Office of the VP for Research

Working Alone Policy

Title: Working Alone Policy
Policy Owner: Division of Environmental Health and Safety
Applies to: University Students
Campus Applicability: Storrs, Regionals, Law School
Effective Date: January 2013
For More Information, Contact Environmental Health and Safety
Contact Information: (860) 486-3613
Official Website: http://www.ehs.uconn.edu/

POLICY STATEMENT

No student is permitted to Work Alone in an Immediately Hazardous Environment.

REASON FOR POLICY

This policy has been developed to minimize the risk of serious injury while Working Alone with materials, equipment or in areas that could result in serious injury or an immediate life-threatening hazard.

APPLIES TO

This policy applies to undergraduate, graduate, and post-doctoral students performing academic or research related work at the University of Connecticut Storrs, regional campuses and the Law School.

DEFINITIONS

Working Alone means an isolated student working with an immediately hazardous material, equipment or in an area that, if safety procedures fail, could reasonably result in incapacitation and serious life threatening injury for which immediate first aide assistance is not available.

Immediately Hazardous Environment describes any material, activity or circumstance that could cause instantaneous incapacitation rendering an individual unable to seek assistance.  Examples include but are not limited to: potential exposure to poisonous chemicals and gases at a level approaching the IDLH (Immediately Dangerous to Life & Health); work with pyrophoric and explosive chemicals; work with pressurized chemical systems; entering confined spaces; work near high voltage equipment; work with power equipment that could pinch or grab body parts and/or clothing; etc.

Unit Managers are managers, supervisors, principle investigators, faculty, Department Heads and others who are responsible for assigning work to students that involve potential exposure to immediately hazardous environments.

Safety Content Expert is a safety professional from the UConn Department of Environmental Health and Safety (EHS).  EHS provides guidance to Unit Managers and their designees regarding the proper classification of campus activities as Immediately Hazardous or not; and provides safety information regarding proper procedures and personal protective equipment needed.

Direct Observation means the assigned second person is in line of sight or close hearing range with the individual working in an Immediately Hazardous Environment.

ENFORCEMENT

Violations of this policy may result in appropriate disciplinary measures in accordance with University Laws and Bylaws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements and the University of Connecticut Student Conduct Code.

RESPONSIBILITIES

Unit Managers are responsible for identifying the risks and conditions that may place a student in an Immediately Hazardous Environment.  If unsure about a specific task or location, Unit Managers are advised to contact EHS to assist in recognizing/evaluating risks, and to help in developing appropriate hazard controls. The Unit Manager is also responsible to see that personnel are properly trained, proper procedures are in place, and that proper personal protective equipment is readily available and use is mandatory. This is documented by means of the Workplace Hazard Assessment form.

If the task/area is deemed a Working Alone situation, the Unit Manager must either:

a) Assign a second person for the duration of the immediately hazardous task or for work in immediately hazardous locations (confined spaces, elevated work area, etc.); or

b) Reschedule the work to a time when others are available to help monitor the welfare of the assigned student.

All personnel are responsible for notifying the Unit Managers of situations that present the possibility of a student Working Alone in an immediately hazardous environment.

Personnel assigned to keep watch must provide Direct Observation at all times while students are in an Immediately Hazardous Environment to prevent a Working Alone situation.

Students are directly responsible for adhering to all safety procedures, wearing appropriate personal protective equipment and to be current in training requirements.  Students shall not Work Alone in an area or on tasks that have been recognized as an Immediately Hazardous Environment.

Environmental Health & Safety (EHS) personnel shall, upon request, assist in identifying Immediately Hazardous Environments and Working Alone situations.  EHS shall assist in the anticipation, recognition and evaluation of hazards and provide expertise in developing controls to prevent injuries to personnel.  EHS will verify submitted area Workplace Hazard Assessment during routine inspections.

Recommended Safety Information Resources

Refer to the EH&S website for additional workplace safety requirements:

Policies, programs and procedures

Training

Forms

Human Stem Cell Research Approval

Title: Human Stem Cell Research Approval
Policy Owner: Office of the Vice President for Research
Applies to: Employees, Faculty, Students, Other
Campus Applicability:  All Campuses
Effective Date: May 25, 2018
For More Information, Contact Office of the Vice President for Research
Contact Information: (860) 486-3001
Official Website: https://ovpr.uchc.edu/

REASON FOR POLICY

The purpose of this policy is to ensure that proposals for human embryonic stem cell (hESC) research and selected types of human induced pluripotent stem cell (iPSC) research are approved by the University’s Stem Cell Research Oversight (SCRO) Committee. This policy does not apply to primary cells isolated from human tissues that are not manipulated to become pluripotent.

The role of the SCRO Committee is to ensure that human embryonic stem cell (hESC) and selected types of human induced pluripotent stem cell (iPSC) research at all University of Connecticut campuses is well-justified and that inappropriate and/or unethical research is not conducted. The SCRO Committee facilitates the collaboration between researchers across University campuses by adopting nationally and internationally accepted standards designed to protect the University’s reputation for ethical and responsible research.

The review and approval of hESC research by the SCRO Committee (or its equivalent) is required by Connecticut law. The SCRO Committee review and approval is also required for all proposals funded by the State of Connecticut Regenerative Medicine Research Fund.

APPLIES TO

All University faculty, employees, students, postdoctoral fellows, residents and other trainees, and agents who supervise or conduct research involving hESCs and select types of iPSCs.

DEFINITIONS

Human Embryonic Stem Cell (hESC): Human embryonic stem cells are pluripotent cells that are self-replicating, derived from human embryos, and are capable of developing into cells and tissues of the three primary germ layers. Although human embryonic stem cells may be derived from embryos, such stem cells are not themselves embryos.

Human Induced Pluripotent Stem Cell (iPSC): Human induced stem cells are a type of pluripotent stem cell that have been artificially created by reprogramming non-pluripotent human cells through techniques that do not involve oocytes or embryos, e.g., through inserting genes into a somatic cell.

POLICY STATEMENT

All research projects in the following categories are required to obtain SCRO Committee approval before acquiring cells or cell lines and before commencing research:

  • All research involving hESCs and their derivatives;
  • All stem cell research involving human gametes and human embryos;
  • All stem cell research projects funded by the State of Connecticut, including those that do not use hESCs;
  • All in vitro human iPSC research involving the generation of gametes, embryos, or other types of totipotent cells; and
  • All in vivo research involving implantation of human iPSCs into prenatal animals or into the central nervous system of post-natal animals.

The SCRO Committee supplements but does not replace other University review processes (e.g., reviews by Institutional Animal Care and Use Committees (IACUC), Institutional Review Boards (IRB), Institutional Biological Safety Committees (IBC), etc.) and compliance with applicable legal requirements.

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, the University of Connecticut Student Code, and other applicable University Policies.

ADDITIONAL RESOURCES

Connecticut General Statutes §§ 4-28e and 32-41jj to 32-41mm, inclusive

NIH Stem Cell Information

 

Policy History

Revisions:

March 28, 2012; May 25, 2018 (Approved by President’s Cabinet)

Use Of Space Heaters in University Buildings

Title: Use Of Space Heaters in University Buildings
Policy Owner: Environmental Health & Safety/UConn Fire Department
Applies to: Faculty, Staff, Students, Others
Campus Applicability: Storrs and Regional Campuses, and the Law School
Effective Date: February 6, 2012
For More Information, Contact Division of Environmental Health and Safety
Contact Information: (860) 486-3613
Official Website: http://www.ehs.uconn.edu/

PURPOSE

As stated in the University’s Health and Safety Policy, the University of Connecticut is committed to providing a healthful and safe environment for all activities under its jurisdiction. In keeping with this commitment, the University has developed this policy to protect the University community and its visitors from the significant fire and workplace safety risks posed by the use of space heaters.  This policy is in keeping with the requirements of the Connecticut Life Safety and Building codes and ConnOSHA and CT Department of Public Health regulations.

SCOPE

This policy applies to the use of space heaters by faculty, staff, students, and others in University-owned buildings at the Storrs and regional campuses and at the Law School.

POLICY STATEMENT

Space heaters pose serious fire and electrical hazards, and are not efficient from an energy use standpoint; therefore, the use of space heaters at the University is strongly discouraged. Their use should be reserved for times of heating system failures rather than as a means for supplementing an existing heating system.

University building occupants should first contact Facilities Operations Work Order Control (6-3113) to request assistance in adjusting the temperature of an area.  If Facilities Operations personnel determine that the work area cannot be heated to the satisfaction of the occupant(s), the temporary use of space heaters will be allowed with the following exceptions:
Space heaters are not permitted in residential occupancies unless issued by permit through the UConn Fire Department in emergencies.  Space heaters are not permitted, under any circumstances, in laboratories, inpatient units, storage areas, or areas not actively occupied by people.  However, space heaters will be permitted in laboratory office spaces.

ENFORCEMENT

The University Fire Department and the Department of Environmental Health and Safety reserve the right to inspect and declare “unapproved” any space heater that creates a safety hazard or is inappropriate to a particular location, based on specific circumstances or legal requirements.  If warranted, space heaters may be removed from service and taken to a designated storage area for later collection by its owner and subsequent removal from the University.

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 Conduct Code.

PROCEDURES

Approved Heaters

In order to ensure that all space heaters meet current safety guidelines, the University Fire Department and the Department of Environmental Health and Safety have approved a limited selection of space heaters for use within the University, which are available at Central Stores.

See approved space heaters here.
Effective Fall Semester 2003, all other space heaters currently in use must be taken out of service.  Department-owned heaters must be turned in as surplus to Central Storrs.  Privately owned heaters must be removed from the University.

Safe Use and Care

  • BEFORE OPERATING A HEATER, ALWAYS READ AND FOLLOW THE MANUFACTURER’S OPERATING INSTRUCTIONS.
  • To prevent overloading an electrical circuit, a space heater must be plugged into a circuit that is rated for 15 amps or more.
  • Always turn off a heater and unplug it when you leave the office.  NEVER leave an operating heater unattended.
  • Before use, ensure that the heater is clean and not covered with dust.  The cord must be in good condition and not frayed.
  • NEVER use an extension cord or power strip with a space heater.  It should be plugged directly into a permanent wall outlet (receptacle). Exception: Radiant Panel heaters may be used with extension cords or power strips rated for 15 amps or more.
  • Never run a power cord under a carpet or floor mat.
  • NEVER use a heater where flammable materials or vapors may be present.
  • Do not use space heaters under desks or in other enclosed spaces.
  • Do not place a heater near combustible materials such as papers, fabric, plastics, or office furniture.
  • Do not place a heater in or near wet areas or in high traffic areas such as exit ways.
  • ALWAYS maintain safe distance clearances around space heaters, as directed by the manufacturers’ instructions.
  • Inspect space heaters at least annually and have them repaired, as needed, by a qualified electrician.
  • Heaters that cannot be repaired must be discarded with the plug cut off to prevent inadvertent use by others.
  • Avoid placing space heaters near room thermostats.

Principal Investigator Eligibility

Title: Principal Investigator Eligibility
Policy Owner: Office of the Vice President for Research, Sponsored Program Services
Applies to: Applies to all faculty, staff, students and others participating in sponsored program activities
Campus Applicability: All campuses except for UConn Health
Effective Date: June 22, 2015
For More Information, Contact Offices of the Vice President for Research and Sponsored Program Services
Contact Information: (860) 486-3622
Official Website: https://ovpr.uconn.edu/

 

REASON FOR POLICY

This Policy is intended to set forth the eligibility requirements for serving as a Principal Investigator (PI) at UConn.  This Policy also describes the processes for requesting and approving exceptions to the PI eligibility requirements.

DEFINITIONS

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

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

POLICY STATEMENT

All externally funded projects conducted at the University of Connecticut 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 limiting Principal Investigator/Project Director status to 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/Project Director is judged to be qualified to conduct an independent research or other educational project.

Faculty members automatically eligible to serve as Principal Investigators/Project Directors include members of the emeritus faculty and those faculty members who hold the following titles:

University Professor
Associate Professor
Assistant Professor
Research Professor
Associate Research Professor
Assistant Research Professor
Professor-in-Residence
Associate Professor-in-Residence
Assistant Professor-in-Residence
Research Scientist
Research Scholar
Extension Educator

Professional staff normally eligible to serve as Principal Investigator:

Professional staff members normally eligible to serve as Principal Investigators/Project Directors 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), such as:

Dean
Associate Dean
Assistant Dean
Director
Associate Director
Assistant Director
Extension Professor
Associate Extension Professor
Assistant Extension Professor
Curator
Program Director

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

Instructor
Assistant Instructor
Lecturer
Post-doctoral appointees
Research associates
Assistants and fellows
And visiting and other short-term appointees

Exceptions

In special cases, exceptions may be made. These special cases require the Request for Approval to Serve as Principal Investigator form be completed by the PI Applicant, signed by the PI Applicant, Faculty Sponsor, Department Head and/or Dean and submitted to SPS for review prior to proposal submission.  In the case of a denial by OVPR SPS, appeals may be directed to the Associate Vice President for Research, Sponsored Program Services.

PROCEDURES/FORMS

Please see OVPR SPS form: Request for Approval to Serve as Principal Investigator.

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.

POLICY HISTORY

Policy created:           6/5/2009

Revised:                    6/22/2015 (approved by the Vice President for Research)                  

 

 

Pre-Award/Advance Account Policy

Title: Pre-Award/Advance Account Policy
Policy Owner: Office of the Vice President for Research, Sponsored Program Services
Applies to: Faculty and staff conducting sponsored program activity at Storrs and the regional campuses
Campus Applicability:  All campuses except UConn Health
Effective Date: July 7, 2015
For More Information, Contact Office of the Vice President for Research, Sponsored Program Services
Contact Information: (860) 486-3622
Official Website: http://ovpr.uconn.edu

 

REASON FOR POLICY

To enable Principal Investigators (PI) who have demonstrated a need to begin project-related activity on sponsored projects prior to receipt of the award notice or executed contract.

APPLIES TO

Faculty and staff conducting sponsored program activity at Storrs and the regional campuses.

DEFINITIONS

Pre-Award Account:  A pre-award account will be used for federal grants where costs are allowed up to 90 days prior to the official start date of the award under expanded authorities granted to the University.

Advance Account:  Advance accounts will be established for those federal and non-federal awards not eligible for pre-award coding.  Costs can only be incurred on advance accounts as of the sponsor approved start date.

POLICY STATEMENT

The Office of the Vice President for Research, Sponsored Program Services (OVPR SPS) will establish Pre-Award or Advance Accounts under the following conditions:

There is a demonstrated need by the PI to incur expenditures prior to the proposed start date (pre-award accounts) or prior to receipt of the executed contract (advance accounts).  Acceptable reasons for requesting an account include, but are not limited to the following:

  • Making employment offers and completing payroll authorizations
  • Equipping a lab or purchasing supplies
  • Purchasing equipment early to take advantage of a discounted price

Accounts also require that:

  • A full copy of the proposal for the project is on file in OVPR SPS
  • OVPR SPS personnel are able to determine that pre-award expenditures are allowed, or in the case of advance accounts, it is likely that an award is forthcoming or contract will be executed
  • When applicable, required compliance approvals have been obtained

This policy does not apply to Federal earmark funding.

ROLES AND RESPONSIBILITIES

Principal Investigators are responsible for submission of pre-award or advance account requests that are consistent with this policy and in accordance with our published procedures.

OVPR SPS is responsible for responding to inquiries about this policy or procedures and approving account request.

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

See OVPR SPS website for Pre-Award or Advance Request Form.

POLICY HISTORY

Policy created:    2/19/2008

Revised:             7/7/2015 (Approved by the Vice President for Research)

Policy on Competitive Federal Graduate Fellowship Awards

Title: Policy on Competitive Federal Graduate Fellowship Awards
Policy Owner: Vice President for Research/Vice Provost for Graduate Education and Dean
Applies to: Students
Campus Applicability:  All Campues excluding the School of Law. Includes Masters/PhD. programs at UConn Health
Effective Date: July 17, 2013
For More Information, Contact Office of the Vice Provost for Graduate Education and Dean
Contact Information: (860) 486-2182
Official Website: http://grad.uconn.edu/

 

  1. The University is committed to enhancing the number of nationally competitive fellowships and awards from federal sources.
  2. While these awards provide students with a full fellowship or trainee stipend, and payment of some portion of tuition and health insurance premiums, there is often a significant shortfall in the award for coverage of the total cost of tuition and health insurance premiums.
  3. The University has developed this policy to fund the difference between the amount awarded (by the granting agency) and the actual cost to the trainee for tuition and health insurance premiums.  The University will provide such supplementation for tuition and health benefits to students who qualify for any competitive federal fellowships, awards and/or training grants.  Examples include:
    • Dept of Ed Graduate Assistance in Areas of National Need (GAANN)
    • Dept of Ed Jacob K. Javits Fellowships
    • Dept of Transportation Eisenhower Graduate Fellowships
    • EPA STAR Grants
    • Fulbright Fellowships
    • NASA Graduate Research Fellowships
    • National Academies Ford Fellowships
    • National Defense Science & Engineering Grad Fellowships (NDSEGF)
    • NIH Fellowships for Students with Disabilities
    • NIH Minority Fellowships
    • NIH National Research Service Award (NRSA)
    • NIH Training Grants
    • NIOSH/CDC Training Grants
    • NSF Graduate Research Fellowships
    • NSF Integrative Grad Education and Research Traineeship (IGERT) Grants
    • USDA National Needs GrantsFor questions about eligibility of non-federally funded national fellowships or grants, please contact the Office of the Vice President for Research (VPR).
  4. The PI must apply for any cost of education (tuition and fees) and the health insurance premium allowance permitted for that award.  Any institutional allowance or educational allowance accompanying these awards (e.g. NRSA) must first be used to cover tuition, then health insurance premiums, and university fees.  Where the institutional allowance or educational allowance is provided directly to the university (e.g. GAANN), these funds will be deposited in the Office of the VPR.  The tuition, health benefits, etc. will be paid from that fund.If funds are available after payment of tuition, health insurance premiums and university fees (if allowed by the grant), they can be used to cover any educational allowance specifically identified in the sponsor guidelines for research supplies, equipment, books, travel to meetings, etc.
  5. The health insurance premium co-pays for individual (or the individual and his/her dependents) will not exceed those charged to graduate assistants on the graduate assistant health plan.
  6. Unless otherwise disallowed, out-of-state students supported on a fellowship, award and/or training grant must apply for in-state residency status by the end of the first year. After the first year, only the equivalent of the in-state tuition rate will be covered if the student remains an out-of-state student.  The difference will be the student’s responsibility.
  7. Please note that it is not the intention of this policy to supplement university fees.  University fees may be paid up to the maximum allowable from the grant if budgeted as an allowable cost on the award.  If there is a shortfall in the grant award for fees, the responsibility to pay the balance will reside with the student.

Applying for In-State Residency

Graduate students who wish to apply for in-state residency status should submit the Application for In-State Tuition form to:

UConn Graduate Admissions Office
Residency Officer
The Graduate School
438 Whitney Road Ext. U-1152
Storrs, CT 06269

The application is available at https://grad.uconn.edu/wp-content/uploads/sites/1635/2015/04/instatetuition.pdf.

Administrative Review and Approval of Proposals for External Support

Title: Administrative Review and Approval of Proposals for External Support
Policy Owner: Office of the Vice President for Research, Sponsored Program Services
Applies to: Principal Investigators and all others involved in the submission of a sponsored program proposal
Campus Applicability:  All campuses except for UConn Health
Effective Date: June 24, 2015
For More Information, Contact Sponsored Program Services
Contact Information: (860) 486-3622
Official Website: http://research.uconn.edu

REASON FOR POLICY

The timely submission of proposals for internal UConn review and approval allows for thoughtful consideration and review of sponsored project proposals for compliance with University, Federal, State and sponsor policies.  Additionally, Sponsored Program Services professionals review proposals against the administrative requirements of the sponsor’s announcement, including budgets and budget justifications to identify potential administrative or financial challenges to the success of the proposal.

POLICY

All proposal submissions seeking external support for research and other sponsored projects must be submitted to the Office of the Vice President for Research (OVPR) Sponsored Program Services (SPS) for review and approval prior to submission to an external sponsor, even when institutional sign-off is not required by the sponsor.

All letters-of-intent and pre-proposal submissions seeking external support for research and other sponsored projects must be submitted to Sponsored Program Services for review and approval prior to submission to an external sponsor if the signature of an authorized official, a detailed budget, or cost share commitment is required.

Proposals submitted without SPS approval may be administratively withdrawn or the offer of funding (award) may not be accepted if the submission is found to be non-compliant with University, Federal, State or sponsor policies.

SPS requests a minimum of five (5) business days prior to the agency or submission deadline for review and approval of the full proposal, internal forms and budget.

The University of Connecticut reserves the right to withdraw any proposal or refuse acceptance of any award that does not comply with this policy.

ROLES AND RESPONSIBILITIES

The Executive Director of Sponsored Programs and Faculty Services has overall responsibility for this policy.

The Principal Investigator accepts the responsibility for the timely submission of all proposals and pre-proposals that require SPS approval to SPS.

The Department Head, Center Director and/or Dean attests to the academic purposes of the proposed project and its appropriateness in terms of budget, committed effort, space and equipment.

The Executive Director of Sponsored Programs and Faculty Services is the authorized signatory for all proposals for sponsored programs. In the absence of the designated official, arrangements are made to ensure timely signing by alternate University signatories.

Principal Investigators, Department Heads, Deans and other individuals as required are responsible for authorizing and signing internal processing documents, but are not authorized to sign a sponsored projects proposal as the institutional official on behalf of the University.

PROCEDURE/FORMS

See OVPR SPS website: Proposal Preparation Guidelines

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.

POLICY HISTORY

Policy created:  6/12/2008

Revised:           6/24/2015 (approved by the Vice President for Research)

 

Subrecipient Monitoring Policy

Title: Subrecipient Monitoring Policy
Policy Owner: Sponsored Program Services
Applies to: Faculty and Staff conducting sponsored program activity
Campus Applicability:  All Campuses except for UConn Health
Effective Date: June 18, 2015
For More Information, Contact Office of the Vice President for Research, Sponsored Program Services
Contact Information: (860) 486-3622
Official Website: http://ovpr.uconn.edu

REASON FOR POLICY

To provide guidance to the University community in complying with the Office of Management and Budget (OMB) Uniform Guidance 2 CFR Part 200, subpart F and Circular A-133 (hereinafter, referred to as “Single Audit”), specifically with respect to its regulations regarding the oversight of subrecipients on federally sponsored programs.

APPLIES TO

This policy applies to faculty and staff at the Storrs and regional campuses who are working with subrecipients.  For federal awards/subawards issued with a start date before December 26, 2014, 2 CFR Part 215 and 220 (OMB Circulars A-21, A-110), and A-133 apply.  New funds (i.e., new awards, continuation funding, and supplements, etc.) received with a start date on or after December 26, 2014 are subject to the OMB Uniform Grant Guidance (2 CFR Part 200) unless specified otherwise in the terms and conditions of the award document.

Definitions

OMB Uniform Grant Guidance (2 CFR Part 200—Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards): Consolidates and supersedes eight previous OMB Circulars (A-21, A-50, A-87, A-89, A-102, A-110, A-122 and A-133), which specifies grant management and audit responsibilities. Single audit regulations also describe the prime recipient/awardee’s responsibility for monitoring subrecipients.

OMB Circular A-133: The circular that specifies federal and recipient audit responsibilities; it also describes recipient’s responsibilities for monitoring subrecipients.

Prime Agency/Sponsor: The agency providing funds directly to the University.

Prime Recipient/Awardee: The institution or non-Federal awardee that receives an award directly from the sponsor.

Subrecipient: The legal entity to which a subaward is made and is accountable to the prime recipient for the use of the funds provided.  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).

Prime Award: Funds obligated by a Sponsor/funding agency to the University for a specific project.

Subaward: An agreement entered into by the University with another entity (i.e., the subrecipient).  The University agrees provide funds to the entity to conduct a portion of the work specified in the statement of work (SOW) submitted as part of the proposal.

Kuali Financial System (KFS): The University of Connecticut at Storrs and regional campuses financial system of record.

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.

Principal Investigator (PI): Individual responsible for the development, writing, and conduct of a sponsored award, including primary responsibility for the technical and fiscal management of the award.

POLICY STATEMENT

It is the responsibility of the University to ensure our subcontractors meet the terms, conditions, as well as the regulations by sponsors from which funds are received.  As a condition of accepting funding from a sponsor, the University is obligated in its role as primary recipient to undertake stewardship activities as well as comply with federal and state laws, sponsor requirements and University policy.  When the University assigns responsibility for conducting a portion of the work to a subrecipient, the University remains responsible to the sponsor for the management of funds and 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

The University will assess the subrecipient organization’s financial and internal controls and may include additional terms and conditions in the subrecipient agreement consistent with the level of risk identified.

Note: A significant financial interest held by the PI in the subrecipient entity must be disclosed to the Conflict of Interest Office.

The University will perform the following stewardship activities with regard to subrecipients:

  • Advise subrecipients of requirements, including but not limited to financial and non-financial reporting, imposed on them by federal laws, regulations of the flow-down provisions of the prime award and any supplemental requirements imposed by the University dependent on level of risk as determined by the University;
  • The University shall provide the best information available to describe a federal award to each subrecipient including the CFDA number, prime award number, award year, and the name of the sponsor as required by OMB Uniform Grant Guidance or Circular A-133;
  • Require each subrecipient to permit the sponsor and/or the University and its auditors to have access to the pertinent records and financial statements, as necessary;
  • Monitor expenditures and activities of the subaward to confirm that funding provided to the subrecipient is used for purposes authorized in the agreement and that performance goals articulated in the statement of work are achieved.  As part of this activity, PIs are required to sign invoices authorizing payments to subrecipients.  This requirement cannot be delegated;
  • Confirm subrecipients expending $500,000 (before 12/26/2014) or $750,000 (on or after 12/26/2014) or more in federal awards during the subrecipient’s fiscal year are compliant with OMB Circular A-133 or Uniform Grant Guidance audit requirements by requesting audit confirmation from all subrecipients. The subrecipient is to certify whether findings were or were not reported as part of their audit;
    • Upon receipt of a subrecipient audit report that include findings:
      • the University will review and determine whether funds are required to be returned to UConn or any financial adjustments necessary as a result of the audit’s disclosed findings;
      • the University will confirm that the subrecipient has taken appropriate and timely corrective action;
      • the University will issue a management decision letter to the subrecipient as required by regulation.

If a material weakness or other reportable condition exists, management actions, including termination of the agreement, may be taken as appropriate.

ROLES AND RESPONSIBILITIES

Principal Investigator

  1. Obtains proposal-relevant documentation from subrecipient, including Subrecipient Checklist and Consortium Statement, and submits with proposal for review and approval to the Office of the Vice President, Sponsored Program Services (OVPR SPS).
  2. Monitors the technical progress of a subrecipient’s performance as defined in the subaward.
  3. Ensures that subrecipient has met all deliverables.
  4. Ensures that subrecipient has complied with all applicable public policy requirements and objectives.
  5. Reviews invoices for cost allowability, compliance with federal regulations, prime award and subaward terms and conditions.  In addition, ensures that the amount billed is consistent with technical/progress reports and production of deliverables.
  6. Approves invoices for payment via KFS. This task may not be delegated.
  7. Submits invoices for payment in a timely manner and retain copies for departmental records.
  8. Notifies OVPR SPS when problems arise regarding invoicing or performance.

Department Grant Administrator

  1. Assists PIs in meeting their monitoring responsibilities, as specified above.

OVPR SPS

  1. Initiates Pre-qualification subrecipient reviews; consults with the appropriate University departments as necessary to perform subrecipient risk assessment for first-time subrecipients.
  2. Negotiates and executes subaward agreements between the University and subrecipient organizations, including appropriate language requiring adherence to federal regulations and other sponsor requirements as applicable.
  3. Provides special terms and conditions in the subaward to manage risk.
  4. Issues and collects annual single audit certification letters and Subrecipient Profile Questionnaire for non-A-133 subrecipients.  Issues management decision on subrecipient audit findings.
  5. Documents annual compliance certifications.
  6. Performs a final review of costs charged and facilitates close-out of all commitments.
  7. Assists to resolve financial questions related to invoices.
  8. Ensures that the University’s subrecipient monitoring procedures are compliant with Federal, non-Federal, and other applicable regulations.
  9. Provides training and guidance in interpreting regulations, subaward terms and conditions and executing these guidelines and 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.

PROCEDURE/ FORMS

Related procedures and guidance are available on the OVPR SPS website under the heading of Subawards.

POLICY HISTORY

Policy created3/22/2013

Revised:            6/18/2015 (Approved by the Vice President for Research)

Review of University of Connecticut-Related Companies by the Stem Cell Research Oversight (SCRO) Committe, Policy on

Title: Review of University of Connecticut-Related Companies by the Stem Cell Research Oversight (SCRO) Committe, Policy on
Policy Owner: Vice President for Research
Applies to: Other
Campus Applicability:
Effective Date: February 16, 2011
For More Information, Contact Vice President for Research
Contact Information: (860) 486-4164
Official Website: http://research.uconn.edu/

 

 

This policy is intended to define the role of the Stem Cell Research Oversight Committee (SCRO) in providing review and oversight of stem cell research performed by private companies affiliated with the University of Connecticut through its Technology Incubator Program (TIP) and/or the UConn Research & Development Corporation in collaboration with University of Connecticut faculty members. SCRO review shall be restricted to research projects conducted at UConn facilities.

The companies requesting review by SCRO shall be required to comply with SCRO policies for review and oversight and shall agree to follow all policies established by the TIP including:

  • Provisions for compliance with all University, State and Federal rules and regulations including those from Environmental Health and Safety (EHS) and, where appropriate, rules related to animal care, use of human subjects, embryonic and adult stem cells, other biomaterials, etc.
  • The rules for indemnification established by the UConn Research & Development Corporation as stated below:

Indemnification

  1. Indemnity.  _<company name>_ shall and shall cause any Sublicenseeto indemnify, defend, and hold harmless the state of Connecticut, the University of Connecticut, the University of Connecticut Health Center and its/their trustees, directors, officers, faculty, students, employees, and agents and their respective successors, heirs and assigns (the “Indemnitees”), against any liability, damage, loss, or expense (including reasonable attorneys fees and expenses) incurred by or imposed upon any of the Indemnitees in connection with any claims, suits, actions, demands or judgments arising out of any theory of liability (including without limitation actions in the form of tort, warranty, or strict liability and regardless of whether such action has any factual basis) concerning any product, process, or service that is made, used, sold, imported, or performed pursuant to any right or license granted under this Agreement.
  2. Procedures.  The Indemnitees agree to provide _<company name>_ and any Sublicensee with prompt written notice of any claim, suit, action, demand, or judgment for which indemnification is sought under this Agreement.  Any Sublicensee shall agree, at its own expense, to provide attorneys reasonably acceptable to UCONN to defend against any such claim.  The Indemnitees shall cooperate fully with _<company name>_ and any Sublicensee in such defense and will permit _<companyname>_ and any Sublicensee to conduct and control such defense and the disposition of such claim, suit, or action (including all decisions relative to litigation, appeal, and settlement); provided, however, that any Indemnitee shall have the right to retain its own counsel, at its own expense, if representation of such Indemnitee by the counsel retained by _<company name>_ and any Sublicensee would be inappropriate because of actual or potential differences in the interests of such Indemnitee and any other party represented by such counsel. _<company name>_ and any Sublicensee agrees to keep UCONN informed of the progress in the defense and disposition of such claim and to consult with UCONN with regard to any proposed settlement.

Restrictions of Publication Rights and Foreign Nationals in Sponsored Research Contracts

Title: Restrictions of Publication Rights and Foreign Nationals in Sponsored Research Contracts
Policy Owner: Vice President for Research and Graduate Faculty Council Executive Committee
Applies to: Faculty, Staff, Students, Others
Campus Applicability:
Effective Date:  April 6, 2004
For More Information, Contact Sponsored Program Services
Contact Information:  (860) 486-3619
Official Website: https://ovpr.uconn.edu/services/sps/proposals/

 

 

INTRODUCTION

This policy outlines the conditions under which UConn can accept restrictions on publication rights and foreign nationals in sponsored research contracts.  This policy is necessary because federal export control regulations (including International Traffic in Arms Regulations – ITAR) severely restricts all publication by PIs and carries severe sanctions.  Under these regulations federal agencies can withhold the right to publish, including a thesis.  Accordingly, the policy’s goal is to safeguard graduate students’ progress towards graduation while allowing them to gain valuable experience working on such sponsored research projects.

KEY ELEMENTS OF THE POLICY

A grant with restrictions on foreign nationals and publication rights can be accepted only if the following conditions are met:

1)      The Principal Investigator (P.I.) must show that graduate students will not be employed on the project for more than 6 months.  This determination will be made on a case-by-case basis and is not automatic.  Six months is the maximum appointment to be considered.  Furthermore, in the future similar work should be done by a technician or post-doc.

2)      The student must understand that the work cannot be part of his/her thesis because of the restrictions.  In addition, it is important that the student or post-doc understands that he/she cannot discuss the research with others in the lab and cannot allow anyone (besides the P.I.) access to the research data.   This information will be conveyed to each student and post-doc in a letter provided by the P.I.

3)      The P.I. must outline procedures to guarantee in writing that no other employee in the lab will have access to the data.  The PI must also guarantee that the work and resulting data will not be discussed in group meetings.

4)      The P.I., as well as each graduate student and post-doc, must sign the statements described in Sections 2 and 3 of this Policy.  OSP must get a signed copy of each statement before funds are released.

5)      The P.I. must be informed by OSP that the consequences of federal oversight on contracts with these restrictions can be severe, both for the individual and the institution.  The procedures outlined in this Policy are designed to protect him/her.

6)      The Associate Vice Provost may meet with the affected graduate student to ensure that he/she understands the Policy.