Applying
for Sponsored Programs UPPS
No. 02.02.01
Issue
No. 6
Effective
Date: 02/29/2008
Review: July 1 ONY
01. POLICY STATEMENT
01.01 This
UPPS provides guidelines for developing and submitting proposals through the
Office of Sponsored Programs (OSP).
02. UNIVERSITY PHILOSOPHY AND DEFINITIONS
02.01 Texas State encourages faculty and staff to
pursue sponsored program activities in their areas of expertise. Because
scholarly activities augment teaching, faculty are encouraged and expected to
participate in meetings, conventions, and other activities that promote
scholarship and creative work, including applying for and administering
sponsored programs.
02.02 Texas State’s policies apply to all sponsored
programs unless the granting agency establishes exceptions. Grant applications
that Texas State approves must clearly identify these exceptions. These
exceptions may not conflict with federal or state law or with the Regents’
Rules.
02.03 Sponsored Program Definition - Sponsored
programs are defined as those activities, sponsored whole or in part, by
sources external to the University for which there is an expectation (implied
or specifically stated) on the part of the sponsor for performance, deliverable
or outcome. Sponsored programs are generally conducted by faculty, but may be
conducted by staff or members of the University administration. Sponsored
programs are awarded through various mechanisms - grants, contracts,
non-teaching consulting services, and cooperative agreements, or other legally
binding means of transfer.
02.04 Sponsored Programs may support instruction,
research and public service activities.
They are identifiable by the following characteristics. A program does not
need to include all elements to be considered to be "sponsored."
a. Inclusion/allowance
of Indirect Costs/Administrative Costs
b. Percentage
of faculty time on project (may or may not be compensated by the sponsor)
c. Expectation
of performance or outcome by the sponsor
d. Statement or
expectation of a “quid pro quo” relationship between the University and the
sponsor
e. Specific
description of the activity or work to be conducted (proposal or contract)
sometimes known as a Scope of Work
f. A Line Item
budget is involved
g. A financial
report is required, and the budget/performance is subject to audit
h. All
government funds, exclusive of financial aid
i. All
corporate research contracts, subcontracts or agreements
j. Defined time
period for the work to be conducted
k. Definition
of how the funds may be spent and what conditions may apply to residual funds
l. Use of
University resources – equipment, space, students – mandate processing through
OSP to determine classification, i. e., does the activity qualify as a
sponsored program and who must approve the use of these resources.
02.05 The following further clarifies definitions
relating to sponsored activities:
a. Grant – A type of
financial assistance awarded to an organization for the conduct of research or
other program as specified in an approved proposal. The proposal typically
defines a scope of work or performance. The sponsor makes an award, which may
be based upon a competitive review, and establishes terms and conditions for
performance. These terms may be generally stated, as in many federal awards, or
may specifically describe allowable and unallowable activities and costs. Unless
prohibited by sponsor regulations, performance under grant awards may be
modified to adjust to project conditions. Such modifications may be approved
internally by the University or may require sponsor authorization. Grants may
be awarded through simple contractual agreements, letters of authorization,
payments of fees, or other similar mechanism. Their defining feature is that
they are governed by specific rules and regulations pre-established by the
sponsor, and that they provide for some flexibility in the conduct of the
activity.
b. Contract – A legally
binding arrangement or performance agreement for carrying out a specific
service or procuring a product that entails specific obligations for both
sponsor and recipient. Contracts are a more restrictive mechanism for securing
services than grants, and may specify penalties for non-performance. A Fixed
Cost or Fee for Service Agreement is one in which one party pays the other
party a predetermined price, regardless of actual costs, for services
rendered. A Cost-Reimbursement Agreement
is one in which the sponsor pays for the full costs incurred in the conduct of
the work up to an agreed-upon amount, and for which invoices containing back-up
information of costs incurred are generally required. A Percent Completion
contract is one in which the sponsor contracts for completion of specific
tasks, and payment is made upon receipt and approval of a report or other
deliverable.
Contracts
may be awarded for research, assessment, specific work performance,
instruction, training, or similar activities. Generally, contracts will define
specific details of the legal relationship between the participating entities
and will incorporate the description and cost of the work to be performed
either as a legally binding attachment or embedded in the contract document. A
purchase order may be a form of contract.
c. Matching
Grant – Some sponsors require the applicant to demonstrate commitment to the
proposed activity by providing funds in support of the overall project costs. Matching
funds may be derived from institutional resources, either in-kind (donated
time, space, equipment use, etc.) or cash, or may be generated from other
entities (third party). Sometimes the Principle Investigator (PI) (faculty
submitting the proposal who will do the work if funded) will include matching
or cost sharing to enhance chances of being funded, even if the sponsor does
not require matching.
Cost-sharing
has become a major issue in federal awards. Recently, the federal government
issued specific guidance on matching funds and the responsibilities of
recipients in accounting for these funds.
Failure to comply may result in loss of revenue associated with the
specifically funded project, or in general sanctions against the institution. The
following are the three types of cost-sharing:
1) Mandatory – Required by the sponsor and
specifically referenced in the proposal, budget or other submitted document.
Must be accounted for in the institution’s accounting system.
2) Voluntary Committed – Committed by the
institution in the proposal, budget or other submitted document to enhance
possibility of funding, but NOT required by the sponsor. Must be accounted for
in the institution’s accounting system. (Note: if a proposal is submitted with
voluntary cost-sharing, and is subsequently awarded, the status of the
cost-sharing converts to Mandatory.)
3) Voluntary Uncommitted – After the award is
received, the University/PI provides more cost sharing than is promised or
required. For example, a PI spends more time on the project than originally
projected. Must be tracked and verified,
but IS NOT entered into the institution’s cost-sharing system.
Funds
promised or provided by third parties to a sponsored program must meet the same
reporting requirements imposed on the institution. The recipient (University) is responsible for
acquiring and maintaining third party matching documentation.
d. Challenge
Grant – A grant that provides monies in response to monies from other sources,
usually according to a formula. A challenge grant may, for example, offer two
dollars for every one that is obtained from a fund drive. The grant usually has
a fixed upper limit, and may have a challenge minimum below which no grant will
be made. This form of grant is fairly common in the arts, humanities, and some
other fields, but is less common in the sciences. A challenge grant differs
from a matching grant in at least one important respect: The amount of money
that the recipient organization realizes from a challenge grant may vary
widely, depending upon how successful that organization is in meeting the
challenge. Matching grants usually award a clearly defined amount and require
that a specified sum be obtained before any award is made.
e. Cooperative
Agreement – an award similar to a grant, but in which the sponsor’s staff may be
actively involved in proposal preparation, and anticipates having substantial
involvement in research activities once the award has been made.
f. Non-teaching
Consulting Services – Consulting as an agent of the University is
defined as additional activity beyond duties assigned by the institution,
professional in nature and based in the appropriate discipline for which the
individual receives additional compensation during the contract year. Consultancy
services include addressing the technical and professional needs of
communities, groups, agencies, businesses and other entities outside the
University. Consulting services are NOT sponsored programs unless the University
is the direct recipient of funds, and liable for the conduct of the activity
performed by the University employee. In this instance, it is essential that
these contracts are managed as sponsored programs, in that they involve
coordination of faculty time and effort reporting, and determination of
appropriate overload policy interpretation.
g. Training/Workshops/Non-Credit
Teaching – Proposals for conducting training/workshops/non-credit teaching
functions are considered to be “sponsored programs” if they meet any of the
above-stated criteria.
NOTE: Activities meeting the above criteria may be
proposed by the Director of Continuing Education in the same manner as other
sponsored programs. OSP will review, process and submit proposals on behalf of
that unit as with other colleges and schools. IDC generated from these
sponsored activities is subject to the same distribution as other units.
h. Gift – A
flexible, irrevocable award of money, equipment, or other property provided by
a donor with few or no conditions specified. Gifts may be provided to establish
an endowment or to provide direct support for existing programs. Frequently,
gifts are used to support developing programs for which other funding is not
available. Gifts meet the determination of having no “quid pro quo”
relationship with the University, and as such are handled by University
Advancement.
A gift to an
organization implies no responsibility to provide the donor a product, service,
technical or scientific report or intellectual property rights. The donor may
specify the use of the funds (as in to a specific scholarship fund) or the gift
may be unrestricted for use in meeting the needs identified by the recipient
organization.
i. Research
gift – A gift for research generally must meet the following conditions:
1) Funds are
awarded irrevocably;
2) The donor
does not impose restrictive contractual obligations;
3) There is no
commitment of direct project personnel effort to accomplish the research; and
4) The funds
are designated for scholarly endeavors
A research gift may be considered a sponsored
project pending discussions with University Advancement.
NOTE: OSP
serves as the first point of contact for faculty seeking external funds. The Office
will review project/program concepts with faculty and seek possible sources of
support on their behalf. From time to time, concepts may be forwarded to University
Advancement for consideration as a fundraising possibility.
j. Endowment – A
fund usually in the form of an income-generating investment, established to
provide long-term support for faculty or research positions (e. g., Endowed
Chair). Endowments are not considered to be “sponsored activity.”
k. Internships – An
externally supported opportunity for an individual (student or faculty member)
to engage in an extended learning activity.
If the University is the recipient of internship funds and the funding
mechanism contains specific details concerning the obligation of the
institution or the intern, the activity is treated as a sponsored program and
must be internally approved and submitted as such.
l. Congressional/Legislative
Allocations – In certain circumstances, federal or state governing bodies may
directly appropriate funds to the University for specific purposes. It is
important that the purpose of these funds represents the intent of the funding
entity. In the case of most federal and state appropriations, the most common
conveyance mechanism is to attach these funds to an existing agency program,
and to request a proposal describing how the University will utilize these in
keeping with the general intent of that specific program’s mandate. An award is
then made to the University by the agency. In this circumstance, the federal or
state regulations and restrictions applied to all recipients of funds under
that agency program apply to the use of funds awarded to the University. For
this reason, proposals requesting support under direct appropriations become
sponsored programs so that they may be accounted for and managed properly.
NOTE: Definition
courtesy of Georgia Southern University
03. PROCEDURES FOR APPLYING FOR GRANTS AND
CONTRACTS
03.01 The Associate Vice President for Research
(AVPR) is responsible for submitting proposals to public and private funding
agencies, except for proposals that require submission by the Development
Foundation.
03.02 Faculty
and staff must submit all proposals for research or sponsored programs (whether
for grants or contracts) through OSP. They must submit all proposals for
permanent endowments, scholarships, and capital improvements through the Vice
President for University Advancement. Proposals not submitted thru proper
university channels are subject to recall at the AVPR’s discretion.
03.03 The AVPR will build opportunities by developing
partnerships between departments, collaborating with other universities and
industries, and establishing affiliations with potential funding agencies and
the U.S. Congress.
03.04 The Office of the AVPR will also enhance the
University’s academic environment by promoting and supporting grant
opportunities. The AVPR’s Office of Proposal Development will assist PIs to
identify potential funding sources and build collaborations with other
entities. When a funding opportunity is identified, the PI has prime
responsibility for developing the proposal.
03.05 Proposal
Preparation
a. Only the
following are eligible to serve as a PI on a sponsored program: (1) full-time
tenured and tenure-track faculty; (2) full-time research faculty; (3) certain
directors of research program centers or institutes; and (4) full-time staff
employees. The college dean and the AVPR may approve exceptions to this policy.
b. University
faculty and staff who wish to submit a proposal to an external funding source
must first contact their chair, dean, or director to discuss the proposal
plans.
c. After
gaining chair, dean, or director support for the proposed project, the faculty
or staff member (who will be the PI of the project) must contact OSP to begin
working with OSP on the proposal through the proposal management system, GAMS.
d. Other
responsibilities of the PI include the following:
1) The
PI bears the primary responsibility for the accuracy of all material in the
proposal and for compliance with all federal, state, private, Texas State
University System, and Texas State regulations such as those relating to
scientific misconduct in research, disclosure of financial conflicts of
interest, and management of human research subjects or lab animals. He or she
has the responsibility to become informed about those regulations, with
guidance from OSP.
2) Completing
the grant application thru GAMS.
3) Developing
and verifying all financial data with OSP prior to routing the proposal. OSP will determine that the requested
facilities and administration costs conform to the University’s federally
negotiated rate or are the maximum allowed by the funding source. PIs
are not authorized to negotiate sponsored program agreement terms with
prospective funders. The AVPR must approve all deviations from the current
negotiated rate in writing.
4) Identifying
all requirements for space needed to operate the contract or grant. If the
needed space is not available and under the control of the department chair,
the dean must be consulted to identify available space under the control of the
college. If space is not available within the college, the PI must add a
request for rent or lease funds in the contract or grant budget to obtain
space. If space is needed to ensure the success of the sponsored program,
the PI must make arrangements at the department
or college level for additional space before the proposal is submitted
to the Office of Sponsored Programs. Please see UPPS No. 08.01.01.
5) Determining,
with the assistance of OSP, which University review boards must review the
proposal for compliance with state and federal guidelines concerning research
activities. The PI must receive his or her approval prior to submitting of
their proposal. Relevant university
review boards include, the Institutional Review Board on the Use of Human
Subjects in Research (see UPPS No.
02.02.03) and the Institutional Animal Care and Use Committee (see UPPS No. 02.02.05).
6) Identifying,
with assistance from OSP, any technology needs. The PI must notify the Vice
President for Information Technology and the Assistant Vice President for
Technology Resources of needs for additional university technology and needs
for technical support required of Technology Resources.
7) Identifying
the amount and source of matching funds, both monetary and in-kind, as well as
making sure that the account manager for these funds has approved the pledge in
writing Pledges of indirect cost as all or part of a match are prohibited,
unless approved in writing by the AVPR.
8) Ensuring,
with help from OSP, that the proposal complies with pertinent state, federal,
or private policy such as those relating to scientific misconduct in research
or disclosure of financial conflicts of interest, coordination of Financial Aid,
and management of human subjects and lab animals.
9) Ensuring,
with help from OSP, that the proposal complies with Affirmative Action
regulations and that it meets any other regulations that might apply, such as
those mandated by section 504 of the 1973 Rehabilitation Act, the 1990
Americans with Disabilities Act and other relevant federal and state laws
pertaining to persons with disabilities.
10) Submitting
the complete proposal to OSP at least five working days before the submittal
deadline.
03.06 Timeline:
The PI must provide for enough time for adequate review of the proposal by the
chair, dean, or director. The PI should release the proposal through GAMS for
routing and approvals at least five working days before the submission deadline
of the funding source (see Section 04. below).
Special
Consideration: Note that if an award is received, and faculty, staff, or
students are employed on that award, the PI must follow all university
04. REVIEW PROCEDURES
04.01 PIs
must receive approval for their proposals by releasing their proposal for
routing and approvals through the GAMS proposal management system. The proposal
shall include at a minimum:
a. A
draft narrative
b. Complete
budget
c. Completion
of the internal processing form
05. NOTIFICATION PROCEDURES
05.01 The
funding source may send the notification of acceptance or rejection to any of a
number of different locations. The office receiving the notification must
forward it to OSP. Failure to do so will delay establishment of a Texas State
account for accepted grants.
05.02 The
action required as a result of the rejection of a proposal varies from one
proposal to another. Therefore, the PI or OSP will determine the proper
individuals to notify concerning the rejection notification.
05.03 When the potential funding source is a corporation or
foundation, the Director of Proposal Development will notify University
Advancement regarding a proposed submission, an acceptance or a rejection.
06. AWARD IMPLEMENTATION
06.01 A sponsored program is not operational
until both the University and the source providing the funding have signed a
contract or award. Awards at Texas State are made to the University and are not
personal grants or contracts to the PI. Only the President or his or her
designee can obligate the University and are the only persons authorized to
sign a grant or contract. No commitment, financial or otherwise, can be made
until the University has received a signed copy of the contract or a formal
award in writing or, in some cases, until the Director of the Office of
Sponsored Programs, is assured by the funding source that such award is in
transit. If a PI deems it necessary to begin work prior to the receipt of an
executed agreement, an expenditure account can be established in accordance
with the rules located in UPPS No. 02.02.02,
Section 05.03. In the event that a PI or other individual not authorized as a
contracting official signs a contract or award with a funding source, that
individual may be held personally liable for any expenditure or obligation of
university resources to the contract or award subsequently determined to be
invalid. Additionally, the University may take disciplinary action against that
individual including revocation of the individual’s status as a PI.
06.02 Acceptance
of the award constitutes a commitment by the PI to comply throughout the grant
period with all policies of the Texas State University System, University, all
state and federal regulations, and all funding agency requirements. If the PI
does not comply, the AVPR or the Director of OSP will take appropriate steps to
ensure that the contractual obligations of the University under terms of the
award are set. These steps may include
removing the PI from the grant or contract and prohibiting him or her from
future work as a PI.
06.03 When
the award notification is received by OSP, the Director will review the
financial terms of the agreement and, provided such terms are satisfactory,
will establish a Texas State account. In the event that terms are not
satisfactory, the Director of OSP will attempt to renegotiate the terms and
conditions of the award. If negotiations are not successful and the terms are
considered unacceptable, the AVPR may reject the award on behalf of the
University.
06.04 Expenditures
from all sources other than the appropriate Texas State account, even prior to
the establishment of a Texas State account, are personal liabilities of the
person making the expenditure and will not be reimbursed from university funds.
Exceptions due to extraordinary circumstances require approval of the Director
of OSP.
06.05 Refer
to UPPS No.
02.02.02 for policies regarding the managing of a grant once it is awarded.
07. REVIEWERS OF THIS UPPS
07.01
Reviewers of this UPPS
include the following:
Position Date
Associate Vice President for Research July 1 ONY
and Director of Federal Relations
Director, Sponsored Programs July 1 ONY
08. CERTIFICATION STATEMENT
This
UPPS has been approved by the following individuals in their official
capacities and represents Texas State policy and procedure from the date of
this document until superseded.
Associate
Vice President for Research and Director of Federal Relations; senior reviewer
of this UPPS
Provost
and Vice President for Academic Affairs
President