(A) Purpose. The sponsored programs
office ("sponsored programs") resides in the division of research and
sponsored programs and, together with grants accounting in the
controller's office, is responsible for stewardship of external funds
received for sponsored projects. Sponsored programs oversees submission of
proposals to external sponsors, negotiation/acceptance of grant and contract
awards, and other Sponsored programs-related matters. Sponsored programs shall
assist faculty and staff with:
(1) Retrieval of funding
source information;
(2) Preparation of
proposal applications to include budgeting;
(3) Authorization and
submission of proposals to federal/state/local/private sponsors;
(4) Negotiation/acceptance of grant/contract award
agreements to include review of terms/conditions;
(5) Plans for spending
awarded funds;
(6) Award modifications
to include changes in scope of work or key personnel, re-budgeting, and/or
no-cost extension requests; and
(7) Grant/contract
personnel appointments.
(8) Additionally, in
cases of proposed or awarded projects, sponsored programs shall guide faculty
and staff in interpretation of university/federal/state/other sponsor policies
relative to cost principles; external sponsor-required university cost sharing;
effort certification; university use/maintenance/sharing of equipment;
intellectual property rights; use of human participants; animal care and use;
use of high hazard chemicals, radioactive materials, recombinant DNA,
bio-hazardous materials, select agents/toxins; matters related to export
controlled data; and classified research/sensitive but unclassified research.
(B) Scope. A "sponsored
project" is defined as any externally funded research or scholarly
activity that has a defined scope of work or set of objectives, which provides
a basis for sponsor expectations. This more specifically involves research,
demonstration, professional development, instruction, training, curriculum
development, community and public services, or other scholarly activity
involving funds, materials, or other forms of compensation, or exchanges of
in-kind efforts under awards or agreements.
(1) A project is
considered a "sponsored project" if any one of the following
conditions apply:
(a) The project is awarded based on a proposal request;
(b) The university commits to a statement of work for a
specified project;
(c) The project involves a set of objectives which provides
the basis for sponsor expectations;
(d) The proposal includes a detailed budget;
(e) There is a written agreement for a commitment of
resources between a sponsor and the university, there is a specified period of
performance, requires deliverables (such as reports, financial accounting, or
intellectual property ownership);
(f) The award provides for the disposition of tangible or
intangible property that may result from the project (such as equipment,
records, formal activity reports, rights in data, software, copyrights,
invention or research-related materials);
(g) The sponsor is involved in making decision regarding
project performance; or
(h) The project involves the use of human subjects,
laboratory animals, radioactive or hazardous materials, recombinant DNA,
carcinogens, pathogens or proprietary materials.
(C) General principles.
(1) To generate proposals
for external funding to the university, Sponsored programs will disseminate
information on funding opportunities across all campuses.
(2) Compliance. Proposals
must be consistent with the mission of the university and must be suitable to
the unit in which the project is to be conducted. A proposal is a formal offer
by the university to conduct a program under the direction of the principal
investigator/project director who does so utilizing personnel and facilities of
the university. Therefore, projects must comply both with university policies
and external sponsor regulations. Authority for proposal submission resides in
sponsored programs where the authorized organizational representative (AOR) or
his/her designee is the legal signatory on submissions.
(3) Acceptance and
contracting authority. A grant or contract award is an award to Kent state
university and, as such, must be accepted by the university. Authority for
acceptance resides in sponsored programs where the AOR or his/her designee
serves as the legal signatory on grant or contract agreement
documents.
(4) Principal
investigators/project director role eligibility. Faculty members and
professional staff who are full-time university employees may serve as
principal investigators/project directors. It is the responsibility of the
principal investigators/project directors to maintain academic and research
integrity in the conduct of his/her sponsored project. A project may be carried
out under the direction of one or more principal investigators/project
directors within a single department, school, institute, center, regional
campus or college or under the direction of such individuals from various
cooperating units. In extenuating circumstances, an individual who is not a
full-time employee may serve as principal investigator/project director; such
cases must be sanctioned by the chair of the department/institute or center
director, or regional campus dean from which the proposal is submitted. A
full-time employee must assume both reporting and fiscal responsibility for the
resulting award if granted.
(5) Approval process.
Prior to the submission of the proposal to an external sponsor, a proposal must
be approved electronically through the Coeus grant proposal and management
system, or any subsequent system in place at the university as designated by
sponsored programs. Though completion of the routing and approval process, the
principal investigator/co-investigator/project director/co-director must accept
responsibility for the proposal's content while also certifying compliance
with the sponsoring agency and institutional requirements. Also prior to
submission to an external sponsor, the proposal must be approved by the
appropriate chair(s), director(s), regional campus dean(s), dean(s), or other
university officer(s), as relevant, indicating to sponsored programs that the
proposed project, its budget, and the level of effort committed by university
personnel have the necessary university endorsements.
In reviewing the proposed project, the
chair/director, dean or regional campus dean must ascertain that the proposed
project is consistent with the goals of the department, college, school, or
regional campus, that the faculty level of effort dedicated to the project is
compatible with the unit's needs, and that any cost-sharing commitment is
both possible and suitable. The college dean or regional campus dean shall
review the proposed project to ascertain to what degree the project commits the
college to long-term support of project personnel or program support beyond the
award period.
(6) Budget. Sponsored
programs staff shall determine the cost of a sponsored project in accord with
principal investigator/project director needs and external sponsor program
guidelines. The proposed project's budget shall include allowable direct
costs, facilities and administrative costs, and, as needed, the appropriate,
sponsor required university cost share whose source and amount has been
approved by responsible chair, director, regional campus dean, or vice
president.
(7) Cost sharing shall
become part of a proposed project's budget when required by the external
sponsor and only when authorized by the appropriate university official
representing the unit providing the cost share. Cost sharing on one project
precludes its use on another project. Sponsored programs shall ascertain that
costs requested from an external sponsor as well as university cost sharing
meet the cost principles (OMB A-21) of allowability, allocability,
reasonableness, and consistency (with university financial practices). The
university assumes the position that voluntary (not required by the external
sponsor) cost sharing shall not ordinarily be offered, and that the
university's negotiated facilities and administrative rate, an essential
sponsored project cost, shall not be waived. When Kent state university project
costs include subrecipient costs, in order to incorporate such costs into the
Kent state university proposed budget, sponsored programs must receive adequate
documentation from the subrecipient prior to proposal submission.
(8) Research projects
involving use of human subjects must be reviewed by the university's
institutional review board (IRB) prior to proposal submission or within thirty
days after proposal submission if allowed by external sponsor guidelines (see
rule 3342-3-03.2 of this Administrative Code). A project's human subjects
must be protected in accord with federal regulations. A project that does not
comply may not be conducted.
(9) Live vertebrate
animals. Research projects involving use of live vertebrate animals must be
reviewed by the university's institutional animal care and use committee
(IACUC, as provided for in rule 3342-3-03.3 of the Administrative Code). No
project involving animals may begin without approval by and adherence to
recommendations by IACUC.
(10) Hazardous materials.
Research projects involving use of high hazard chemicals, recombinant DNA,
bio-hazardous materials, radioactive materials, or select agents/toxins must
receive approval from the manager, research safety and compliance in research
and sponsored programs. No project may begin without such approval.
(11) Export controls. The
conduct of research projects involving export-controlled data must be approved
by sponsored programs in concert with university legal counsel, with the aim of
maintaining university exemption from export control restrictions based upon
the university's position that it is (under "National Security
Decision Directive 189") a fundamental research institution with
publication rights which the university shall not waive. In such cases where
export controlled information is a consideration, the university shall, as
necessary, implement its master technology control plan accompanied by the
annex appropriate to the specific project in question. Each project involving
export-controlled information will comply with its specific annex.
(12) The university shall
maintain its publication rights in all sponsored projects. The university shall
not accept awards or enter into agreements for the support of research that
permits another party the power to prohibit publication of or dissemination in
any form of results of the sponsored research activities. The university shall
permit short delays (thirty to sixty days) of publication or dissemination of
results in order for sponsor review, not sponsor approval, in order for
sponsors to remove inadvertently included, sponsor-provided proprietary
information or for sponsors to seek patent applications; in such cases, these
delay conditions will be specified in the initial grant/contract award.
(13) Classified research.
At times, a government agency or an industry has need to contract with the
university for a research project under conditions that do not permit free
inquiry and disclosure of results. Such research is "classified
research." Contracts for classified research may be considered on a
case-by-case basis. The general purpose and method of such research shall be
disclosed to pertinent faculty and administrators so that they can judge the
appropriateness of the research and its contribution to human knowledge and
well being. The funding agency shall not influence the selection or promotion
of faculty members or the formulation of university academic policy. The
study's results and conclusion shall be available for open discussion
and/or publication after a reasonable period of time. To ensure adherence to
these policies, faculty members shall submit any proposal responding to an
external sponsor request involving classified research to the vice president of
research and sponsored programs for review and consideration. The vice
president of research and sponsored programs may consult with the university
research council. The principal investigator or the granting agency may appeal
the decision of the vice president to the provost. In order to facilitate the
conduct of federal classified grants or contracts, the university shall
continue to hold a "facility clearance." This involves providing the
physical means to protect security data, perhaps requiring personal security
clearance of certain university officers and other employees.
(14) Gifts. A
solicitation for a gift (a donation that has no requirements attached and is
not work for hire) is submitted through the office of institutional advancement
and foundation. The office of institutional advancement and foundation is also
responsible for submission of other proposed projects in such cases where the
agencies/foundations require submission by that office. In these latter cases,
sponsored programs shall assist the office of institutional advancement and
foundation with accurate proposal budget development.
(15) Approving
department. A proposal to an external sponsor is subject to approval of the
department in which the sponsored project will reside. The proposal may be
submitted only if the proposed project does not unduly disrupt the established
research and teaching programs of the university and department, that is, if
teaching obligations can be met or rearranged as needed; if appropriate space,
equipment, and facilities can be made available to the project; and, if the
university can provide for continuation of support for a project's new
positions if required.
(D) Implementation: proposal preparation
and submission.
(1) Individual
faculty/staff members prepare proposals in accord with external sponsor
guidelines.
(2) Sponsored programs
staff shall review the proposal and provide project proposal support including
but not limited to the following services:
(a) Sponsored programs staff shall review the proposal for
adherence to university policy and sponsor regulations.
(b) Sponsored programs staff shall assist with development
of the budget, ensuring its adequacy for the proposed work, allowability (meets
cost principles as delineated in OMB A-21 and external sponsor cost
requirements), and consistency with university financial procedures; and shall
ascertain that the university is not cost sharing unnecessarily or unduly.
(c) Sponsored programs staff shall review the level of
effort committed and the indicated current and pending support.
(d) Sponsored programs staff shall ensure that the
principal investigator/project director follows university-required procedures
(involving as necessary the institutional review board, the institutional
animal care and use committee, the manager, research safety and compliance,
university legal counsel) when human subjects, animals, export controlled data,
high hazard chemicals, recombinant DNA, bio hazardous materials, radioactive
materials, select agents/toxins, or new use of space (obtaining approval from
the relevant university official) are involved in the project's conduct.
(3) Sub-recipient
institution. When a sub-recipient institution serves as a partner in the
university's proposed project, sponsored programs staff shall coordinate
the proposal submission with the subrecipient. Sponsored programs staff shall
obtain, prior to submission of the proposal, the necessary subrecipient
documents. This documentation shall be in the form of a letter of commitment to
the project, an officially authorized budget for subrecipient costs and cost
sharing if applicable, the sub-recipient's statement of work
substantiating what that institution will do for its proposed costs, and
verification of the sub-recipient's facilities and administrative rate.
(4) AOR authorization.
Every proposal must be authorized by the AOR for submission and submitted by
sponsored programs staff to the external sponsor.
(5) Endorsement. Prior to
its submission to an external sponsor, the proposal must be approved
electronically through Coeus by the appropriate chair/director and dean or
regional campus dean. In reviewing the proposed project, the chair/director,
dean or regional campus dean and executive dean for regional campuses must
ascertain that the proposed project is consistent with the goals of the
department, college, school, or regional campus, that the faculty level of
effort dedicated to the project is compatible with the unit's needs, and
that any cost sharing commitment is both possible and suitable. The college
dean or regional campus dean shall review the proposed project to ascertain to
what degree the project commits the college to long-term support of project
personnel or program support beyond the award period.
(6) Conflict of interest.
Prior to its submission to an external sponsor, all potential conflicts of
interest must be disclosed (see rules 3342-3-07 and 3342-3-07.1 of the
Administrative Code) by the project's key personnel (those who have a role
in the design, conduct, or reporting of the project). Each investigator must
complete the "investigator certification" in Coeus, which
incorporates the financial conflict of interest screening form questions, while
key personnel must complete the financial conflict of interest screening form.
(7) Time for submission.
Sufficient time shall be allowed for sponsored programs to process the proposed
project. University principal investigators/project directors submitting
proposals must follow the established timelines to ensure efficiency,
expediency, and quality of the proposal process.
(a) Sponsored programs should be notified of intention to
submit a proposal at least ten working days before the submission deadline.
(b) A complete proposal with the final budget must be
entered into Coeus and routed for internal approval no later than five working
days prior to the due date.
(c) If narrative proposal documents will be revised after
submission for internal approval, all files must be finalized in Coeus no later
than two working days before the due date of the proposal to the external
agency or source.
(E) Procedures: Grant/contract
acceptance, initiation, and administration.
(1) The grant or contract
award to Kent state university is issued as a document that must be reviewed by
sponsored programs staff, often in concert with university legal counsel; prior
to acceptance, unacceptable clauses are modified or struck from the agreement.
Acceptance is evidenced by the AOR's signature on the award agreement
document. The university does not make funds available to the principal
investigator/project director until he/she has met all compliance requirements
(e.g., financial conflict of interest, IRB, IACUC).
(2) When an award to the
university includes subrecipient collaboration, the university shall issue the
subaward agreement that includes the external sponsor's award terms and
conditions. The subaward agreement will require the subrecipient's
certification of compliance with federal regulations and/or other external
sponsor requirements. The agreement is then executed between Kent state
university and the subrecipient. Ongoing monitoring of subrecipient technical
performance is documented by the principal investigator/project director and of
administrative requirements by sponsored programs and grants
accounting.
(3) In the administration
of grant or contract awards, sponsored programs shall abide by: The award
instrument issued by the particular funding agency; OMB circulars A-21, A-133,
A-l 10; Other federal regulations; and university policies.
(4) When an external
sponsor selects a proposal for an award, the sponsor commonly requests
additional budgetary or technical information. Such budgetary information may
be provided only by sponsored programs staff.
(5) Any award negotiation
that takes place between Kent state university and an external sponsor must be
conducted by sponsored programs. If an external sponsor contacts a principal
investigator/project director directly, he/she shall advise sponsored programs.
Prior to finalizing negotiations, sponsored programs staff shall work with the
principal investigator/project director to ensure that his/her needs are met
and that the university is protected. Sponsored projects are subject to
facilities and administrative costs (F&A) at the university's current
federally-approved F&A cost rate agreement applicable to the type of
project being conducted. If the sponsor has a published policy, uniformly
applied, prohibiting or restricting the payment of F&A costs, the
university may accept the reduced F&A rate in accordance with the
sponsor's policy. This does not apply to for-profit sponsors that are
expected to provide full F&A recovery.
(6) The principal
investigator/project director shall operate within university policy and
external sponsor requirements and shall be responsible for day-to-day direction
and financial and administrative management of his/her awarded project.
Sponsored programs staff shall guide the principal investigator/project
director in the interpretation of university policy and external sponsor
requirements. University policy and external sponsor terms and conditions shall
be followed for all sponsored program activities including but not limited to
travel, equipment acquisition, employment and committed effort of personnel,
participation of human participants, and/or use of animals. The principal
investigator/project director shall fulfill the requirement for review and
certification of salaries, assuring that salaries charged to sponsored projects
correspond to effort expended on those projects.
(7) Equipment as defined
by the university that is purchased with grant/contract funds shall be subject
to university equipment inventory control procedures regardless of whether
title vests in the university or the funding agency. The principal
investigator/project director shall be responsible for such equipment, shall
purchase the equipment in due time (well before an award end date), and shall
account for all items periodically as well as at the project's end.
Retention and disposal of equipment at project termination falls into three
categories: (a) equipment purchased by the university with university funds
(deemed to be cost share) remains in the department, school, or regional campus
of the principal investigator/project director and cannot be removed from the
university by a resigning principal investigator/project director; (b) special
purpose equipment purchased by the university with grant or contract funds with
title vested in the university by a sponsor remains in the principal
investigator/project director's department, school, or regional campus and
may be transferred with the approval of the appropriate chair/director/regional
campus dean to a principal investigator/project director's new institution
upon his/her resignation, only if the department/school/regional campus has no
use for the equipment (final approval for transfer rests with the provost or
his/her designee; and (c) equipment purchased with grant/contract funds that
remains vested with the external sponsor shall be tagged appropriately to
identify the sponsor and grant/contract number and shall be disposed of in
accord with external sponsor instructions and as coordinated between the
controller's office and sponsored programs.
(8) Kent state university
considers that cost sharing included in proposal budgets and accepted by the
sponsoring agency is an award condition and university obligation. Cost sharing
is subject to audit; the external sponsor will require repayment of a portion
of grant funds if the proposed cost sharing is not obtained/documented and
could terminate an active award. Cost sharing obligations, including both
mandatory and voluntary-committed investigator effort, are appropriately
recorded by project in the university's accounting records and
substantiated by documentation (e.g., effort certification, vendor letters
stating equipment value). Cost sharing is monitored for timeliness and adequacy
as well as for allowability, allocability, reasonableness, and consistency with
other university charging procedures. Cost sharing expenditures like
expenditures subsidized by the grant/contract award must comply with federal
cost principles and sponsor award terms and conditions. Where cost sharing is a
requirement of a university-issued subaward, the cost sharing commitment that
the university requires from the subrecipient is included in the
university-issued subaward document. The subrecipient's compliance with
the required cost sharing commitment is then monitored by both the principal
investigator/project director and grants accounting and appropriately reported
to the external sponsor.
(9) Throughout an
externally funded project's course, the principal investigator/project
director shall inform his/her chair/director, or regional campus dean as well
as sponsored programs staff if there is or will be (a) any deviation from the
project's sponsor-approved scope of work, budget, and/or level of
personnel effort; or (b) any other change necessitating external sponsor
approval. Sponsored programs staff should be informed about any such proposed
deviations prior to discussions that might occur between the principal
investigator/project director and the external sponsor. The principal
investigator/project director shall not communicate directly with the external
sponsor about such deviations without approval from sponsored programs.
(10) A separate
university-restricted index with its own number shall be established for each
externally sponsored project. All project-related expenditures shall be charged
directly to this index. All expenditures must occur during the period of the
grant/contract award. Principal investigators/project directors shall be
responsible for reviewing the project expenditures (as documented in the
university system-generated reports) on a monthly basis, correcting any errors,
and staying within the sponsored programs-approved budget. Costs allocable to a
particular sponsored agreement may not be shifted to other sponsored agreements
in order to meet deficiencies caused by overruns or other fund considerations,
or to avoid restrictions imposed by law, by terms of the sponsored agreement,
or for other reasons of convenience.
(11) Costs allocable to
activities sponsored by industry, foreign governments or other sponsors may not
be shifted to federally sponsored agreements. If a cost transfer is made due to
discovery of an error, the transfer must be supported by documentation that
fully explains how the error occurred and a certification of the correctness of
the new charge. sponsored programs staff must approve any cost transfer that
exceeds ninety days from the original erroneous charge.
(12) External sponsors
and Kent state university expect principal investigators/project directors to
manage the funded grant/contract project both within the sponsor-approved
budget and project period. Unanticipated developments can, however, necessitate
modification of the budget, scope of work, personnel effort, project period,
or, in some cases, all of these. Principal investigators/project directors who
need a modification must submit the request to sponsored programs for approval.
The university has established procedures to implement the federal expanded
authorities and documents actions taken under such federal expanded
authorities. Exercising this authority, the university's AOR is able to
approve certain budget and time frame modifications, to include pre-award
costs, expeditiously without contacting the funding agency. When required, the
university seeks external sponsor prior approval for modifications and
maintains records of the approvals granted.
(13) As recipients of
external funds, principal investigators/project directors must exercise
appropriate responsibility in reporting performance on the funded project to
the sponsor. Technical progress (e.g., quarterly, annual) and final reports
shall be submitted by the principal investigator/project director to the
external sponsor as required and in timely fashion. The principal
investigator/project director shall provide a copy of any submitted report (to
include electronic reports) to sponsored programs. At the project period's
end, the project work ceases; after the termination date, no additional
expenditures may be charged to the grant/contract index. A period of thirty to
ninety days is usually allowed to pay previously committed financial
obligations prior to grant accounting's preparation of the final financial
report based on expenditures recorded in the grant index. Grants accounting
shall certify the accuracy of the final fiscal report to the external sponsor.
Final technical reports, invention disclosure reports, subrecipient reports
(property, patent, technical, and fiscal) if applicable, and other reports as
required by the external sponsor shall be submitted by sponsored programs to
the external sponsor (the principal investigator/project director may have
submitted the final technical report as required). The university shall not pay
the subrecipient's final invoice until the reports and deliverables
required from the subrecipient have been received and accepted. The principal
investigator/project director shall certify that the subrecipient has
adequately completed the technical aspects of the work. Upon acceptance of
these closeout reports, grants accounting shall close the index.
(14) Considered an
integral part of a department/center/institute, school, or regional campus
program and resources base, grant/contracts/other sponsored agreements must be
monitored not only by the principal investigator/project director but also by
the chair, director, and college dean or by the regional campus dean. Project
over-expenditures and audit disallowances are, ultimately the responsibility
and burden of the home department/center/institute, school, or regional campus.
(15) Records of sponsored
project activities (financial and programmatic records, supporting documents,
statistical records, lab books, records for real property and equipment) shall
be retained for the active years plus five years.