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

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

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

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