Sponsored Program Services

Effort on Sponsored Program Activities, Policy on

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

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 Policy

UConn Health:
Guidance – Cost Sharing (UCH)
NIH Salary Cap Guidelines
Budget Preparation Guidelines (UCH)
Budget Templates/Calculators (UCH)
Policy 2002-08: Effort Reporting

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

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 (Storrs and Regional 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.

 

Governing and Cost Accounting Standards

Title: Governing and Cost Accounting Standards
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 18, 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 confirm sponsored programs are administered in accordance with award requirements such as the Uniform Guidance, Cost Accounting Standards for Educational Institutions, Federal Acquisition Regulations, Federal and State regulations, and sponsor and university policies.

APPLIES TO

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

POLICY STATEMENT

This policy establishes the terms and conditions that govern sponsored projects.  The University will be responsible for determining the appropriate costing treatment and for the maintenance of the CAS Disclosure Statement (DS-2) as prescribed in 2 C.F.R. §200.419.

In accepting a sponsored program, the Institution and Principal Investigator(s) assume responsibility for fulfilling the requirements of the program.  These requirements may be specifically contained in the agreement or they may be incorporated by reference to guidelines issued by the sponsor in special publications or directives.

Cost accounting and financial compliance for federally funded sponsored projects at the University is dictated by various Federal Office of Management and Budget Circulars and agency regulations.

The following is a brief explanation of the major bodies of federal and agency regulations that address financial compliance related to sponsored programs:

Uniform Guidance (2 CFR Part 200)

The Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) establishes a basis for policy in the management of federally sponsored programs.

Specifically, the Uniform Guidance sets forth the uniform administrative requirements for grant and cooperative agreements, including the requirements for Federal awarding agency management of Federal grant programs before the Federal award has been made, and the requirements Federal awarding agencies may impose on non-Federal entities in the Federal Award. The Uniform Guidance also establishes the principles for determining the allowable costs incurred by non-Federal entities under Federal awards. Finally, the Uniform Guidance sets forth standards for obtaining consistency and uniformity among Federal agencies for the audit of non-Federal entities expending Federal awards.

Federal Acquisitions Regulations (FAR) (48 CFR)
Establishes the policies, procedures, and requirements of Federal contracts.

Cost Accounting Standards (48 CFR 9905)

Standards designed to ensure uniformity and consistency in the measurement, assignment and allocation of costs to contracts with the US Federal Government, and include:

CAS 501 – Consistency in Estimating, Accumulating and Reporting Costs

University will ensure compliance by employing consistent practices when developing budgets for proposals and in accounting and reporting costs for program expenses (in accordance with Federal and State rules and regulations and University policy).

CAS 502 – Consistency in Allocating Costs Incurred for the Same Purpose

Costs incurred for the same purpose, in similar circumstances, must be given consistent treatment in the accounting system. All costs must be charged consistently as either a direct cost or as part of the federally negotiated Facilities & Administrative (F&A) cost structure.

CAS 505 – Accounting for Unallowable Costs

Unallowable costs (as defined by federal, state or university regulation or policy) must be identified and excluded from any billing, claim, or proposal submitted to the Federal government.

CAS 506 – Cost Accounting Period

The University Fiscal Year (July 1 – June 30) will be used as the accounting period regardless of the sponsor’s accounting period.

Federal Sponsor Guidelines
While the Uniform Guidance establishes the principles for sponsored program management, each federal agency may differ in policy application. Additionally, terms and conditions specific to an award may apply.

Non-Federal Sponsor Guidelines
The specific award agreement, together with University policy, usually guides the project’s conduct.  State agencies, foundations, and private businesses may also publish their own funding guidelines and requirements.

ROLES AND RESPONSIBILITIES

Principal Investigator

Responsible for ensuring appropriateness of all charges on sponsored projects.  Ensure the consistent application of direct costing practices to sponsored projects.

Department or Shared Services Fiscal Officer/ Administrator

Assists the Principal Investigator in ensuring consistent application of costing practices, record keeping and other financial and administrative requirements.

Sponsored Program Services

Develop and maintain policies and procedures in accordance with Federal regulations.  Provide training and guidance to Principal Investigators and staff.  In accordance with policy and procedure, review transactions for appropriateness under Federal and institutional guidelines.

Office of Cost Analysis (Storrs and regional campuses) / Research Finance (UConn Health)

Maintain and file CAS Disclosure Statement (DS-2) in accordance with §200.419 identifying accounting practices, policies, and procedures for assigning costs to federally sponsored programs, and to attest to the consistent treatment of those practices.

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/ OTHER POLICY

UConn Storrs and Regional Campuses:

Disclosure Statement (DS-2)

Cost Accounting Disclosure-1 Direct/Indirect

 

UConn Health:

UCH Policy 2002-39:  Direct Cost Expenditures

UCH Policy 2002-05:  Unallowable Costs/Administrative Costs

Disclosure Statement (DS-2)

 

POLICY HISTORY

Policy created:  Approved by the President’s Cabinet on 09/12/2019. This is a new University wide policy to better document practices at Storrs and regional campuses and combines two previous policies at UConn Health.

History:                

Miscellaneous guidance at Storrs and regional campuses

UCH Policy 2002-12, “Governing Standards”, 2/25/2002

UCH Policy 2002-37, “Cost Accounting Standards”, 2/25/2002

 

Fixed Price Residual Policy

Title: Fixed Price Residual 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 for UConn Health
Effective Date: July 7, 2015
For More Information, Contact Offices of the Vice President for Research and Sponsored Program Services
Contact Information: (860) 486-3622
Official Website: http://research.uconn.edu

 

REASON FOR POLICY

To establish guidelines for the disposition of residual balances remaining in sponsored project accounts for fixed price contracts awarded to the University.

APPLIES TO

This policy applies to faculty and staff at the Storrs and regional campuses who are working with sponsored program grants and contracts.

DEFINITIONS

Fixed Price Contract: An agreement in which the University guarantees to deliver a product or perform a service for a set (fixed) price agreed upon in advance and payable regardless of actual costs.

Residual Balance: An unobligated, unspent balance remaining in a fixed price sponsored project account after all work has been completed and all deliverables have been met.

POLICY STATEMENT

Residual fund balances that are under 15% of the direct cost budget of a fixed price sponsored program restricted project account will be transferred to an unrestricted account for use by the PI at his/her discretion subject to the following conditions:

  • The project budget represented a good faith and realistic estimate of the cost to perform the work.
  • The PI confirms in writing that all project-related costs have been charged to the project account and that all deliverables have been met.

Direct cost balances over the first 15% will be evaluated by the Dean of the school/college to determine their disposition.

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

SPS has established operating procedures designed to ensure compliance with this policy. This includes working with the PI and department personnel during the closeout process to ensure all project-related costs have been charged to the restricted account, and all deliverables have been met.

See Fixed Price Residual on the Award section of the OVPR website.

POLICY HISTORY

Policy created:   3/1/2013

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

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)

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)

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.