Pre-Award Procedures and Responsibilities
1. Released Time
Commitments of faculty time will be permitted if approved in advance by the Department Chair, and the Dean of the school or college. In most cases, the grant or contract should fully reimburse the University for that portion of a faculty member's time that is being released. Summer compensation at the rate of 1/9 of the 9-month contract amount per month is routinely approved, provided that no other employment is assumed during that period. Faculty members are expected to request reimbursement for time allocated to research projects funded by grants or contracts, even though the percentage of time allocated may not call for a further reduction of course load. (See Appendix Bl)
Faculty may not be paid additional grant compensation beyond their regular contract except in rare cases where there are clearly defined extra duties. Generally, only those faculty teaching off-campus extension and continuing education courses in addition to their regular class schedules will qualify. (Faculty Handbook, April, 1997)
3. Human Subjects
All proposed research involving human subjects conducted under the auspices of a department, school, or research unit within the university requires completion of the Request for Review of Research Involving Human Subjects and the Research Protocol forms and submission to the OSRP well in advance of the proposal deadline. Research involving human subjects is required by federal regulation [45 CFR 46.102] to be reviewed and approved or declared exempt by the NCCU Institutional Review Board for the Protection of Human Research Subjects (IRB) prior to submitting a proposal for extramural funding to support such research. (See Appendix B)
The IRB meets monthly. All protocol and other documentation needed for the review must be submitted to the IRB by the first working day of the month in which the review results are needed. (See IRB Manual for detailed procedures.)
4. Use of Scheduled Substances
For certain controlled substances (drugs), specific clearance is needed. Therefore, if your proposal involves drugs, the Health and Safety Officer should be contacted to ascertain which substances NCCU is licensed to purchase and maintain. Clearance for additional substances can take up to 6 months.
5. Patent, Copyright and Publication Rights
NCCU's efforts in this regard are aimed at protecting rights of the Principal Investigator. Faculty rights to patent, copyright and publish the results of research should not be unduly restricted by the terms of grants. (See University Policies, Appendix A, and Faculty Handbook, April, 1997.)
6. Cost Sharing
For those programs that require cost share, appropriate discussions must be concluded prior to proposal preparation. Contact the OSRP to initiate this discussion. Any type of commitment on the part of the University must be cleared in writing by the University administration ( i.e. department chair, dean and Provost) Some commitments may require approval of the Chancellor. Matching funds must be approved in writing by the University.
7. Indirect Costs
Indirect cost rates are established by federal negotiation, not by the University. Contact the OSRP for the University's current negotiated indirect cost rate and for assistance with this part of the budget. The negotiated rate must be charged to all grants and contracts. Deviations must be stated in writing by the agency sponsor or waived in writing by the University administration.
8. Fringe Benefits
Employee benefits vary for different types of appointments but must be charged to the grant in proportion to the salaries that are given. (Speak to Pre-Awards Coordinator or Post-Awards Manager.)
9. University Commitments After Grant Expiration
Any commitment of the University to support a program at any level after expiration of the grant period must be cleared in writing with the University administration.
10. Checklist of Procedures for Submitting Proposals
The procedures outlined here are designed to satisfy informational needs within the University, UNC-General Administration internal processing requirements, and to assure that contractual obligations implied in written proposals are in harmony with University policies, practices, and capabilities.
In order to gain approval for submission of a research proposal to an off-campus agency:
a. Obtain from the OSRP a copy of the Proposal Forms Package which includes:
• Intent to Submit Form
• Internal Processing Forms
• Faculty Release Time Form
b. Carefully complete the information requested on each internal processing form and on each of the sponsoring agency forms.
c. Obtain the endorsing signatures of the Department Chair and Dean on the GA internal processing forms, the faculty release form and any letters of commitment for cost sharing or matching funds.
d. Proposals involving faculty, staff or graduate students from more than one department, college or school must be endorsed by all involved chairs or deans as outlined in the above procedure.
e. Submit the original proposal with the guidelines to to the Director of Sponsored Research, allowing ten (10) working days for processing. Who will need to examine in detail the budget and be satisfied that the fiscal details of the proposal are in accord with the policies of the University and of the granting or contracting agency. The Director will determine whether additional revisions or discussions are needed before final approval for submission is given. Once satisfied that the proposal is in order, the original and all signature forms will be forwarded to the Chancellor for final approval and appropriate signature. In the Chancellor's absence, the Provost, and the Director of Sponsored Research have, in that order, designated signature authority.
f. Additional requirements for electronic submission of proposals through NSF FastLane or other federal electronic system are available by contacting the Director, OSRP.
Post Award Procedures And Responsibilities
1. Notification of The Award
After favorable action on the application, a "Grant Award" or similar document is ordinarily issued by the sponsor. Upon receipt of such documents, the OSRP will complete a Notification of Award form, which summarizes the terms and conditions of the award, codes the budgets and authorizes the establishment of an account in the Office of Contracts & Grants. A copy of the award notification is forwarded to the Principal Investigator and Grants Officer(Comptroller).
When notification of the award is completed and the budget is cast, the Principal Investigator is responsible for the transmittal of all payroll forms on employees who will be paid on the grantor contract. The University Personnel Policy should be followed when hiring new employees. The following post-award procedures should be followed when a proposal is funded:
a. Notification of Grant Award when received, should be brought to the OSRP
b. NCCU Funding Account Notification of Award (OSRP Form 8) including Object Code Budget is completed by OSRP staff following analysis of all award documents and related regulations.
c. An Object Code Budget, reflecting agency approved budget and restrictions, is prepared by OSRP.
d. The completed Award Notification and Object Code Budget are sent to Grants and Contracts to assign the FRS account number and set-up the grant account.
NOTE: Package of personnel forms and procedures for implementing project related staffing can be obtained from the NCCU Human Resources Department and the Provost Office.
e. When the FRS account number is received from Contracts and Grants, the Award Notification and Object Code Budget are forwarded by OSRP to the principal investigator as well as all of those responsible for related subgrant budgetary activity (e.g., MBRS, Title III, etc.).
f. Account set-up, billing, monitoring of grant fiscal activity, and fiscal reporting will be expeditiously executed by the Office of Contracts and Grants. Monthly printouts of grant budget disposition will be sent to the Principal Investigator by the Office of Contracts and Grants.
2. If the Proposal Is Not Funded
If the proposal is not recommended for support, you are entitled to know why funding was denied. Some agencies include reviewers' comments with the declination notice and others will provide them when requested by the Principal Investigator. Most agencies permit resubmissions and some even encourage them with proposals having a basically sound idea but a design that may require some revision.
3. The Office of Contracts and Grants
The Office of Contracts and Grants (C&G) is responsible to the university and to the funding agencies for the financial administration of all contracts and grants awarded to the university. This responsibility includes the following duties:
• Determining the propriety and reasonableness of costs.
• Exercising fiscal oversight of contract and grant funds.
• Preparing and submitting financial reports and invoices.
• Maintaining an effective and auditable time and effort reporting system.
• Providing support to faculty, staff, students and the university business offices for the financial administration of contracts and grants.
a. Establishing Account
When the Office of Sponsored Research (OSRP) receives and accepts a formal notice of award from the granting agency, a copy of the award, extramural funding notification and object code budget are sent to C&G. The Grants Office proceeds to process this information according to the following steps:
(1) Establishes a grant account number.
(2) Prepares a fund authority form which is sent to the principal investigator for appropriate signatures before returning it to the grants office.
(3) Prepares certified budget data to be entered into the university accounting system.
(4) Develops a grant file.
b. Expenditure of Grant Funds
The Contracts and Grants Office will review all requests for payroll authorization, purchase requisitions and travel requests for compliance with specific grant terms and conditions and for compliance with university, state and federal regulations.
(1) Purchase Requisition:
All purchase requisitions for grant accounts, except Title III accounts, must be submitted to the Grants Office for processing before going to the Purchasing Office. Title III requisitions are first submitted to the Title III Office for endorsement.
Requisitions will be reviewed for signature of principal investigator, grant termination date, account number, object code, availability of funds and allowability of costs under the grant.
(2) Travel Requests
All travel requests must be submitted to the travel office for approval. The request is forwarded to the Grants Office for review of signature, account number, availability of funds and to determine if travel is allowed under the grant.
(3) Payroll Authorizations
Personnel commitments are handled in accordance with established university salary and wage policies. Requests for employment are submitted to the appropriate offices for approval, (i.e., the Provost Office, the Title III Office) before submission to the Grants Office. The Grants Office reviews the request for appropriate signatures, account number and object code, type of employment, distribution of time, the availability of funds and allowability of costs under the grant.
(4) Time and Effort Reports
Office of Management and Budget Circular A-21 requires effort certification for payroll distribution purposes for all payroll charges to federal contracts and grants. These Time and Effort reports account for 100% of each individual's effort even if he/she is part-time.
OMB Circular A-21 requires that the payroll distribution system (time and effort reporting) will be (1) incorporated into the official records of the University, (2) reasonably reflect the activity for which the employee is compensated by the University, and (3) encompass both sponsored and all other activities on an integrated basis. The Office of Contracts and Grants is responsible for collecting, reviewing, and maintaining the official file of time and effort reports. The department head or dean must certify the effort of the principal investigator. Certification of the effort requires that the person signing the time and effort report have first-hand knowledge of all the employee's activities during the reporting period. The completed forms (see Forms, Appendix B) should be forwarded to the Grants Office by the 5th working day of each month in which salary or wages are charged to the grant account.
(5) Cost Sharing, In-Kind and Matching
The Principal Investigator must report to the Grants Office, with accompanying documentation all cost sharing or in-kind expenditures obligated to the grant. These records must show how the value placed on the contribution was calculated. The contribution must be verifiable and documented in the university accounting records. A copy of a receipt or letter in verification of matching funds should be submitted to the Grants Office.
(6) Budget Revisions and Transfers
Requests for budget transfers and revisions must be submitted to the OSRP for approval. Upon approval the request is forwarded to the Grants Office where the revision is entered into the university accounting system.
c. Closing Grant Account
Prior to the termination of a grant the principal investigator should review the grant for available funds, deficit balances, accuracy of the account and outstanding encumbrances. All requisitions must be submitted to the Grants Office before or by the termination date. If an extension of the grant beyond the ending date is needed, a written request should be submitted to the funding agency through the OSRP prior to the termination date.
4. Internal Prior Approval System Procedures
All requests for modifications to grants, contracts, or agreements are processed through the Office of Sponsored Research (OSRP).
The extent of budget reallocations permissible varies widely from sponsor to sponsor and program to program. Certain budgeted transfers may be accomplished using the established University prior approval system, whereas other budget transfers will involve agency approval. In all cases, authorization to deviate from the award budget must be approved prior to the expenditure, not after the fact. Consult OSRP on specific issues.
a. The NCCU Organization Prior Approval System (Form 12, Appendix B) should be completed and submitted to the OSRP with endorsement by the project director and department chair.
b. The nature of the request, i.e., budget transfer no cost extension, change of PI, or other, should be described in sections I and /or II of Form 12.
c. A detailed justification for the proposed changes(s) should be stated in section III of Form 12.
d. After review by the OSRP, if the request can be approved internally, it will be endorsed by the OSRP Director and forwarded to the Office of Contracts and Grants for execution.
e. If sponsor approval is required, a written request to the sponsor for approval of changes to approved budgets, personnel, project timelines or other project needs should be sent to the sponsor through the OSRP. The requests should include a detailed statement of justification and a copy of a revised budget when appropriate. When written approval is received from the sponsor, the OSRP Director will endorse Prior Approval System Form 12 and forward to the Office of Contracts and Grants for execution.
5. Changes in Human Subjects Protocol
Changes in Human Subject Protocol must be approved by the Institutional Review Board for the Protection of Human Subjects from Research Risks (IRB).
6. Human Resources
Contact the Human Resources Department for established University procedures which must be used in hiring all persons to be supported with grant or contract funds.
Remember: Principal Investigators/Project Directors should have all payroll authorizations approved before an employee starts to work. Questions regarding position classifications and salary and wage policies should be discussed with the Human Resources Department.
7. Cost Sharing, In-Kind and Matching
All cost sharing that is required or reported to an agency must be documented. Salaries and wages must be certified via the time and effort reporting system. Supplies, materials and equipment must be supported by invoices or other documents verifying the expenditure.
The project director/principal investigator must report all cost sharing expenditures to the Contracts and Grants Office at the end of the project with supporting documentation. The Contracts and Grants Office will report expenditures to the agencies.
Practically all sponsors require a final, comprehensive report on completion of a project. The one exception is when a project is continued, in which case an interim report may also be required. There is ordinarily a firm due date for final reports, and sponsors properly expect to receive the report on or before that date. If, for reasons beyond the Project Director's control, the report will be delayed, a letter should be transmitted from the OSRP to the sponsor explaining the reasons for delay and requesting a time extension. In many cases, as with the National Institutes of Health (NIH), no costs can be charged to the project after the expiration date even though the report may not have been delivered. Consequently, if the report is not completed on or before the expiration date, there may be difficulty in paying such costs as typing, art work, duplication, etc.
The University cannot receive its final payment under a contract or grant until the sponsor's final reporting requirements are met. Therefore, undue delay in submission of the final report may work a financial hardship on the University. There is also a very real probability that both the Principal Investigator's and the University's image with the sponsor may be damaged.
9. Program Income
For grants with program income please consult the university's Policy.
See the Roles and Responsibilities Matrix for additional grants management guidance.