaward to confirm that funding provided to the subrecipient is used for purposes authorized in the subaward.
  5. 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.
  6. Approves invoices for payment. Delegation of this approval may be assigned to a programmatic responsible individual who is managing the subrecipient.
  7. Notifies SPS when problems arise regarding invoicing or performance.

Fiscal Officer (FO)/Department Administrator (DA):

  1. Assists PIs with administrative tasks associated with their monitoring responsibilities, as specified
    above.

Sponsored Program Services:

  1. If not yet submitted by PI and/or FO/DA, collects necessary forms and information, when applicable, from subrecipients.
  2. Initiates a pre-qualification review of subrecipient, and verifies subrecipient/vendor determination.
  3. 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.
  4. 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.
  5. 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.
  6. Negotiates and executes subaward agreements between the University and subrecipients, including appropriate language requiring adherence to federal regulations and other sponsor requirements, as applicable.
  7. 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.
  8. Documents compliance certifications.
  9. Coordinates changes to project budgets or expenditures that require University or sponsor prior approval.
  10. Performs a final review of costs charged and facilitates proper close-out of all commitments.
  11. 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.
  12. Ensures that the University’s subrecipient monitoring procedures are compliant with Federal, non- Federal, and other applicable regulations.
  13. Provides training and guidance in interpreting regulations, subaward terms and conditions and executing these guidelines and requirements.
  14. 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

Effort Reporting and Certification, Policy on

Posted on by
Title: Effort Reporting and Certification, Policy on
Policy Owner: The Office of the Vice President for Research (OVPR)
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)

BACKGROUND

The Uniform Guidance Subpart E 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The University’s practice is to utilize an after-the-fact effort reporting system to certify that salaries charged, or cost shared to sponsored awards, are reasonable and consistent with the work performed.

PURPOSE

To ensure the University’s compliance with OMB Uniform Guidance 2 CFR 200.430, the university uses an after-the fact effort reporting and certification system, which is a University process designed to meet regulatory requirements for maintaining records that accurately reflect the work (effort) performed on sponsored projects including all personnel expenses charged directly to a sponsored project or to an institutional account, as well as cost-sharing (i.e., committed effort that is not directly charged to the award) or match requirements in fulfilling a commitment to a sponsor.

APPLIES TO

All faculty, staff, and students involved in the administration of sponsored programs at the University of Connecticut and all regional campuses, and UConn Health (“University”).

DEFINITIONS

Principal Investigator (PI), Co-Principal Investigator (Co-PI): The individual(s) deemed responsible for the conduct, direction, and administration of a specific sponsored program.

Effort Certification: The Effort Certification Statement documents the proportion of time devoted to sponsored projects, teaching, clinical practice, and other activities, expressed as a percentage of University effort.

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,” (2 CFR Part 200).

POLICY STATEMENT

Per Uniform Guidance, the University must maintain a system of distributing salary charges to federal awards that results in a reasonable allocation of salary charges to each award. The salary distribution system must also include a periodic review to confirm the reasonableness of salary charges to the federal projects. Effort directly charged to sponsored projects and any committed cost shared effort must be identified in the University’s effort distribution/reporting system.

Under these standards, records must:

  1. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
  2. Be incorporated into the official records of the University;
  3. Reasonably reflect the total activity for which the employee is compensated by the University, not to exceed 100% of compensated activities;
  4. Encompass both federally assisted and all other activities as compensated by the University;
  5. Support the distribution of the employee’s salary or wages among each specific activity or cost objective on which the employee

The University employs an After-the-Fact effort reporting system that provides the principal means for certifying that the effort charged to sponsored projects are reasonable and consistent with the portion of total professional activity committed to the projects.

Effort reports are to be reviewed and certified by the individual named on the report, Principal Investigator (PI)/Designee, Co-Principal Investigator (Co-PI) or other responsible official. The Faculty member, PI/Co-PI/Designee, or responsible official shall have reasonable means of verifying that the salaries or cost-shared commitments to sponsor awarded activities reasonably reflect the activities for which they are compensated.

Effort reports and accompanying certifications shall be prepared periodically within the year as per the Effort Reporting and Certification Procedures at either Storrs and the regional campuses or UConn Health.

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.

Failure to follow the provisions of this policy or the timelines as delineated in either the Storrs/regional campuses or UConn Health Effort Reporting Procedures may subject the individuals and responsible departments to disciplinary actions or sanctions until the effort reports are up to date and properly completed and certified. At the discretion of the Sponsored Program Services Director, possible disciplinary actions may include:

  1. Removing and transferring salary costs associated with uncertified grant activity to a faculty discretionary or departmental account;
  2. Freezing spending for accounts with uncertified grant activity;
  3. Suspending a noncompliant faculty member’s new proposal submission or not permitting the inclusion of a noncompliant researcher in new

PROCEDURES/FORMS

Storrs and Regional Campuses:
Effort Reporting and Commitments (ERC) Guidance

UConn Health:
Award Management System (AMS) Committed Effort Module

POLICY HISTORY

Policy approval date: December 12, 2022

This policy combines previous policies at Storrs/regional campuses and UConn Health and establishes one shared policy for Storrs/regional campuses, and UConn Health:
Storrs/Regional Campuses Policy, “Effort Reporting,” created on 3/19/18, and revised on 4/6/2018
UConn Health Policy 2002-08, “Effort Reporting,” created on 2/25/02 and revised on 11/8/2016

Sponsored Project Expenditures: Approval and Monitoring, Policy on

Posted on by
Title: Sponsored Project Expenditures: Approval and Monitoring, Policy on
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

Sponsored project expenditures must be in accordance with standards set forth by the sponsor.  Federal expenditures must comply with the Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR Part 200, commonly referred to as Uniform Guidance. Adherence to these cost principles is necessary to prevent cost disallowances, penalties, and/or fines. Expenditures on sponsored projects must conform to individual sponsor requirements.

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

Direct Costs: Those costs that can be identified specifically with a particular sponsored project and that can be directly assigned to such activities relatively easily and with a high degree of accuracy.

Facilities and Administrative Costs (F&A): Those costs that are incurred for common or joint objectives that cannot be readily identified with an individual project or program.

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.”

POLICY STATEMENT

This policy outlines the standards for the allowability of a charge to a grant and the approval and monitoring of expenditures to ensure compliance with federal and state requirements, sponsor terms, and University policy.

Sponsored projects administration is a joint effort between the Principal Investigator (PI) and the University. The PI is responsible and accountable for the management and administration of his/her/their award within the constraints imposed by the sponsor and in accordance with UConn policy. Along with the PI, the University is legally and financially responsible and accountable to the sponsor for the performance and proper use of funds for the award, and relies on the oversight of the PI in fulfilling its stewardship role.

All costs charged to a sponsored project must be in conformance with the award terms and conditions of the sponsored project, the Uniform Guidance in the case of federal sponsored projects, federal and state law, and University policy.

I. Federal Regulations: The Uniform Guidance

Per Uniform Guidance (§200.403), in order for a direct cost to be an allowable cost on a sponsored project, the cost must:

a. Be necessary and reasonable for the performance of the federal award and be allocable under these principles;
b. Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items;
c. Be consistent with policies and procedures that apply uniformly to both federal and non-federal activities of the University;
d. Be accorded consistent treatment. (A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost);
e. Be determined in accordance with generally accepted accounting principles (GAAP);
f. Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period;
g. Be adequately documented.

Subpart E of the Uniform Guidance provides general provisions for selected items of costs. In accordance with this part, the following costs are unallowable:

  1. Meetings, conventions, convocations, or other events related to other activities of the entity (University) (200.421(e)(2));
  2. Alcoholic beverages (200.423);
  3. Alumni/ae activities (200.424);
  4. Bad debts (200.426);
  5. Costs of contributions and donations, including cash property and services, from the non- federal entity to other entities (200.434(a));
  6. Costs of goods or services for personal use (200.445(a));
  7. Costs related to securing patents and copyrights where the costs to prepare disclosures, reports, and searching the art are not required by the federal award or where the federal award does not require conveying title or a royalty-free license to the federal government in the case of filing and prosecuting any foreign patent application (200.448(2));
  8. Costs incurred for interest on borrowed capital, temporary use of the endowment funds, or the use of the non-federal entity’s own funds (200.449(a));
  9. Lobbying to influence activities associated with obtaining grants, contracts, cooperative agreements or loans, and executive lobbying costs (200.450(a) and 200.450 (b));
  10. Losses on other awards or contracts (200.451);
  11. Membership costs in any country club or social or dining club or organization and membership costs in organizations whose primary purpose is lobbying (200.454(d) and 200.454(e));
  12. Selected relocation costs such as loss on the sale of a former home and continuing mortgage principal and interest payments on a home being sold (200.464(d));
  13. Student activity costs (200.469);
  14. Travel costs for dependents when the duration is less than six months (200.475(c)(2)) (University policy does not allow reimbursement for dependent travel costs);
  15. In addition to the list above, the federal sponsor may not allow other costs in accordance with sponsor policy and the terms of the award.

II. Direct Cost Expenditure

Principle Investigators have the responsibility to verify that charges on his/her/their awards are allowable. Investigators may receive assistance on financial tasks from the Fiscal Officer (FO) at Storrs and regional campuses, or the Department Administrator (DA) at UConn Health, and Sponsored Program Services (SPS). However, the PI retains the responsibility for the review and approval of charges on his/her/their sponsored project(s). PIs review and approval of expenditures is to assure that:

  1. for federal awards, direct costs meet the standards of an allowable cost per the Uniform Guidance (see “I.” above);
  2. direct costs meet the specific terms of the project and are reasonable, allocable, and allowable;
  3. expenditures occur within the project period;
  4. expenditures are appropriately documented;
  5. expenditures meet the limitations of the sponsor-approved budget.

III. Expenditure Review

Transaction review and budget monitoring are essential components of an integrated system of control activities. Along with preventative controls, after the fact financial reviews provide reasonable assurance, but not absolute assurance, that financial activity is accurate, valid, and complete.

  1. The PI will make a timely review of project expenditures and remaining balances;
  2. The PI and FO/DA will review reports of expenditures charged to each sponsored project to ensure allowability and to take prompt corrective action when costs are determined to be unallowable. The PI and FO/DA will monitor the budget and submit rebudget requests when necessary which are approved by SPS.

IV. Prior Approval for Certain Expenditures

Sponsor prior approval is often required for certain direct cost expenditures. The Uniform Guidance, sponsor grant policy, and the award terms and conditions include these requirements. For non-federal sponsors, if the award does not include specific requirements, Principal Investigators should follow the guidance for federal grants and cooperative agreements unless otherwise approved by the sponsor and the University. For federally funded awards, and in accordance with the Uniform Guidance (200.407), prior written approval from the sponsor is required before the expense can be incurred. Common examples of these types of costs include the addition of a subaward or purchase of equipment that was not included in the proposal and administrative expenses.

V. Roles and Responsibilities

Principal Investigator (PI):
Except as noted, these steps may be performed by another investigator on the project or technical designee.

  1. Apply the factors of allowability (in accordance with the Uniform Guidance for federal awards) regarding a cost prior to requesting, incurring, or processing an expenditure. Provide and/or maintain documentation of the appropriateness of the expense in conjunction with the project.
  2. Provide the FO/DA documentation or maintain such documentation of the expenses of the project.
  3. Authorize requests for expenditures including goods, services agreements, subawards, and personnel expenses;
  4. Ensure expenditures occur within the project period;
  5. Monitor and approve payments for consultant services and subawards (PI approval);
  6. Monitor project expenditures to confirm they are allowable, allocable, and reasonable and promptly request the FO/DA make corrections upon identifying a charge that needs to be removed from the project;
  7. Approve all cost transfers;
  8. Monitor budgets and submit, or have the FO/DA submit, budget revisions to Sponsored Program Services;
  9. Obtain prior approval through SPS when required by the sponsor’s terms and conditions before funds are committed or expended on the sponsored project (PI approval).

Fiscal Officer (FO)/Department Administrator (DA):

  1. Apply the factors of allowability (in accordance with Uniform Guidance for federal awards) prior to approving an expenditure;
  2. Ensure PI or his/her/their designee provides adequate justification/documentation of the expense on the project;
  3. Review reports of expenditures charged to each sponsored project to ensure expenditures are allowable and review any reconciling items or budget overruns with PI and aid in the submission of cost transfers and/or rebudget requests;
  4. Alert the PI and/or SPS to issues and concerns.

Sponsored Program Services (SPS):

  1. Apply the factors of allowability (in accordance with Uniform Guidance for federal awards) prior to approving an expenditure;
  2. Review and approve purchase requisitions as required in the University’s financial system and subawards;
  3. Review and approve cost transfer requests;
  4. Process non-payroll and certain payroll cost transfers in the University’s financial system;
  5. Facilitate, review, and approve sponsor prior approval requests;
  6. Review and approve rebudget requests;
  7. Process budget revisions in the University’s financial system;
  8. Monitor grant expenditures and review all expenditures prior to financial closeout and ensure all unallowable expenses are removed.

Accounts Payable/Payroll/Procurement

  1. Ensure expenditures are in compliance with University requirements.

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:

Direct and Indirect Costs of Federal Grants and Contracts, Policy CADS1
General Cost Principles
Federal Costing Principles Training Slides
Cost Transfer Policy

UConn Health:

Budget Preparation Guidelines and General Cost Principles
Federal Costing Principles Training Slides
Cost Transfer Policy

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 for Storrs/regional campuses, and UConn Health:
Storrs/Regional Campuses Policy, “Sponsored Project Expenditures: Approval and Monitoring,” created on 2/26/18
UConn Health Policy 2002-39, “Direct Costs Expenditures,” created on 2/25/2002, and revised on 11/8/2016

Principal Investigator Eligibility on Sponsored Projects, Policy on

Posted on by
Title: Principal Investigator Eligibility on Sponsored Projects, Policy on
Policy Owner: Office of the Vice President for Research, Sponsored Program Services
Applies to: All faculty, staff, and students
Campus Applicability: All Campuses, including UConn Health
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

This Policy sets forth the eligibility requirements for serving as a Principal Investigator (PI) or Co- Principal Investigator (Co-PI) at the University. This Policy also describes the processes for requesting and approving exceptions to the PI/Co-PI eligibility requirements.

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

Principal Investigator (PI): This title identifies the individual, identified and determined by the grantee who is responsible for the conduct of the sponsored program project. This responsibility includes the intellectual conduct of the project, fiscal accountability, administrative aspects, and the project’s adherence to relevant policies and regulations. A project may have multiple individuals serving as PIs (multi- PIs) who share the authority and responsibility for leading and directing the project, intellectually and logistically. Each PI is responsible and accountable for the proper conduct of the project.

Co-Principal Investigator (Co-PI): This designation refers to individuals who share the responsibility for the project with the Principal Investigator and therefore requires the same qualifications.

Project Director/Co-Project Director: Although not as commonly used by sponsors, this title is a synonym for Principal Investigator and Co-Principal Investigator respectively.

POLICY STATEMENT

All externally funded projects conducted at the University are expected to be consistent with the teaching, research, and service missions of the University. All projects are therefore carried out within departments, centers or institutes, or other administrative units under the direction of a faculty member or comparable professional employee.

By defining Principal Investigator status as a limited set of designated individuals and/or job categories, and by procuring appropriate dean and department head approval, the University is assured that the proposed research is consistent with its missions and that the necessary space, equipment, facilities, and qualified personnel are available to conduct the proposed project. In all cases, the individual designated  as Principal Investigator is judged to be qualified to conduct an independent research or educational project. In addition, eligible faculty must meet all other University or sponsor requirements to serve as a PI.

Faculty members eligible to serve as Principal Investigators include members of the emeritus faculty and those faculty members who hold the following titles or rank*:

• Professor*
• Associate Professor*
• Assistant Professor*
• Research Scientist
• Research Scholar
• Research Instructor

*These ranks include academic faculty, research faculty, clinical faculty, and other full-time faculty, with the exception of visiting faculty or other short-term appointments.

Professional staff normally eligible to serve as Principal Investigator:
Professional staff members normally eligible to serve as Principal Investigators include staff who hold titles typically associated with independent activity, whose appointment is subject to a rigorous review of credentials, and who have supervisor approval (i.e., signature on the proposal routing sheet), including:

• Dean
• Associate Dean
• Assistant Dean Director
• Associate Director
• Assistant Director
• Curator
• Educational Program Managers
• Program Director

Categories of employment normally considered ineligible to serve as Principal Investigator:

• Instructor
• Assistant Instructor
• Lecturer
• Post-doctoral Appointees, other than those receiving a fellowship
• Research Associates
• Research Assistants and fellows
• Visiting and other short-term appointees
• Students, other than those receiving a fellowship

Exceptions:
In special cases, exceptions may be made. These special cases require the approval of the appropriate Faculty Sponsor, Department Chair, Dean and Sponsored Program Services prior to proposal submission. In the case of a denial by Sponsored Program Services, appeals may be directed to the Associate Vice President for Research, Sponsored Program Services.

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

Storrs and Regional Campuses:
Request for Approval to Serve as Principal Investigator Form

UConn Health:
Request to Serve as Principal Investigator Form

POLICY HISTORY

Policy approval date: December 12, 2022

This is a new policy combining two previous and separate policies at Storrs/regional campuses, and UConn Health and establishes one shared policy for Storrs/regional campuses, and UConn Health:
Storrs/Regional Campuses Policy, “Principal Investigator Eligibility,” created on 6/5/2009, and revised on 6/22/2015
UConn Health Policy 2008-05, “Senior/key personnel & Committed Effort,” created on 12/16/2008, and revised on 10/8/2013

Negotiation and Acceptance of Sponsored Program Awards, Policy on

Posted on by
Title: Negotiation and Acceptance of Sponsored Program Awards, Policy on
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

This policy documents the authority for the review, negotiation, and acceptance of all grants and contracts for sponsored programs to ensure compliance with University policies, mission, sponsor requirements, and state and federal regulations.

APPLIES TO

All faculty, staff, and students involved in the administration of sponsored programs at the University of Connecticut and all regional campuses, and UConn Health (“University”).

DEFINITIONS

Award: Formal document from a sponsor/funding agency obligating funds to the University for a specific project.

Contract: A written agreement that represents a legal obligation for both the sponsor and the University. Each contract contains a scope of work and/or deliverables to be performed in exchange for consideration, typically in the form of compensation.

Grant: Type of financial assistance awarded to an organization for the conduct of research, scholarship, or other programs, as specified in an approved proposal.

POLICY STATEMENT

The review, negotiation, and acceptance of the terms and conditions of all sponsored program grant awards and contracts are the responsibility of Sponsored Program Services (SPS) in collaboration with the Principal Investigator(s) of the project.

ROLES AND RESPONSIBILITY

Principal Investigator (PI)/Department Administrator:

1. Responsible for the scientific/academic content and budget of the project, and must ensure that the agreement reflects PI’s understanding of what is proposed to be accomplished over a specified time, and that there are sufficient funds to cover the project through the period.
2. Ensure that the schedule for and the nature of any technical or progress reports or other deliverables are acceptable to the sponsor.
3. Advise SPS of any issues that the PI has with any terms of the award or contract.
4. Ensure that work does not begin on the project until the award is accepted or contract is fully executed, or unless special approval has been received to set up a pre-award account for the project.
5. May not accept or execute sponsored program awards and/or contracts on behalf of the University.

Sponsored Program Services:

1. In collaboration with the Principal Investigator(s), ensure that the terms and conditions of the award and/or contract are in compliance with University policies and mission.
2. Consult with, refer to, or seek guidance from appropriate internal and external entities and individuals prior to accepting an award or executing a contract.
3. Work with relevant University units to ensure compliance with relevant policies and regulations, including but not limited to human subjects, human subjects’ data, vertebrate animals, export controls, and financial conflicts of interest.
4. Authorized Official(s) to accept sponsored project awards and execute sponsored project related contracts on behalf of the University.

Research Compliance:

1. Provide advice and guidance, as needed, on areas such as human subjects, human subjects’ data, vertebrate animals, export controls, and financial conflicts of interest.

Technology Commercialization Services:

1. Provide advice and guidance, as needed, on areas such as complex intellectual property terms and royalty and licensing arrangements.

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

Storrs and Regional Campuses:

Guidance – Sponsored Program Services: Awards
Guidance – Sponsored Research Agreements

UConn Health:

Guidance – Sponsored Program Services: Awards
Guidance – Sponsored Research Agreements
Guidance – When to Use the IPAS form

POLICY HISTORY

Policy approval date: December 12, 2022 (Approved by Senior Policy Council)

This is a new policy at Storrs/regional campuses to better document established practices and procedures. The policy combines two previous policies at UConn Health and establishes one shared policy for Storrs/regional campuses, and UConn Health:
UConn Health Policy 2002-33, “Acceptance of Awards,” created on 04/10/02
UConn Health Policy 2002-32, “Negotiation of Awards,” created on 04/10/02

Effort on Sponsored Program Activities, Policy on

Posted on by
Title: Effort on Sponsored Program Activities
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: January 24, 2020
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)

REASON FOR POLICY

Effective January 5, 2001 by Presidential Review Directive and clarification memo issued by the Office of Management and Budget (OMB) to 2 CFR Part 220 (as codified from Circular A-21) and most recently OMB Uniform Guidance 2 CFR Part 200, it is expected that “most Federally-funded research programs should have some level of committed faculty (or senior researchers) effort, paid or unpaid by the Federal government. This effort can be provided at any time within the fiscal year (summer months, academic year, or both).” The clarification memo also states that, “…Some types of research programs…do not require committed faculty effort, paid or unpaid by the Federal government…”

The National Institutes of Health (NIH) Grants Policy Statement asserts that “‘zero percent’ effort or ‘as needed effort’ is not an acceptable level of involvement for ‘key personnel.’”

The National Science Foundation revised its policy effective January 18, 2011 stating that except when required in an NSF solicitation, inclusion of voluntary committed effort cost sharing is prohibited.

APPLIES TO

All faculty, staff, and students at the University of Connecticut and all regional campuses, and UConn Health (“University”).

DEFINITIONS

University Effort: The portion of ‘total professional effort’ that comprises one’s professional/professorial workload at UConn for which the employee is compensated.  This includes activities such as research, instruction, other sponsored activities, administration, non-sponsored/departmental research, university service, competitive proposal preparation and clinical activities.

Committed Effort: Any part of ‘University effort’ that is quantified and included in a sponsored program proposal and/or the subsequent award (e.g., two summer months, 12% time, one half of a year, three person-months, etc.).  This quantified effort/time is associated with the specific dollar amount of the employee’s compensation and may be in the form of:

Direct Charged Effort:  Any portion of ‘committed effort’ toward a sponsored activity for which the sponsor pays salary/benefits.

Cost Shared Effort:  Any portion of ‘committed effort’ toward a sponsored activity for which the sponsor does not pay salary/benefits, which instead are paid using other, non-federal, or UConn sources.

Uncommitted Effort: Any portion of ‘University effort’ devoted to a sponsored activity that is above the amount committed in the proposal and/or the subsequent award.  This ‘extra’ effort is neither pledged explicitly in the proposal, progress report or any other communication to the sponsor nor included in the award documentation as a formal commitment. This effort must be paid by non-sponsored University sources.

POLICY STATEMENT

This policy establishes the effort requirements for sponsored programs.

Federal Sponsored Awards:

Investigators are expected to propose some level of sponsor supported effort or the minimum required by the program on proposals on which they are listed as Principal Investigator, Co-Principal Investigator, Co-Investigator or other roles as required by the sponsor unless specifically exempted by the sponsor.  (Examples of exceptions to the minimum proposed effort requirement would possibly include doctoral dissertations, equipment and instrumentation grants, travel grants, and conference awards.)  If an award is accepted, these personnel are committed to providing this level of effort, either through direct charge or cost shared effort, over the annual budget period of the award unless sponsor policies permit otherwise.

The minimum amount of effort committed to a specific federally sponsored research activity may be no less than 1% of the employee’s ‘University effort’ during some portion of the sponsored award or the minimum amount required by the sponsor.  Notwithstanding the foregoing and in accordance with OMB Clarification Memo, at least 1% of a senior faculty (or researcher) effort must be devoted to the project throughout the life of the award.

Non-Federal Sponsored Awards: 

University of Connecticut and Regional Campuses: The University does not require a minimum amount of effort except in cases required by the sponsor. However, Principal Investigators must ensure they have time available to complete the project that does not overlap or conflict with their effort commitments to other sponsors or their University responsibilities.

UConn Health Campus:  The minimum amount of effort committed to a specific non-federal sponsored activity may be no less than 1% of the employee’s ‘University effort’ during some portion of the sponsored award or the minimum amount required by the sponsor.

All Sponsored Awards:

Beyond the minimum amounts specified above, the specific amount of effort committed to a particular sponsored activity is left to the judgement of the individual devoting effort to the project and the Principal Investigator/Project Director, based on his or her estimate of the effort necessary to conduct the project.

Prior sponsor approval for a decrease in effort must be obtained prior to a reduction in effort if and when sponsor approval is required as determined by the sponsor’s terms and conditions.

ROLES AND RESPONSIBILITIES

Principal Investigator:

  1. The Principal Investigator is responsible for ensuring that the minimum level of effort required by this policy, 2 C.F.R. Part 200 (federal awards) and the requirements of the sponsor are met.

All Faculty and Investigators:

  1. Devote time commensurate with effort on each project, ensure that the effort does not conflict with commitments to other sponsors or University responsibilities and is in accordance with University policy.

Department Administrators/Fiscal Officers:

  1. Regularly review faculty/investigator effort on sponsored awards to ensure it meets with the requirements of this policy.
  2. Inform Sponsored Program Services if effort commitments may not be met.

Sponsored Program Services:

  1. Provide guidance and assistance to faculty, investigators and department administrators on this policy.
  2. Review changes to payroll allocations (UConn Health Campus) and effort reports (University of Connecticut and Regional Campuses).

 
ENFORCEMENT

Violations of this policy or associated 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, the University of Connecticut Student Code, other applicable University Policies, or as outlined in any procedures document related to this policy.

PROCEDURES/FORMS

Related Information:

See NSF Cost Sharing Policy Guidance

POLICY HISTORY

Policy created:

Approved by the President’s Cabinet on 09/12/2019. This new policy combines two previous policies at Storrs and UConn Health.

History: 

Storrs Policy, “Minimum Effort on Sponsored Program Activities”, created on 3/1/2013 and revised on 7/7/2015, as approved by the Vice President for Research

UCH Policy 2008-05, “Senior/Key Personnel & Committed Effort”, created on 12/16/08 and revised on 10/8/13

Cost Sharing Policy

Posted on by
Title: Cost Sharing
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: January 24, 2020
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)

REASON FOR POLICY

This policy is to meet the requirements of the Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) and federal agency policies and procedures. Non-federal sponsor cost share requires similar diligence to recognize the commitment and maintain appropriate documentation of its performance. Therefore, all committed cost sharing is subject to this policy.

APPLIES TO

All faculty, staff, and students involved in the administration of sponsored programs at the University of Connecticut and all regional campuses, and UConn Health (“University”).

DEFINITIONS

Cost sharing – the specific portion of project costs that are funded by the University rather than the sponsor in support of a sponsored program. Cost sharing represents payroll and other project costs that University and/or other project participants contribute to or match through the expenditure of funds or through in-kind contributions.

Cash contributions – a type of cost sharing that requires additional funding that can be documented in the accounting system. Examples include the purchase of a piece of equipment, or the allocation of compensated faculty or staff time, paid for by University funds.

In-kind contributions – non-cash contributions donated to the project.

Mandatory Cost Share – cost sharing required by the sponsor in order for an award to be made. Such requirements are generally incorporated in the funding opportunity announcements or solicitations, or required by federal statute and included as part of the proposal.

Voluntary Committed Cost Share – represents a cost sharing commitment made in the budget, budget justification, or identified elsewhere in the proposal that is not required by the sponsor. This type of cost sharing must be tracked and may need to be reported. Examples of this include a percentage of effort of faculty in a proposal for which compensation was not requested, or the purchase of equipment for the project for which sponsor funds have not been requested.

Voluntary Uncommitted Cost Share – represents a cost or contribution made to the project and not funded by the sponsor, which has not been identified in the proposal or in any other communication with the sponsor. This type of cost sharing does not have to be tracked or reported to a sponsor. An example is academic year effort on a project for which only summer salary was proposed.

Salary Limitation/Salary Cap – limitation imposed by the sponsor (e.g., DHHS salary cap) on the amount or rate of salary and/or of fringe benefits that can be charged to the project. Although the University may cover the difference between the limitation and the actual cost, this is not considered cost sharing and it is not tracked as cost sharing by the University.

POLICY STATEMENT

Expenditures must meet the standard terms and conditions of the award to be cost share. The costs are allowable in accordance with Uniform Guidance when they are:

  • Verifiable from the recipient’s records;
  • Not included as contributions for any other federally-assisted sponsored project or program;
  • Necessary and reasonable for proper and efficient accomplishment of project objectives;
  • Not paid by the Federal Government under another award, except where authorized by federal statute to be used for cost sharing or matching; and
  • Provided in the approved budget when required by the federal awarding agency.

The review and approval of all cost sharing is the responsibility of the unit providing the cost sharing and Sponsored Program Services. Mandatory and Voluntary Committed cost sharing must be approved prior to submission of the proposal to the sponsor, and must be in conformance with the award terms and conditions, the Uniform Guidance in the case of federally sponsored projects, federal and state law and University policy. Mandatory and Voluntary Committed cost sharing must be tracked by the University and reported to the sponsor (if required by the terms of the award).

The funding of cash cost sharing is the responsibility of the unit that has made the commitment. The PI or designee is required to report and confirm cost shared effort on Effort Reports. Records related to cost sharing must be retained for the period of time prescribed under relevant record retention policies.

Cost sharing, including the re-budgeting of direct-charged salary from a sponsored project to cost share account at UConn Health is permitted only with approval of the Department Chair, Dean, and the Office of Sponsored Program Services, or designees. When necessary, prior approval from the sponsor must also be obtained.

ROLES AND RESPONSIBILITIES

Principal Investigator:

1. Obtain approval for any mandatory and/or voluntary committed cost sharing prior to proposal submission.
2. Ensure cost sharing commitments are met.

Fiscal Officer/Department Administrator:

1. Track and monitor cost sharing commitments.

Sponsored Program Services:

1. Monitor cost sharing commitments.
2. Report on cost sharing when required by the sponsor.

ENFORCEMENT

Violations of this policy or associated 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, the University of Connecticut Student Code, other applicable University Policies, or as outlined in any procedures document related to this policy.

PROCEDURES/FORMS

Storrs and Regional Campuses:
Effort Reporting and Certification Policy

UConn Health:
Guidance – Cost Sharing (UCH)
NIH Salary Cap Guidelines
Budget Preparation Guidelines (UCH)
Budget Templates/Calculators (UCH)

POLICY HISTORY

Policy created:
Approved by the President’s Cabinet on 09/12/2019.  This is a new policy at Storrs and replaces a previous policy at UConn Health.

History:
UCH Policy 2002-14, “Cost Sharing/Matching Requirements”, created on 4/10/2002 and revised on 5/9/17.

Sponsored Award Closeout

Posted on by
Title: Sponsored Award Closeout
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: November 25, 2019
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)

REASON FOR POLICY

To ensure the thorough review of financial transactions in addition to other compliance requirements in accordance with the terms and conditions of the award prior to sponsored project closeout.  Unless stated otherwise by the terms and conditions of the Notice of Award, all applicable grant closeout reports are due no later than 120 days after the project end date. Failure to submit timely and accurate closeout documents may affect future funding to the University.

APPLIES TO

All faculty, staff, and students involved in the administration of sponsored programs at the University of Connecticut and all regional campuses andUConn Health (“University”).

DEFINITIONS

Closeout – The act of completing all internal procedures and sponsor requirements to terminate or complete a research project.

Progress/Technical Report – A technical description of the project results and additional information as required by the sponsor.  Additional information requested can include an abstract and a list of publications, patents, patent applications, and / or presentations at scientific meetings.

Final Financial Report/Invoice – Final report or invoice reflecting a summary of all transactions on an award.

Invention Statement – Document detailing all inventions conceived or first reduced to practice during the course of the project under the award and the inventing party.

POLICY STATEMENT

Prior to the closeout of a sponsored award, all applicable administrative actions and all required work of the sponsored award must be completed, including but not limited to financial reports, performance reports and deliverables as required by the terms and conditions of the sponsored award.  Note that final payment on an award may be contingent on the receipt of non-financial reports.

Responsibility for ensuring compliance with sponsored awards’ terms and conditions is shared between Sponsored Program Services (SPS), Principal Investigators (PI) and the fiscal officer/department administrator. The PI is responsible and accountable for the management and administration of his/her award within the constraints imposed by the sponsor and in accordance with University policy. The University is legally and financially responsible and accountable to the sponsor for the performance and proper use of funds for the award, and relies on the oversight of the PI in fulfilling its stewardship role. SPS will issue final financial reports to the sponsoring agency upon receipt of the approval of expenditures from the PI and/or designee.

All costs charged to a sponsored award must be in conformance with the award terms and conditions, the Uniform Guidance in the case of federally sponsored awards, federal and state law and University policy. Funds may not be obligated after the termination date of the sponsored award and all costs incurred on the award must benefit the award during the projects period of performance in accordance with the sponsoring award notice.

SPS has the authority to transfer unallowable costs, non-reimbursed expenditures or other disallowances as determined by the sponsor or the University under the terms of the sponsored award to an unrestricted account.

ROLES AND RESPONSIBILITIES

Principal Investigator:

  1. Ensures that any purchase orders for equipment, supplies or other materials, or services are executed prior to the end of the award performance period;
  2. Prior to the submission of the closeout financial report and within the required timeframe, reviews and approves expenditures to ensure they are allowable and allocable to the project. Further,  any required adjustments to expenses are posted in compliance with closeout policies and procedures;
  3. In collaboration with SPS, prepares and submits all required programmatic reports, which may include progress/technical reports and invention statements;
  4. Works with SPS to confirm final disposition of equipment purchased on the award in accordance with sponsor award notice;
  5. In collaboration with SPS, reviews the reported effort of key personnel to ensure agreement with the effort committed to the sponsor agency and addresses variances; and
  6. Ensure all other areas of compliance including but not limited to disposition of research animals, human subject information/records and protocols and disposition of hazardous materials are addressed in accordance with Federal, State, local and institutional regulations.

Fiscal Officer/Department Administrator:

  1. Monitors the costs charged to sponsored awards in accordance the terms and conditions of the award, relevant federal and state regulations and University policy.
  2. Ensures any outstanding vendor/subcontract invoices and any other subcontract obligations are approved and processed;
  3. Confirms final award expenditures; and
  4. Works with SPS and the PI to resolve any outstanding issues related to closeout.

Sponsored Program Services:

  1. Reviews charges made to accounts to ensure appropriateness;
  2. Reconciles Facilities and Administrative costs (F&A) charged to accounts and makes any necessary adjustments;
  3. In collaboration with the PI and Fiscal Officer/ Department Administrator may review the reported effort of key personnel to ensure agreement with the paid and committed effort reported to the sponsoring agency and addresses variances;
  4. Prepares and submits final financial information to the PI for review and approval;
  5. Ensures that financial reports and invoices are issued in a timely manner in accordance with sponsor requirements;
  6. Prepares and submits final Inventions/patent/property reports;
  7. Prepares and submits other non-financial reporting (e.g., Release and Assignment of Refunds, Rebates, Credits & Other Amounts forms); and
  8. Performs final review of account to ensure all pending action items (encumbrances, cash receipts, etc.) are completed and closes the account in the financial system.

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

Storrs and Regional Campuses:

Guidance – Award Management (Storrs and Regional Campuses)

UConn Health:

Guidance – Award Management (UCH)

Related

Sponsored Project Expenditures: Approval and Monitoring Policy (Storrs and Regional Campuses)

Policy on Effort Reporting and Certification (All Campuses)

Policy 2002-08:  Effort Reporting (UCH)

Policy 2002-21:  Interim and Final Financial Reports (UCH)

POLICY HISTORY

Policy created: Approved by the Board of Trustees on 12/11/2019.