Policies

Sponsored Programs Policy

Full policy details: Sponsored Programs Policy

Policy Statement and Purpose

The University of North Texas Health Science Center (UNTHSC) supports the principle that research and development activities can and should increase the excellence of instruction. Such activities are considered to be part of the academic responsibilities of faculty members. Sponsored Projects provide support that can make these activities possible. UNTHSC encourages individual faculty members and interdisciplinary teams to seek support for Sponsored Project activities. Faculty members are encouraged to integrate these activities with instruction and engage in scholarly research activities that lend themselves to involvement of students. As a recipient of externally funded Sponsored Project, UNTHSC has a responsibility to ensure proper stewardship of those funds. The Office of Sponsored Programs (OSP) is the central point of coordination for all sponsored awards at the University of North Texas Health Science Center. Sponsored Projects are required to comply with all applicable Regents Rules, System Regulations, federal and state statutes and regulations, UNTHSC Policies, and Sponsor terms and conditions. Questions may arise from time to time concerning whether a proposed or existing project conforms to the Regents' Rules and System Regulations, federal and state statutes and regulations, UNTHSC Policies, or sponsor terms and conditions. Such questions should be referred to the OSP who has authority to coordinate the resolution of policy questions on Sponsored Projects.

Definitions

Allowable. “Allowable” means rules covered in the OMB Uniform Guidance, 2 CFR, Part 200, Section 400 and federal regulations. In many cases, the issue of whether a particular cost is allowable is a complex one. When in doubt, consult with the Office of Sponsored Programs (OSP). Expenses are chargeable to the federal government only if they are: o Reasonable – A prudent person would have purchased this item and paid this price o Allocable – Expenses can be allocated to the government activity based on benefit derived, cause and effect, or other equitable relationship. o Consistently Treated – Like expenses must be treated the same in like circumstances. o Allowable – Allowable or not unallowable as specified by government regulations. If an expense cannot meet the above criteria, it is not eligible to be charged to a federal grant or contract no matter what its purpose. NOTE: Agencies that sponsor grants and contracts use the term allowable to mean permitted as a direct cost under the terms of a specific grant or contract. Expenses that are generally allowable for federal reimbursement may not necessarily be permitted under the terms of a specific grant or contract. Cost Transfer. “Cost transfer” means any adjustment or transfer of expenditures to/from an externally funded Sponsored Project Account. Direct Costs. “Direct costs” mean expenses that are specifically associated with a particular Sponsored Project or expenses that can be directly assigned to such activities relatively easily with a high degree of accuracy. Example: cost of materials used on a project. Facilities and Administrative Costs. “Facilities and Administrative Costs (F&A)” means necessary costs incurred by a recipient for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved. This may also be referred to as “Indirect Costs” or “Overhead Costs”. Gifts. “Gift(s)” means any item of value given to UNTHSC by a donor who expects nothing significant of value in return, other than recognition and disposition of the gift in accordance with the donor’s wishes. Principal Investigator. “Principal investigator (PI)” means, for the purpose of this policy, a single individual who in the event of an award from an external funding agency shall have the full and final responsibility for the conduct of the project as proposed and encompasses the terms Principal Investigator, Project Director, Program Director and the like. Persons eligible to be principal investigators shall be full-time and/or part-time regular and/or non-regular faculty. Project Lead. “Project Lead” means an individual responsible for the conduct and outcome of a sub-project or core within a program project, center grant, or similar award. Recharge Center. “Recharge Center (RCs)” means operating units that either stand alone or exist within departments, and provide goods and/or services on a cost-recovery basis. Examples of products or services that Recharge Centers may provide are telephone, statistical services, animal care facilities, training, and specialized equipment usage, etc. Sponsored Projects. “Sponsored Projects” means funded activities which have a defined statement of work or set of objectives which provides a basis for sponsor expectations. In addition to financial support, non-monetary awards such as equipment grants and consortium activities may be considered Sponsored Projects. Internally funded activities will be considered Sponsored Projects if they are provided through a competitive application and award process and the proposed activity generally meets the same criteria as externally funded Sponsored Projects such as a defined scope of work, return of unspent funds, detailed financial and/or technical reporting requirements, restrictions on how funds may be spent, etc. Subrecipient. “Subrecipient” means a third party that receives a subaward from a pass-through entity to carry out part of a Sponsored Project; but does not include an individual that is a beneficiary of such project. The term includes consortium participants.

Management of Gifts and Sponsored Projects

1. Both Sponsored Projects and Gift-funded activities may be externally supported, with funds provided typically in response to a request or proposal. The classification of funding as "Gift" or "sponsored" will affect, among other things, the way UNTHSC accounts for the funds, calculates and applies F&A (indirect) costs, and reports on the use of the funds to the sponsor or donor. 2. The following conditions characterize a Sponsored Project, and help to distinguish such Sponsored Projects from Gifts. a. STATEMENT OF WORK - Sponsored Projects are typically awarded to UNTHSC in response to a detailed statement of work and commitment to a specified project plan. As described below, this statement of work is usually supported by both a project schedule and a budget, both of which are essential to financial accountability. The statement of work and budget are usually described in a written proposal submitted by UNTHSC to the sponsor for competitive review. There are typically progress or technical reports due to the sponsor based on the statement of work. b. DETAILED FINANCIAL ACCOUNTABILITY - The Sponsored Project includes financial accountability, typically including such conditions as: i. a budget related to the project plan. The terms of the Sponsored Project may specify allowable or unallowable costs, requirements for prior approvals for particular expenditures, etc. ii. budget restrictions and rebudgeting limits iii. a specified period of performance, typically defined with "start" and "stop" dates iv. periodic payments are made to UNTHSC so that the financing of the project is on a continuous basis. v. regular financial reporting and audit, including, for federal awards, accountability under the terms of 2 CFR 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (OMB Uniform Guidance). vi. a Sponsored Project budget will include UNTHSC's full negotiated F&A (indirect) cost rate, unless a waiver of those costs has been approved or the sponsor prohibits such costs. vii. These conditions generally define the level of financial accountability associated with a Sponsored Project. While not all of the above conditions are necessary to define a Sponsored Project, they are collectively indicative of the increased level of financial accountability associated with such projects. 3. DISPOSITION OF PROPERTIES (“Deliverables”) - Sponsored Projects also usually include terms and conditions for the disposition of tangible properties (e. g., equipment, records, specified technical reports, theses or dissertations) or intangible properties (e.g., rights in data, copyrights, inventions). The presence of such terms and conditions in the agreement indicate that the activity is a Sponsored Project. 4. In general, the following characteristics describe a Gift: a. There are no "deliverables" to the donor. However, the Gift may be accompanied by an agreement that restricts the use of the funds to a particular purpose and progress reports as well as reports confirming allowable expenditures of funds may be required. b. A Gift is typically irrevocable. While the Gift may be intended for use within a certain timeframe, there is no specified "period of performance" or "start"/ "stop" dates as associated with Sponsored Projects. c. There is usually no formal fiscal accountability to the donor beyond periodic progress reports and summary reports of expenditures. These reports may be thought of as requirements of good stewardship, and, as such, may be required by the terms of a Gift agreement, but they are not characterized deliverables. d. In the classification of external funding as a Gift or as Sponsored Project funding, the following guidelines apply: e. Gift solicitations should be coordinated with the Office of Institutional Advancement, and the Office of Institutional Advancement should be contacted for procedures applicable to Gift solicitations. f. DISTINCTIONS BASED ON SOURCE OF FUNDS - Any funding provided by U.S. Government agencies, at the federal, state, or local level, in support of UNTHSC activities is treated as Sponsored Project funding. Government funds are not treated as Gifts. Funding from Voluntary Health Organizations or Associations, such as the American Cancer Society or American Heart Association, is usually treated as a Sponsored Project and not a Gift. g. DISTINCTIONS BASED ON INTENT OF DONOR/SPONSOR - In remaining cases, e.g., where funding is being provided by corporations, foundations, trusts or others not specified above, the distinction between Gifts and Sponsored Projects will be made based on the proposal, statement of work, and terms of the agreement, taking into consideration the intent of the donor/sponsor. h. Note that, in some situations, communication, including the proposal and award as well as conversations, makes it clear that the donor's/ sponsor's intent is to classify an award to UNTHSC as either a Gift or a Sponsored Project. In these cases, the terms of the accompanying agreement may have to be adjusted in consultation with the donor/sponsor in order to clearly document the intent and avoid unintended classification. 5. In some cases, particularly when the source of funds is a non-profit entity, the distinction between Gift and Sponsored Project funding, can be difficult to draw. The same terms can be used by sponsors and donors to denote a Sponsored Project or a Gift. When an individual is in doubt about the proper classification and handling of an award to UNTHSC, the OSP and Institutional Advancement will confer and resolve the question. 6. In resolving issues related to the classification of an award, UNTHSC personnel must maintain an appropriate balance between the interests and preferences of the donor/sponsor and UNTHSC’s administrative policies and objectives. Personnel should seek the guidance of UNTHSC’s OSP and Institutional Advancement to determine appropriate resolution when classification questions arise. In the process of resolving these issues, in some cases it may be necessary to contact the donor/sponsor for clarification of intent and requirements, and/or to discuss the planned use of the funds. 7. Whenever a new account is requested, the responsible department (OSP in the case of Sponsored Projects or Institutional Advancement in the case of Gifts) verifies that the account being set up is proper, in accordance with the definitions in this policy. These offices are responsible for assuring that a proper determination of Gift or Sponsored Project status has been made.

Principal Investigator Eligibility

1. Certain legal and ethical obligations are stated or implied in terms and conditions from external sponsors. UNTHSC becomes responsible for the proper performance of the stated work and for fiscal management of the funds received from the sponsor. Sponsors usually require that an individual be named to oversee the project with the reasonable assurance that the agreed responsibilities will be discharged faithfully and prudently in the mutual interest of the sponsor and UNTHSC and over the full period of the award. 2. The Principal Investigator shall use all reasonable efforts to comply with the terms, conditions, and policies of both the sponsor and UNTHSC, including the submission of all required reports. 3. Persons holding the following positions may be designated as Principal Investigators (PI) or Project Lead in applications for externally sponsored funding: a. All tenured and tenure-track Assistant, Associate, and Full Professors and Librarians. All persons holding appointments as Research Assistant Professor, Research Associate Professor and Research Professor, and Clinical Professors. 4. Persons holding the following positions may be designated as Principal Investigators (PI) or Project Lead in applications for externally sponsored funding only after receiving all necessary approvals required by the PI Eligibility Form: a. All persons holding Adjunct, Visiting, and Emeritus faculty positions at the UNTHSC. PI’s in one of these categories should also include a Co-Investigator from appointment types eligible for PI status. When added for this purpose, Co-Investigators are responsible for ensuring that the PI is aware of and fulfills obligations as set out in this policy. b. In the event a Co-Investigator is not named, the Department Chair and, also, the Dean of the relevant School or College shall accept full fiscal and administrative liability and responsibility for the actions of the Principal Investigator included in this category. c. All Post-Doctoral Fellows. The Post-Doctoral Fellow’s mentor must be listed as a coinvestigator. d. All Professional Staff (e.g. Directors), employed in a full-time position. Note: Neither undergraduate nor graduate students may be designated as PIs. When a Sponsor’s program guidelines require the student to be listed as PI on the Proposal application, the student’s mentor/advisor shall be the PI of record on External Proposal Transmittal Form and responsible for conduct and oversight of the project.

Submission of Proposals for External Funding

1. OSP is the central administrative office responsible for submitting proposals and accepting awards on behalf of the Health Science Center. All proposals for Sponsored Projects must be submitted through the OSP. The Vice President for Research can grant various levels of signature authority on proposals and/or acceptance of awards, as appropriate. Sponsored Project proposals must be submitted and awards accepted only by individuals specifically authorized to sign the necessary documents. Questions in this regard may be directed to OSP staff. 2. Adequate lead-time is needed for assuring compliance to sponsors requirements. Unless an exception is granted by the VPR, all completed administrative documents of a proposal must be submitted to the Office of Sponsored Programs for review at least five (5) business days in advance of the Sponsor Deadline, and scientific documents must be submitted at least one (1) business day in advance of the Sponsor deadline. 3. This policy applies to all research proposals for work to be carried out in the HSC academic departments, laboratories, administrative units and clinics. In addition, the terms of this policy also apply to proposals that commit HSC resources for projects to be performed off-campus, including affiliated institutions. For submission of a proposal, the procedures outlined in Procedure for Submission of Proposal for External Funding must be followed.

Principal Investigator Responsibilities for Financial Oversight of Grants and Contracts

1. Principal Investigators are required to exercise financial oversight of each Sponsored Project to ensure charges are reasonable, allocable, consistently treated and Allowable under the terms and conditions of the award and properly allocated among multiple awards and funding sources, and limited to the funds awarded for the Sponsored Project. 2. As a recipient of federal and non-federal funding, UNTHSC is required to comply with numerous rules and regulations promulgated by those sponsors. Among those agencies are the Federal Office of Management and Budget, which sets forth broad policies governing federal grant and contract financial administration, as well as numerous individual agencies which award grants and contracts such as the Public Health Services (PHS) and the National Science Foundation (NSF), with their own agency-specific regulations for administering grants and contracts. 3. Common to the regulations of all agencies is the fundamental requirement that a particular grant or contract may only be charged for costs related to that project. Fund availability or grant expiration may not govern which grant or contract is charged. If an investigator's activities are entirely funded by a single grant or contract, there are no cost allocation issues. It is often the case, however, that an investigator's research laboratory is funded by multiple sources. Accordingly, it is necessary to ensure that expenditures, whether they be related to personnel, equipment, travel, supplies or other categories, are properly allocated to the various grants and contracts. 4. UNTHSC encourages the use of Departmental Administrative support in carrying out routine administrative activities related to award management, such as initiating transaction processing, ordering supplies, allocating salary distribution requests and processing vendor invoices at the direction of the Principal Investigator. At the same time, however, the nature of Sponsored Project support is such that grant and contract administration cannot be performed without guidance and oversight by the investigator, particularly when the project is supported by multiple sources. The Principal Investigator best understands the scope of the project, the effort committed to it by faculty and staff, and the relationship of that project to other projects with which resources may be shared. The Faculty Research Support Team (FRST) is a resource which can be utilized to provide a second level of review of expenses allocated to Sponsored Projects and acts as a liaison between the Principal Investigator/Project Lead and OSP. 5. Carrying out these responsibilities requires the Principal Investigator to clearly communicate instructions to those performing the day to day financial administration tasks on how to allocate charges among various funding sources. Additionally, the Principal Investigator must regularly monitor the financial status of the Sponsored Project to ensure the charges conform to the above requirements. Accordingly, although the Principal Investigator may delegate responsibility for day to day financial management of a Sponsored Project to others within the unit, the Principal Investigator must exercise appropriate oversight of the overall finances of the project. This is necessary in order to ensure charges to Sponsored Projects are: a. As they relate to personnel costs, consistent with the effort expended by those working on the grant or contract b. As they relate to costs other than personnel, are appropriately charged and allocated to the grant or contract c. Limited to the funds awarded for the project

Cost Transfers

The administration of cost transfers is extremely important and sensitive when Sponsored Project funding is involved. Federal and State agencies, which award Sponsored Projects to UNTHSC, are especially concerned that costs can be specifically identified with the funded activity they benefit. When Sponsored Project records are reviewed, inappropriate or poorly documented cost transfers can result in sponsors denying reimbursement of these questionable charges or imposing other sanctions on UNTHSC, such as imposing more stringent oversight of Sponsored Project funds. Salaries, wages, goods and services that do not benefit a Sponsored Project may not be transferred to that Sponsored Project. Therefore, it is important to provide detailed written explanations justifying all cost transfers. Diligent reconciliation and regular review of financial records and timely communication between principal investigators and department administrators should prevent the necessity for transfers; however, under certain circumstances transfers may be appropriate. 1. It is the responsibility of the Principal Investigator and his or her administering department, center, or institute to ensure that only allowable and allocable costs are expensed against a Sponsored Project account. 2. It is the responsibility of the department, institute, or center to ensure compliance with this policy and ensure that all personnel engaged in the financial administration of Sponsored Projects understand this policy. 3. The OSP is responsible for reviewing and approving all cost transfers. 4. To be considered allowable, all cost transfers must be timely, documented and explained in detail, adhere to the sponsor’s standards, and have appropriate authorizing signatures. Cost transfers should be prepared and submitted as soon as the need for the transfer is identified, but under most circumstances, not later than 90 days from the original transaction date. 5. Cost Transfer Within 90 Days. Cost transfers involving Sponsored Projects (including payroll reallocations) that are processed within 90 days of the original transaction require submission of a Cost Transfer Form. 6. Cost Transfers Over 90 Days. Only in the case of exceptional circumstances will cost transfers (including payroll reallocations) be permitted after effort certification, or more than 90 days after the original charge. However, unallowable costs will not be allowed to remain on a Sponsored Project account. The justification for a cost transfer more than 90 days after the original charge must be documented in detail on the Cost Transfer Form.

Cost Sharing

1. Cost sharing is defined as program or project costs not supported by the sponsoring agency. Cost sharing includes contributed effort, matching funds, and unrecovered facilities and administrative costs (F&A aka indirect costs). OMB Uniform Guidance, 2 CFR, Part 200, Section 200.306, requires that all cost sharing (federal and non-federal): a. Are verifiable from the non-Federal entity’s records; b. Are not included as contributions for any other Federal award; c. Are necessary and reasonable for accomplishment of project or program objectives; d. Are allowable under Subpart E -- Cost Principles of this part; e. Are not paid by the Federal government under another Federal award, except where the Federal statute authorizing a program specifically provides that Federal funds made available for such program can be applied to matching or cost sharing requirements of other Federal programs; f. Are provided for in the approved budget when required by the Federal awarding agency; 2. Types of Cost Share: a. Mandatory cost sharing is cost sharing that is legally required by the awarding agency as a condition of the award. b. Voluntary committed cost sharing is not required by the awarding agency as a condition of the award. However, some federal agencies expect some cost sharing commitment to be identified in the proposal. If voluntary cost sharing is included in the proposal, it will become legally mandatory cost sharing if accepted by the sponsoring agency as a part of the award (grant or contract). c. Voluntary Uncommitted Cost Sharing is defined as university faculty effort that is over and above that which is committed and budgeted for in a sponsored agreement. This differs from mandatory or voluntary committed cost sharing which is cost sharing specifically pledged in the proposal’s budget or award. d. In-Kind Cost Sharing is defined as contributions where in the value can be readily determined, verified, documented and justified but where no actual transaction has occurred to secure the good or service. Typically this is considered third party cost share. In Kind cost share must be tracked manually by the department, center, or institute managing the award. 3. Voluntary committed cost sharing and voluntary uncommitted cost sharing are discouraged by UNTHSC, especially the cost sharing of UNTSHC buildings or building space and equipment. 4. In cases where the Sponsor has a mandatory salary cap, salary over the cap shall not be considered cost share as it is not an Allowable expense. Though it is not treated as cost share, salary over the cap must be charged to a non-sponsored source of funds. 5. The primary department with which the Sponsored Project is affiliated is ultimately responsible for meeting cost sharing commitments. If a proposal includes any cost sharing, then it must be identified on the External Proposal Transmittal Form and the Cost Sharing Authorization Form required by the Division of Research and Innovation. Approval of cost sharing on these forms constitutes a commitment to provide those funds upon award. 6. The Vice President for the Division of Research and Innovation through the OSP is responsible for developing, implementing, and maintaining procedures associated with this policy. The OSP will require the PI to identify the account(s) and/or type of costs to be used for cost sharing at the time an award is received.

Recharge Centers

1. For questions and guidance on establishing a Recharge Center the Office of Financial Planning and Budget should be consulted. 2. Recharge Centers may only charge to a Sponsored Project when the charge directly benefits the project and the cost is Allowable. Sponsored Projects may only be charged at the established and documented break-even rate which recovers only Allowable, actual expenses. Expenses which are not Allowable must not be included in the billing rate computation. 3. OMB Uniform Guidance requires that recharge centers adjust their rates on at least a biennial basis, however the UNTHSC Office of Financial Planning and Budget may require a more frequent rate assessment. 4. The use of special rates, such as for high volume work or less demanding non-scientific applications, is allowable, but the special rates must be equally available to all users. The federal government does not object to charging external users a higher rate than that charged to internal users, but internal rates must be applied consistently, and all Sponsored Projects must be charged the internal, break-even rate. 5. The Recharge Center is responsible for maintaining documentation of compliance of their rate with applicable laws, regulations, guidelines, and UNTHSC Policies, and for ensuring that the appropriate, internal break-even rate is applied when charging Sponsored Project Accounts. It is the responsibility of each Recharge Center or its overseeing department to maintain records of the detail contained in all recharge transactions and to answer inquiries concerning those charges. All recharge operations must be documented and records maintained for the applicable record retention period to support expenditures, billings and cost transfers on Sponsored Projects.

Facilities and Administrative Costs Recovery and Distribution

UNTHSC applies the currently negotiated Federal Facilities and Administrative (F&A) rates to all federal, state and private funded grants, contracts and other agreements. In the event a sponsor limits or prohibits the full federal F&A recovery; the institution will recover the full amount allowable. In rare cases, there may be compelling circumstances where exceptions to this policy may be warranted. All requests for an exception should be made by submission of a completed F&A Waiver Request Form to the Office of Sponsored Programs for consideration by the Vice President for Research. 1. F&A recovered monthly on Sponsored Project Account’s will be credited to an institutional local F&A recovery account on a monthly basis. 2. Funds to be returned to the appropriate Dean, Chair and Principal Investigator would be distributed from the institutional local F&A recovery account on at least a semi-annual basis. Funds being returned to these individuals will only be distributed for active grant accounts, which recover UNTHSC “full federal” on-campus/off-campus rate.

Subrecipient Monitoring

1. Federal regulations require pass-through entities to establish internal controls to determine risk of non-compliance for each subrecipient, apply an appropriate monitoring level, and ensure that the subaward activities are conducted in compliance with applicable laws, regulations, and Sponsor terms and conditions. The State and other non-federal sponsors may also require similar oversight to be conducted by UNTHSC. 2. Failure to adequately oversee subrecipient compliance could result in reputational damage to UNTHSC, jeopardize current and future funding and subject UNTHSC, the PI and others at UNTHSC to legal prosecution. It is the responsibility of UNTHSC, as the pass-through entity, to ensure proper stewardship of Sponsored Project funds. UNTHSC should expect the same level of diligence in oversight from Subawardees as it applies funds retained and managed at UNTHSC. 3. The PI and Department, Institute, or Center support are responsible for providing a written statement of work at the proposal stage and award stage, monitoring programmatic progress of the subrecipient and ensuring ability to meet objectives of the award, reviewing and approving subrecipient invoices, and escalating any concerns to the Office of Sponsored Programs. 4. The Office of Sponsored Programs is responsible for completing risk assessments for new subrecipients on federal awards annually, reviewing and approving subrecipient invoices, applying appropriate additional controls to medium and high risk subrecipients, and reviewing problematic subawards identified by the PI or OSP and establishing additional controls as needed.

Reference

Applicable Laws, Rules and Regulations: - 2 CFR 200 – Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. - Public Law 95-224 - 45 CFR Part 75 - 45 CFR Part 92.32 Related Policies and Procedures: - Procedure for Submission of Proposal for External Funding. - Subrecipient Monitoring Procedures.

Effort Reporting Policy

Full policy details: Effort Reporting Policy

Policy Statement and Purpose

The purpose of this policy is to establish compliance with Office of Management and Budget (“OMB”) requirements, “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards,” 2 CFR Part 200, Section 200.430, Compensation – Personal Services (OMB Uniform Guidance or “UG”). A labor distribution system supported by internal controls and accurate records is required by UG. The methodology for an effort reporting system includes an after-the-fact certification of the percentage of effort directly devoted to and charged to Sponsored Projects, including cost sharing. The Principal Investigator of a Sponsored Project is required to devote some measurable level of effort to the Sponsored Project. For the purposes of this policy, effort is measured in terms of percentage and not in terms of hours worked.

Definitions

Allowable. “Allowable” means rules covered in the OMB Uniform Guidance, 2 CFR, Part 200, Section 400 and federal regulations. In many cases, the issue of whether a particular cost is allowable is a complex one. When in doubt, consult with the Office of Sponsored Programs (OSP). Expenses are chargeable to the federal government only if they are: o Reasonable – A prudent person would have purchased this item and paid this price o Allocable – Expenses can be allocated to the government activity based on benefit derived, cause and effect, or other equitable relationship. o Consistently Treated – Like expenses must be treated the same in like circumstances. o Allowable – Allowable or not unallowable as specified by government regulations. If an expense cannot meet the above criteria, it is not eligible to be charged to a federal grant or contract no matter what its purpose. NOTE: Agencies that sponsor grants and contracts use the term allowable to mean permitted as a direct cost under the terms of a specific grant or contract. Expenses that are generally allowable for federal reimbursement may not necessarily be permitted under the terms of a specific grant or contract. Cost Sharing: “Cost Sharing” means that portion of the total project costs of a sponsored agreement that are not borne by the sponsor through a Sponsored Project account but rather is borne by the institution through a department account. This indicates the Principal Investigator or Project Director (PI) or any of his/her staff spent time on the project while being paid from other sources than the Sponsored Project account. Cost Sharing should only be contributed when required by the sponsor guidelines. For purposes of this policy, Cost Sharing will be the term used to represent contributed, match or cost share effort on the project. Effort: “Effort” means the amount of time spent on a particular activity. It includes time spent working on a sponsored project in which salary is directly charged to the sponsor or contributed, matched, or cost-shared time charged to the department/institution. Institutional Base Salary (IBS): “Institutional Base Salary (IBS)” means the total guaranteed annual compensation an individual receives from UNTHSC, whether the individual’s time is spent on research, instruction and teaching, patient care, public service, or other activities. The IBS shall be used to compute salaries charged to sponsored programs unless sponsor’s policies further limit salary charges. IBS excludes: fringe benefit payments; non-recurring merit payments; incentive payments; reimbursed expenses; temporary, supplemental compensation for incidental work; income earned outside of duties to the institution; and any portion of compensation that is not guaranteed to be received. Key Personnel: “Key Personnel” means the principal investigator and other senior personnel who contribute to the scientific development or execution of a Sponsored Project in a substantive, measurable way. Principal Investigator. “Principal investigator (PI)” means a single faculty or staff member of UNTHSC who, in the event of an award from an external funding agency, shall have the full and final responsibility for the conduct of the project as proposed and as set forth in the contract or grant, and encompasses the terms Principal Investigator, Project Director, Program Director and the like.

Policy and Responsibilities

1. Minimum Effort: Sponsored Project proposals must include a reasonable estimate of effort to be committed to the Sponsored Project for PIs, faculty, and other key personnel. A minimum effort commitment of 1% is required on the part of the PI and any other key personnel for a Sponsored Project. The following proposal types are exempt from this requirement: equipment grants, travel grants, conference support, dissertation support, and other awards intended as student augmentation (A student augmentation award is an award whose primary purpose is to fund a student’s or post doc’s activity). 2. Maximum Effort: The certification includes a verification that employees are not charging more than 100% of their Institutional Base Salary to Sponsored Projects. Most faculty have responsibilities for teaching , service, and/or administrative duties that would preclude them from devoting 100% of their time to sponsored activities; exceptions to this include key research staff who have no duties outside of Sponsored Projects, and do not participate in preparation of additional funding proposals. The following guidelines are established for the allocation of effort: Position Title: Research Track Faculty, Postdoctoral Research Associates or other non-tenure track faculty Description: No teaching, service or clinical responsibilities Maximum % on Sponsored Programs: 95% leaving 5% available for writing proposals and other activities unrelated to sponsored programs Position Title: Tenure Track Faculty Description: Includes some level of teaching, service, and/or clinical responsibilities Maximum % on Sponsored Programs: 90% leaving 10% available for teaching, service, and clinical responsibilities Position Title: Center or Institute Directors Description: Includes some level of teaching, service, clinical or formal administrative responsibilities Maximum % on Sponsored Programs: 85% leaving 15% available for teaching, service, clinical responsibilities or managing a center or institute Position Title: Deans, Chairs, and other Executive Leadership Description: Includes some level of teaching, service, clinical or formal administrative responsibilities Maximum % on Sponsored Programs: 80% leaving 20% available for teaching, service, clinical responsibilities or managing a department, school, or college There may be unique circumstances in which it is appropriate for the salary of a Postdoctoral Research Associate to be charged 100% effort to a research grant. Under these circumstances, the PI and Department must obtain a written waiver from Office of Sponsored Programs. 3. All faculty and non-faculty Principal Investigators engaged in Sponsored Project activities are required to provide a reasonable representation of the amount of time and effort worked on each Sponsored Project during the applicable effort reporting period. The amount of time and effort spent on a Sponsored Project is required to reasonably relate to the services provided by the faculty and non-faculty Principal Investigators to the Sponsored Project and must be allowable. The federal government acknowledges that practices vary among and within institutions as to the activity constituting a full workload. Accordingly, UNTHSC is permitted to express effort in terms of a percentage distribution of total institutional activities. Quarterly Effort Certifications distributed in accordance with this policy should reflect the total activity for which an employee is compensated and include activities such as administration, patient care, research, public service and teaching that are often inextricably intermingled. Total UNTHSC effort includes only those activities for which an individual is being compensated by UNTHSC. It does not include non-UNTHSC effort. 4. All Principal Investigators (PIs) overseeing staff engaged in Sponsored Project activities are required to provide a reasonable representation of the amount of time and effort worked on by that staff on each Sponsored Project during the applicable effort reporting period. The amount of time and effort spent on a Sponsored Project is required to reasonably relate to the services provided by the staff to the Sponsored Project. The federal government acknowledges that practices vary among and within institutions as to the activity constituting a full workload. Accordingly, UNTHSC is permitted to express effort in terms of a percentage distribution of total institutional activities. Quarterly Project Effort Certifications, distributed in accordance with this policy, should reasonably reflect the activity for which an employee is compensated on that Sponsored Project as a percentage of their total institutional activities. 5. The PI and Department or Sponsored Project Administrative Staff should initiate and accurately complete electronic payroll activity requests (ePARs) at Sponsored Project setup which reflect the reasonable anticipated effort on the Sponsored Project. Salary rates for Sponsored Project employees must comply with university policies for faculty, staff, and student compensation. When an award is accepted, the Principal Investigator and other key personnel are committed to providing the level of effort specified in the proposal, subsequent budget modification or resulting award notification, over the award period, unless sponsor policies permit otherwise. Before PIs or other key personnel change their effort, they should notify the Faculty Research Support Team (FRST) or the Office of Sponsored Programs (OSP) and participate in review of the terms and conditions of their award to determine whether or not prior approval is required from the sponsor. If sponsor prior approval is required, a request must be submitted through the OSP. Changes to percent of effort worked on the Sponsored Project should be documented by processing a revised ePAR at the time of the change to the percent effort actually expended. Any effort which is committed in the proposal and resulting award, but not charged to the sponsor, will be treated as cost sharing and must be handled in accordance with Sponsored Programs Policy. 6. To identify potential errors and make adjustments on a timely basis, payroll expenditures should be reviewed monthly by the PI and/or Department/Sponsored Project Administrative Staff to review for the accuracy of payroll allocations on all Sponsored Projects, Department Accounts, and Non-sponsored Project Accounts. If the payroll allocation is determined to be inaccurate at the time of this review, changes to the allocation should be documented by processing a revised ePAR at the time of discovery, in accordance with the Sponsored Programs Policy. 7. Variances up to and including 3% of the individual’s IBS for each Sponsored Project listed for the period being certified are allowable and do not require an adjustment. Variances over 3% should be corrected, in compliance with the Sponsored Programs Policy, prior to final approval of the certification. (For example: a certification with a charge to a Sponsored Project for 40% of an individual’s time during the applicable effort reporting period can be approved provided the actual effort is between 37% - 43%, +/- 3%). 8. All PIs and faculty members who have effort charged, or committed to Federal and State Sponsored Projects must certify their quarterly effort distribution. The Quarterly Effort Certifications follow the calendar year: January-March, April-June, July-September, and October-December. All PIs and faculty members are required to sign their own certifications, with limited exceptions. Any delegation of authority for Quarterly Effort Certification must be approved by the Vice President for Research. 9. Quarterly Project Effort Certifications are required for each Federal and State Sponsored Project that has non-faculty salary charges. Each quarterly certification includes all nonfaculty personnel who were charged to the Sponsored Project during the quarter. The quarterly certifications follow the calendar year: January-March, April-June, July-September, and October-December. PIs are required to certify the Quarterly Project Effort Certification(s) for their Sponsored Projects as applicable under this Policy. Any delegation of authority for Quarterly Project Effort Certification must be approved by the Vice President for Research. 10. Violations of this policy may subject faculty and other employees to disciplinary procedures, including, but not limited to: a. Suspension of new proposal submissions, Sponsored Project expenditures, and distribution of F&A return as applicable until the faculty member’s ER is certified. b. Administrative/disciplinary processes and policies for faculty and staff. c. Reporting to the sponsoring agency any finding of noncompliance as required by applicable law, regulations and the terms and conditions of the award. 11. Criminal Penalties: Falsification of effort certification may lead to criminal charges against an individual who certifies a falsified report.

Reference

Applicable Laws, Rules and Regulations: OMB Uniform Guidance, 2 CFR, Part 200, Section 200.430 Related Policies and Procedures: - Include a reference to any related UNTHSC Policies and / or Procedures in this sub-section.

 

This page was last modified on March 2, 2020