Grants and Contracts
| POLICY STATEMENT |
This policy outlines the procedures through which grants and contracts are obtained and negotiated for Delta State University.
| DEFINITIONS |
Authorizing Officials (AO’s)
Designated positions with the authority to enter grant agreements and commit university resources toward an externally-funded project.
Certifications
Assurances, issued or described by the institution, required at the time of proposal submission and/or award acceptance, which inform federal agencies that the University has applicable policies and procedures in place to successfully carry out the project.
Contracts
A financial assistance mechanism used by a Federal and/or non-Federal funding agency for specific inquiry directed towards particular areas of research and development, instruction or other sponsored activities needed by the funding agency. A contract usually involves defined deliverables and/or services expected to be performed by the grantee within a specified project period.
Cooperative Agreements
Cooperative agreements, a financial assistance mechanism, similar to grants in that they are awarded by the funding agency to assist and support research and related activities.
External Funding
External support including grants, contracts, and cooperative agreements.
Facilities and Administration Costs (Indirect Costs)
Expenses incurred by the University generally considered to be overhead costs, not easily attributable to a single project or activity.
Fringe Benefits
Fringe benefits are actual personnel expenses associated with any salary paid by the University.
Grants
A grant is a financial assistance mechanism, used when the idea for the research or training project is initiated by the investigator following the conditions and criteria established in the agency guidelines; when no substantial program involvement is anticipated between the funding agency and the institution; and when there is no expectation on the part of the funding agency for delivery of a specified product or service for the use or benefit of the funding agency. Funding agencies, however, do expect grantees to share with the public any results, products or model projects that further the knowledge of the discipline, the research community and/or society as a whole.
Institutional Based Salary (IBS)
The annual compensation paid by the University for an Individual’s Appointment, whether that individual’s time is spent on research, instruction, administration, or other activities.
Office of Institutional Grants
The office officially charged with the oversight of all external funding processes, procedures, and proposals for Delta State University.
Principal Investigator (PI) or Project Director (PD)
The Principal Investigator or Project Director (PI/PD) has primary responsibility for ensuring that all programmatic and fiscal requirements of the grant are met. Only regular, full-time faculty and/or staff may serve as a PI/PD on a grant and/or contract. Sponsors may at their discretion further define and restrict those allowed to direct projects or act as PI/PD. With permission of the Provost/VPAA, part-time employees or non-paid representatives of the University may serve as PI/PD.
| PROCEDURES and RESPONSIBILITIES |
(All federal grants and contracts comply fully with the current federal PART 200—UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS)
The Office of Institutional Grants is formally charged with the responsibility of providing services to faculty and staff for securing external support from federal, state, and nonfederal sources including foundations and corporations, assisting faculty and staff in identifying, preparing, and obtaining research, educational, and service grants and other funding opportunities. It is charged with ensuring that proposals are in adherence with University policy and funder requirements; for maintaining the official grant file; and for reporting external funding to IHL and other entities as requested.
Delta State University is the legal entity for all obligations relating to contract and grant activity. All proposals which use the name and resources of Delta State University and which may result in an award to the University or an award to an individual functioning in a university capacity involving restricted funds must adhere to University policies and procedures for submitting a proposal, accepting an award and administering the project. While there is no expectation on the part of the funding agency for delivery of a specified product or service for the use or benefit of the funding agency, funding agencies do expect grantees to share with the public any results, products or model projects that further the knowledge of the discipline, the research community and/or society as a whole.
Internal Approval of Projects
All external funding proposals, both new and continuation, submitted by the University must go through an internal process via the Office of Institutional Grants Internal Approval Form and with the approval of the University’s Authorizing Officials (AO’s): the Vice President of Finance and Administration, Provost/Vice President for Academic Affairs, Dean of Graduate and Continuing Studies, and Director of Institutional Grants. The AO’s are formally charged with approving proposal submissions and acceptance of awards and contracts, including related certifications required by funding agencies during the proposal and award process. These authorizing officials must also approve all negotiations and re-allocations of funds that occur after the original proposal has been submitted. Grant proposals will not be submitted if all signatures are not obtained.
Only the President, Vice President of Finance and Administration, and Provost/Vice President of Academic Affairs are authorized to commit expending university funds regardless of funding source.
It is the responsibility of the PI/PD to obtain approval for proposal submission by their department chair and dean substantially in advance of university and funder submission deadlines. All proposals, with a required project budget, must be submitted to the Office of Institutional Grants a minimum of four business days prior to the funder’s due date in order to ensure appropriate institutional approval. Once the proposal is deemed in compliance, the Director of Institutional Grants will process the Internal Approval Form for approval by the Authorizing Officials. Proposals submitted in less than four business days prior to the due date may not be reviewed and approved for submission. Complicated proposals and those with significant commitment of university resources shall be discussed with the Director of Institutional Grants well in advance of the minimum four business days noted above, in order to allow the Authorizing Officials sufficient review of the proposed commitment.
Early approval by department chairs and deans (or supervisors) and the timely submission of proposals to the Office of Institutional Grants ensure sufficient time for the thoughtful consideration and review of sponsored project descriptions, budgets, and resources for compliance with University and sponsor policies.
Failure to obtain internal approval prior to submitting a proposal may result in funding being declined upon award notification.
Management of Sponsored Projects
While several offices may be involved with the management of restricted funds, the Office of Finance is responsible for approving all expenditures from a restricted fund account. Upon notification of award, the PI/PD will contact the Office of Institutional Grants, which will notify the Office of Finance to establish a restricted fund account for that grant award. That office will be involved with the principal investigator throughout the management process relating to restricted fund accounts.
All University policies and procedures relating to expenditure of funds must be followed for all contract and grant activity (i.e., purchasing rules, travel policy, property management, human resources).
The PI/PD is responsible for ensuring that all contractual requirements of the funder are followed including documentation and reporting requirements. Each funder is unique and has different requirements. It is the PI/PD’s responsibility to know those requirements and ensure that they are met and to document all contracted time and effort committed towards a grant funded activity.
Contract performance is closely monitored by the funding agency to ensure accomplishment of contract goals or deliverables. A contract is usually issued as either a fixed-priced contract or a cost-reimbursement contract. A fixed-priced contract is used when the agency agrees to pay a “fixed amount” regardless of the actual costs of the project. That is, price adjustments are not made after the award of the contract, regardless of the actual costs of the performance of the work. Therefore, if a fixed-priced contract is under budgeted, the University must absorb the cost difference.
A cost-reimbursement contract is used when the funding agency agrees to pay the University for costs that are allowable, allocable and reasonable in performing the project. The agency will usually establish a “not-to-exceed cost” or a “cost ceiling” for the contract. Once that ceiling has been reached, the University stops work and incurs no further liability.
Cooperative agreements are treated like grants; however, grants require minimal or no involvement of the awarding agency during the performance of project activities, whereas cooperative agreements involve a substantial cooperation and/or coordination between the funding agency and the University.
Budget Revisions
It is sometimes necessary to revise the grant project budget. Most funders have regulations and mechanisms in place to make budget revisions. All budget revisions must be submitted through the Office of Institutional Grants. The Director of Institutional Grants can assist the PI/PD with the funder requirements regarding budget revisions and with developing the budget revision request.
Reporting Requirements
The Office of Finance is responsible for submitting all fiscal reports to funding agencies. Official financial reports are prepared by the Office of Finance, which is also involved in all audits on restricted funds and is responsible for maintaining copies of all final technical reports for audit purposes. The Office of Institutional Grants is responsible for maintaining records of grants, contracts, and cooperative agreement activity for the purpose of all other reporting.
It is the responsibility of the PI/PD to ensure that all programmatic reporting is submitted in a timely manner. The PI/PD should notify the Office of Institutional Grants in the event that there may be a deviation from the original grant application.
Acknowledgement of Funding Sources
Any publication, recording, performance, presentation or other scholarly activity that is the result of a sponsored project should acknowledge all the resources contributing financial support.
Human Subjects
The Human Subjects Committee (Institutional Review Board, “IRB”) assures that adequate protection of human subjects’ rights and welfare are carried out in accordance with federal guidelines. This Committee, composed of representatives from all colleges as well as a community representative, is required to review all research projects involving human subjects before initiation of data collection. It is the responsibility of the PI/PD to ensure that IRB requirements are followed.
Cost Sharing (Matching Funds)
The University may be required to contribute to the costs of a sponsored project as stated in funding agency guidelines. In some cases, these expenses may be in the form of “in-kind” costs such as contributed effort of personnel (salary and fringe benefits) who are supported by non-sponsored funds. At other times, there may be a requirement for “cash,” particularly for equipment-related projects.
When cost sharing funds are required, the PI/PD is required to discuss these needs with the respective chair/director and dean. Grant proposal budgets which include a commitment of matching salary funds by the institution must have the prior approval of the Provost. If these areas cannot provide the total cost share required for the project, the PI/PD should contact the Director of Institutional Grants for assistance in determining possible cost sharing areas.
Cost sharing may also come from non-university, third-party arrangements. These arrangements must be committed and documented at the time of proposal submission.
The University is required to document all cost sharing/matching funds just as it tracks agency dollars. These funds are auditable expenditures, and the primary responsibility for documentation rests with the PI/PD.
Indirect Costs/Facilities and Administrative Costs (F & A)
Indirect Costs (sometimes referred to as Facilities and Administrative Costs or F & A) are actual costs incurred by the University that cannot be readily identified or associated with a single sponsored project or activity. These costs are normal business activities of the University such as utilities, public safety, libraries, building and equipment use and maintenance, accounting, payroll, and academic and sponsored administration. Every project has indirect costs associated with it; however, funding for indirect costs is described and approved according to each funder’s guidelines or requirements.
The determination of F & A costs rates is based on a cost proposal submitted by the University to its respective federal cognizant agency, the Department of Health and Human Services. This proposal contains all of the “F & A” categories that relate to direct costs necessary to conduct the primary functions of the institution such as teaching, research and other activities. Rates are then negotiated and a final rate agreement is signed establishing the required rates for all projects submitted to external funding sources. DSU’s current negotiated rates are applied against salaries and fringe benefits to determine the indirect cost funding by agencies following the federal guidelines.
In the event that the funder does not allow for the recovery of indirect costs using the federally negotiated indirect rate, only the Provost/VPAA has the authority to waive the federally-negotiated indirect rate. Any reduction of rates must be documented at the time of proposal approval. It is the responsibility of the PI/PD to provide documentation demonstrating that the funder will not recognize the university’s federally negotiated rate.
With regard to distribution of recovered F & A (Indirect) costs, the University promotes a distribution formula for units [49% E & G budget, 1% Accounting and Finance, 14% Provost; 2% Grants Office, 34% Dean and Originating unit (or Administrative Office)]; the final F & A distribution for individual, internal units may depend on the PI/PD’s home department or unit guidelines.
Salaries Charged To Grants
Faculty Course Release Time
Faculty members are encouraged to work on the grant during the academic year, if allowable by the grant and if qualified personnel are available to teach their course(s). If allowed by the grant, a faculty member may then request the granting agency “buy out” a portion or all of their course responsibilities. The faculty member must receive permission from his/her department/division chair, appropriate Dean, and the Provost for a “course buy-out.” Faculty members working on federal grants may then charge a proportionate share of their base salary and fringe benefits to the grant, but faculty may not increase their total compensation by working on a grant. The salary charged to the grant is based on their regular, annual compensation, also referred to as their Institutional Base Salary or IBS. If approved, the faculty member’s proportionate salary and fringe benefits will be charged to the grant, providing the University the funds to pay for adjuncts or overloads to cover the teaching assignments.
Faculty Consulting
For faculty consultation on a grant funded project that reaches across departmental lines or involving a separate or remote operation that is in addition to his or her regular responsibilities, additional compensation above IBS may be allowable provided that such consulting arrangements are specifically provided for in the grant budget or in writing by the granting agency, expressly communicated in an Memorandum of Understanding, and approved by the faculty member’s chair and dean.
Additional Compensation
Additional compensation, similar to Overload Compensation, is allowable if all of the following conditions are met:
- The Department is unable to identify qualified personnel to teach the faculty’s assigned course, preventing a “Course Buy-Out” as described above.
- The compensation is consistent with the university’s policies on Additional Compensation
- A Memorandum of Understanding is in place and approved by the faculty member’s chair and dean.
- Compensation charged to the grant is not at a rate higher than the IBS rate of pay for the amount of additional work performed.
Faculty Summer Salary
For periods outside the academic year, the Uniform Guidance states: “Charges for work performed by faculty members on federal awards during periods not included in the base salary period will not be excess of the IBS.” §200.430(h)(5)(i); and “Charges for teaching activities performed by faculty members on Federal awards during the periods not included in the IBS period will be based on the normal written policy of the institution governing compensation to faculty members for teaching assignments during such periods.” (Uniform Guidance 200.430 (h)(5)(ii) )
Consequently, faculty members may earn additional compensation for working on grants from mid-May (after graduation) until 31 August (when the summer ends). The base salary is defined as the 9-month salary (for which the faculty member is paid over 12 months). The maximum monthly salary permitted under a grant is one-ninth of the base salary. The maximum percentage of the base salary that can be earned during the summer period will be 33.3%. The PI/PD will document faculty time and effort as required by funder.
Administrative and Staff Salaries
Salaries and wages of current administrative and clerical staff are not typically funded as direct costs to the grant. Any exceptions will be determined in consultation with the Director of Institutional Grants.
Fringe Benefits
Fringe rates are determined by the Office of Human Resources. Every salary (excluding students’ pay) associated with contract and grant activity has a corresponding fringe rate to be charged. These benefits include such items as workmen’s compensation, health insurance, and FICA. The Office of Institutional Grants will work with the PI/PD to ensure accurate inclusion of fringe benefits in the budget request.
An employee hired or contracted under a grant has equal rights and responsibilities as a university employee, unless expressly exempted in the grant. The PI/PD will ensure that benefits (vacation time, for example) have been utilized by the time a person employed under the grant leaves the position so that university resources are not required to accommodate leave not taken.
Tuition Remission, Degree Completion Compensation, and Merit Raises
A full-time grant-funded employee may be eligible for tuition remission (for the employee only), degree completion compensation, or a merit raise if the employee meets the University’s requirements. Eligibility, however, will be subject to grant guidelines, restrictions, and the availability of funds.
Prior approval is needed from the Office of Institutional Grants and from the Office of Human Resources for tuition remission, degree completion compensation, and merit raises for full-time grant-funded employees.
Responsible Office and/or Policy Owner: Office of Institutional Grants
| RELATED DOCUMENTS |
- Uniform Guidance, Part 200 — UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS
- Office of Grants and Contracts’ Internal Approval Form
- Time and Effort Form
| STATUS |
Active
| DATES(S) |
Change/Review/Approval Date:
- Policy Effective Date: 11/30/2015
- Approved by Academic Council: 04/22/2014; 02/09/2017
- Approved by Cabinet: 05/12/2014; 02/20/2017; 08/20/2018
