Sponsored funding rose 10% in a challenging year: The DORED annual report on research and economic development for Fiscal Year 2013.
Policies and Procedures: Sponsored programs
- Research proposal submission (DORED – SP – 1 – 081513)
Including proposals, pre-proposals, white papers, agency notices of intent, and agency letters of intent
- Award processing (DORED – SP – 2 – 081513)
- Responsibilities of the principal investigator (DORED – SP – 3 – 081513)
- Responsibilities of the department chair (DORED – SP – 4 – 081513)
- Responsibilities of the dean (DORED – SP – 5 – 081513)
- Start-up meeting (DORED – SP – 6 – 081513)
- Principal investigator eligibility (DORED – SP – 7 – 081513)
- Budget revisions (DORED – SP – 8 – 081513)
- Closeout (DORED – SP – 9 – 081513)
- Contract types (DORED – SP – 10 – 081513)
- Cost sharing (DORED – SP – 11 – 081513)
- Employee termination clearance (DORED – SP – 12 – 081513)
- Equipment grants (DORED – SP – 13 – 081513)
- Equipment leases and purchases (DORED – SP – 14 – 081513)
- Hiring consultants (DORED – SP – 15 – 081513)
- Industry contractual issues (DORED – SP – 16 – 081513)
- Letters of support (DORED – SP – 17 – 081513)
- Modification (incremental funding) of an award (DORED – SP – 18 – 081513)
- Overhead determination and negotiation (DORED – SP – 19 – 081513)
- Property management (DORED – SP – 20 – 081513)
- Proposal identification number (DORED – SP – 21 – 081513)
- Project files in RAMSeS (DORED – SP – 22 – 081513)
- Records retention in RAMSeS (DORED – SP – 23 – 081513)
- Report of invention to the federal government (DORED – SP – 24 – 081513)
- Request for a budget revision (DORED – SP – 25 – 081513)
- Request to change principal investigator (DORED – SP – 26 – 081513)
- Request for foreign travel (DORED – SP – 27 – 081513)
- Request to purchase additional equipment (DORED – SP – 28 – 081513)
- Request for a residual account (DORED – SP – 29 – 081513)
- Request to submit funding for a subcontractor (DORED – SP – 30 – 081513)
- Request to transfer an award/project (DORED – SP – 31 – 081513)
- Requesting contingency funds (DORED – SP – 32 – 081513)
- Requesting a no-cost extension on an award (DORED – SP – 33 – 081513)
- Restrictive disclosure agreements (DORED – SP – 34 – 081513)
- Screening industrial sponsors for business risk (DORED – SP – 35 – 081513)
- Unofficial proposals (DORED – SP – 36 – 081513)
- Waiver of overhead (DORED – SP – 37 – 081513)
- Non-funded cooperative agreements (DORED – SP – 38 – 081513)
Research proposal submission (DORED – SP – 1 – 081513)
Including proposals, pre-proposals, white papers, agency notices of intent, and agency letters of intent
Only the Division of Research & Economic Development can submit research and research-related proposals on behalf of the University. As such, all research and research-related proposals to foundations, government agencies, public and private entities must be submitted through DORED. Sufficient time must be allotted for the vice chancellor and DORED staff to review and approve the proposal. Therefore, all research and research-related proposals should be submitted to DORED three days prior to the closing date of the solicitation.
All research proposals must be approved by the departmental chair and dean of the school/college prior to DORED submitting the proposal on behalf of the University. Such approvals are made through the University’s Research Administration Management System and eSubmission database system (RAMSeS). Any proposal submitted to any entity outside of these procedures will not be considered an official proposal on behalf of the University and as such imposes no responsibilities or encumbrances on the University.
All proposals must be accompanied by a copy of the sponsor’s announcement, solicitation, RFP, RFQ, or guideline document that specifies what the requirements are for the proposal. This is to give Sponsored Programs the required information to review the proposal for compliance with University and sponsor requirements.
If the proposal requires submission via email or U.S. mail, contact information must be included in RAMSeS.
Award processing (DORED – SP – 2 – 081513)
Internal processing procedures ensure compliance with federal and state laws and UNC policies. They also clarify submission procedures and processing of awards for external sponsored program funds, and they ensure a uniform administrative process among the constituent UNC institutions. The guidelines provided here comply with the University of North Carolina General Administration (UNC-GA) Policy Manual Chapter 500 – Sponsored Programs, Research, and Intellectual Property.
UNC-GA requires that:
- Sponsored programs be conducted and funds used in a manner consistent with federal and state laws and University policies,
- Sponsored programs funds reside in designated University accounts,
- A statement of work and a budget exist that explain the purpose and use of each sponsored program’s funds, and
- Only those with delegated authority enter into agreements that commit the university to provide for the delivery of goods or services.
The principal investigator/project director will:
- Receive notification from the Office of Sponsored Programs (OSP) of the receipt of the award;
- Review the award document and inform the OSP of any questions or concerns;
- Determine acceptance of the award;
This involves reading the terms and conditions, preparing the Budget Create Form in accordance with the agency-approved budget, and returning the budget form to OSP (please contact OSP if budget assistance is required).
- Set the date for the start-up conference;
- Discuss any award issues with the Grant Administrator (GA);
- Discuss the financial management of the award with the assigned university accountant ;
- Monitor expenses to be sure charges do not exceed project award; and
- Submit all incremental/progress and final reports to the sponsor and forward copies to GA assigned to the project.
The grant administrator will:
- Notify the PI of receipt of the award and request the Budget Create form from the PI;
- Enter the award information into RAMSeS and select the award status as Funded/Anticipated (which puts the award in the Anticipated category);
- Upon receiving the Budget Create from the PI, review and approve before attaching the form in RAMSeS and change the award status to Obligated (which puts the award into the Awaiting distribution for disposition category by Contracts and Grants and allows the assignment of an account number);
- Provide the Award Packet to Contracts and Grants and PI; and
- Work with the PI through the life of the project.
The grant administrator also will check RAMSeS to ensure these documents are attached:
- Award agreement,
- Composite profile with account number,
- Budget create form,
- Approved budget (may be attached to award or proposal),
- Award review sheet,
- Compliance approvals (if applicable),
- IP approvals (if applicable),
- University employee cost-sharing form (if applicable),
- Faculty release form (if applicable), and
- Other guidance documents (if applicable).
Responsibilities of the principal investigator (DORED – SP – 3 – 081513)
Sponsored projects administration is a joint effort between the principal investigator/project director (PI/PD) and the University. The PI/PD is held accountable for the proposal fiscal management and conduct of the project. The University is held legally and financially responsible and accountable to the sponsor for the performance of the activity funded and the proper use of funds, but without the full cooperation and oversight of the PI/PD, the University would be unable to fulfill its stewardship role.
The PI/PD is responsible to the University and to the sponsor for assuring that the scope of work for which the award was made is completed, that University policies and procedures are adhered to, and that funds are expended in accordance with the awarded budget and sponsor terms and conditions. This can best be accomplished by having periodic meetings with the grant administrator from the Office of Sponsored Programs and the grant accountant from the Office of Contracts and Grants to provide them with project status and to ascertain expenditure compliance.
While the PI/PD may delegate some responsibility for day-to-day management of finances or other tasks to departmental and school business staff, the PI/PD remains accountable for compliance with University policy and sponsor requirements.
Responsibilities of the department chair (DORED – SP – 4 – 081513)
The department chair’s approval is required for a proposal to move forward in RAMSeS. This authorization constitutes an endorsement attesting to the academic purposes of the proposed research or other sponsored activity, its departmental compatibility, and its appropriateness in the context of the budget, the time available to the faculty member to carry out the project, and the availability of space and research equipment.
The department chair verifies, by authorizing in RAMSeS, that he/she has assessed the adequacy of the budget, how it will impact departmental finances, and any space or cost sharing requirements. This authorization also indicates approval of certain expenses or actions related to the program, such as stipend payments, tuition, and new hires, and indicates his or her acceptance of financial responsibility for the department for any eventual overruns and/or cost disallowances. Where possible, the department chair provides departmental assistance in preparing and submitting appropriate documentation for financial and other administrative transactions.
The chair verifies, by authorizing in RAMSeS, that any request for additional staff lines has been approved by the dean.
If the research involves investigators from more than one department or unit, one department is selected to administer the award (admin department), but each department or unit still must provide approval for the use of space, personnel, and/or equipment to be used on a particular project.
The chair checks expenditures of funded grants and/or contracts on a periodic basis and, when student assistants are hired, will ensure that the regulations regarding nepotism are followed both literally and in spirit.
Responsibilities of the dean (DORED – SP – 5 – 081513)
The dean reviews the proposal to verify that the faculty member is eligible to be a principal investigator and can effectively manage and properly conduct the proposed program. The dean also reviews budgets, gives official approval to any cost-sharing commitments or provisions for additional resources, and confirms that proposals and programs are in accordance with department/school objectives. The dean will accept financial responsibility for any eventual overruns and/or cost disallowances.
In addition, the dean will:
- Read the guidelines and follow terms and conditions;
- Maintain consistent communication with the agency technical contact;
- Follow all instructions;
- Be familiar with University policies, rules, and processes;
- Know the key players and their roles in Purchasing, HR, etc.;
- Obtain institutional approvals for research compliance if necessary;
- Ensure that costs are related to the project that they benefit; and
- Ensure that costs are reasonable (would a “prudent person” find these costs to be reasonable?).
Start-up meeting (DORED – SP – 6 – 081513)
When the grant administrator (GA) has received the account number from Contracts and Grants, the GA will schedule the start-up meeting and complete the Grant Management Checklist and the Cost Sharing Certification forms, if applicable, which will be signed by all meeting attendees. The start-up meeting is held to ensure that the principal investigator/project director (PI/PD) and all responsible parties are familiar with their responsibilities as outlined in the proposal and award documentation, the terms and conditions of the award, the budget, the period of performance, and the technical and financial reporting requirements. Attendance of PI/PD, grant administrator and grant accountant is mandatory. The Grant Management Checklist and the Cost Sharing Certification must be signed by all attendees. The GA will post copies of these signed documents in RAMSeS and provide signed copies to all attendees.
Principal investigator eligibility (DORED – SP – 7 – 081513)
All tenure-track faculty members may submit proposals for support of research and scholarly projects. All proposals must be approved by the faculty member’s unit or department head and dean before submission to the vice chancellor for research & economic development for final campus approval. Non-tenure-track faculty members, employees, and postdoctoral fellows with termed appointments may submit proposals with prior approval from their dean and the Vice Chancellor for Research & Economic Development.
Before outside research support is accepted, each member of the faculty and research staff is responsible for making provisions acceptable to the department chair to sustain his or her University commitments. Once a member of the faculty or research staff accepts outside sponsorship of a project that will be of benefit to the University, he or she has an obligation to complete the project in a timely manner, including any obligation to file reports as called for by the sponsored research agreement.
Copies of all reports or electronic deliverable files should be sent to DORED at the time of submission to the funding agency.
Budget revisions (DORED – SP – 8 – 081513)
There is considerable variation in sponsor policies on budget revisions. Accordingly, award terms and/or guidelines must be consulted when revisions are contemplated. To the extent possible, budget revisions should reflect all necessary reallocations of resources that are foreseen through the end of the budget period. Requests for budget revisions are submitted to DORED on a Request for Budget Allotment Form.
If prior agency approval is required for a budget revision, a request letter, prepared by the principal investigator, detailing the revision and justification should be addressed to the agency administrator or program officer as designated in the award. This letter must be submitted to DORED for review and submission. Upon approval by the agency, the budget revision will be initiated by the grant administrator.
Budget requests not requiring agency approval are reviewed and processed by the grant accountants.
Closeout (DORED – SP – 9 – 081513)
Project closeout is an administrative process that is handled by DORED. A pre-closeout review is conducted to verify the project's status. DORED issues a Notice of Project Closeout and a Patent and Subcontract Questionnaire when applicable. The notice of project closeout indicates the required closeout actions have been distributed to the project director/principal investigator, administrative network representative, Office of Contracts and Grants, property management office, and others as appropriate. The requirements for project closeout are established by contractual provision and/or agency regulations. DORED monitors the submission of closing documents by recording the date items are received. When all closing actions are completed, the project history becomes the permanent record of the project and is entered into RAMSES.
Contract types (DORED – SP – 10 – 081513)
DORED uses several types of contract documents in agreements for sponsored research. These range from the standard industrial agreement, which, with the exception of rights to intellectual property, basically offers to industry the same contractual arrangements as DORED receives from the federal government, to agreements that allow an industrial sponsor to purchase rights to intellectual property developed during the research.
The common themes in these agreements are that:
- The University’s costs must be reimbursed,
- No legal or financial liability is imposed on the University, and
- The University has the right to retain or release intellectual property that it develops during research.
The proper mechanism for this relationship is a cost-reimbursement contract. Infrequently, an industry sponsor will insist on a fixed-price contract. Such contracts may be accepted with the approval of the vice chancellor for research and economic development if DORED determines that the financial/legal risks are acceptable or minimal, the researcher’s department identifies the funds to be used in the event of an overrun, and the deliverables do not include hardware or software.
“Time and Materials” contracts require fixed labor rates that include all overhead and other costs. These contracts cannot be accommodated by our accounting systems without handling them “off-line” manually. This type of contract is not appropriate for an educational institution operating under OMB Circular A-21 Cost Principles. Such contracts must be reviewed by the Division of Research & Economic Development and the University attorney.
Other contracts include:
- Beta Test
All contracts are reviewed and negotiated by the associate vice chancellor for research administration and signed by the vice chancellor for research.
Cost sharing (DORED – SP – 11 – 081513)
The University discourages cost sharing and cost matching unless they are required in the sponsor solicitation. Whenever cost sharing is proposed, the source of funds must be identified and approval obtained from the person with authority over those funds. Cost sharing must be approved at the proposal stage by the chair, dean, and vice chancellor for research & economic development. These approvals are obtained via the Cost Sharing Form. All outstanding cost sharing commitments are tracked by the Office of Contracts and Grants.
Upon receipt of the award, the Division of Research & Economic Development obtains a project account number and in some cases a cost sharing account number from Contracts and Grants. This opens chargeable accounts for the principal investigator/project director (PI/PD). The project account will be valued at the amount of the award, and the cost sharing account will be valued at the amount of the cost sharing required by the sponsoring agency and obligated by the chair, dean and vice chancellor.
The PI/PD will provide a signed and completed copy of the cost sharing form to DORED, which will be uploaded into RAMSeS.
The Office of Contracts and Grants inputs the budget for the sponsored account and in some cases inputs a cost sharing account into BANNER and then awaits the monthly charges from the PD/PI to be identified. If the PD/PI does not identify charges to be applied to the cost sharing account by the end of the project period, the Contracts and Grants will request that the cost sharing be satisfied in order for the project to be closed out.
Employee termination clearance (DORED – SP – 12 – 081513)
The Division of Research & Economic Development is responsible for certifying that terminated N.C. A&T employees have completed the requirements of all agency research projects, as appropriate. This certification is a condition for issuance of the terminating employee's final paycheck.
If the employee is listed as principal investigator/project director (PI/PD) of an active project, accountability must be reassigned by the school’s chair and approved by the dean. A memorandum should be sent to the DORED naming the succeeding PI/PD.
If the employee is listed as PD/PI of a project in closeout status, all outstanding deliverables must be resolved before DORED will sign off on the clearance form. The PD/PI must provide evidence that deliverables have been submitted, that they are no longer required by the sponsor, or that another PI/PD has assumed responsibility for all outstanding deliverables.
Equipment grants (DORED – SP – 13 – 081513)
Equipment grants and awards will be processed through the Office of Sponsored Programs (OSP) and the Division of Research & Economic Development (DORED) but will not require a Banner number from the Office of Contracts and Grants when no money is provided from the sponsor.
Whether or not there is a solicitation for the award, the principal investigator will need to enter the information into RAMSeS to generate a proposal number and obtain the electronic approvals from the chair and dean.
When the equipment grant is awarded and the award document states that the sponsor will purchase the equipment and pay for installation, with the University incurring no expenses for the award nor receiving funds to purchase the equipment, there should be no request for a grant number from Contracts and Grants.
In the Project Number field for the Award and Project Modules in RAMSeS, the grant administrator should enter: X-EQUIP for equipment or X-SOFTW for software.
Since there is no budget breakout, enter only the total value of the equipment on the equipment line and the total line in the Project Module.
Equipment leases and purchases (DORED – SP – 14 – 081513)
Equipment is an article of capital nature, complete in itself, which does not lose its identity, has a useful life of more than one year, and an acquisition cost of $5,000 or more per unit. Special purpose equipment is equipment used exclusively for research, medical, scientific, or other technical activities. General purpose equipment is equipment not limited to research, medical, scientific or other technical activities.
- Expenditures for general purpose equipment are unallowable as direct charges, except as approved in advance by the sponsoring agency.
- Expenditures for special purpose equipment are allowable as direct charges, provided the acquisition of items having a unit cost of $5,000 or more are approved in advance by the sponsoring agency.
- Expenditures for improvements to equipment that materially increase their value or useful life are unallowable as direct charges, except where approved in advance by the sponsoring agency.
Rental or lease costs of equipment are allowable, provided the costs are reasonable as defined in Office of Management and Budget (OMB) Circular A-21. Where significant rental costs are incurred under leases, which create a material equity in the leased property, they are allowable only up to the amount that would be allowed if the property were purchased on the date the lease agreement was executed.
Equipment lease costs are burdensome and therefore a part of the Modified Total Direct Costs (MTDC) base. All purchased equipment, whether deliverable or not, is excluded from overhead.
Hiring consultants (DORED – SP – 15 – 081513)
The Purchasing Department is responsible for hiring all consultants. The consulting agreement will be prepared by the Purchasing Department. The principal investigator (PI) must submit a statement of work, budget, vita of the individual performing the service, and letter from consultant accepting the statement of work. Upon receipt of a fully executed agreement, a vendor-create form is completed by the PI and sent to the Division of Research & Economic Development attached to the consultant agreement. The consultant agreement package is forwarded to the Office of Contracts and Grant. A consultant file number is coded by the active account number assigned by Contracts and Grants and uploaded into RAMSeS by the Division of Research & Economic Development.
Industry contractual issues (DORED – SP – 16 – 081513)
Contractual issues that are standard in our dealings with the government become points of negotiation when dealing with industry. The following terms are among the most commonly addressed issues in accepting subcontracts from other universities and companies.
Legal and financial liability
State law prohibits the obligation of unappropriated state funds or the state's credit. Contract clauses involving such liabilities cannot be accepted. Three prime examples are:
- Termination for default: If the sponsor determines that the University has not performed satisfactorily, this clause would allow the sponsor to hire another contractor to complete the work and require the University to pay any additional expenses. The University cannot accept these provisions. This is non-negotiable.
- Indemnify/defend/hold harmless: Provides for the University to assume the legal responsibility for any loss incurred by the sponsor in connection with the contract or the sponsor's use of the deliverable. The University cannot accept such provisions. This is non-negotiable.
- Warranty/guarantee: N.C. A&T cannot accept such clauses. This is non-negotiable.
Laws of the State of North Carolina will govern all agreements, or they will be considered null and void. This is non-negotiable.
Cost reimbursement vs. fixed price
Fixed-price contracts require the University to expend whatever is required to complete the program no matter how much it exceeds the contract funding. If a sponsor requires a fixed-price contract and the academic department requests the Division of Research & Economic Development to accept such potential financial liability, the department must identify the source of funds that will be committed to pay cost overruns in the event they occur. The University is particularly reluctant to accept a fixed-price contract where hardware and/or software are to be delivered, simply because the associated risk is very high.
Ownership of intellectual property
All government agencies funding sponsored programs convey title to intellectual property to the University.
If a private funder requires intellectual property rights or restricts publications, an appropriate fee, based on the potential commercial value of the technology, is usually charged. The University’s Technology Transfer Office must be involved in the decision to release or sell the intellectual property rights and/or restrict publications since acceptance of such provisions could compromise any intellectual property rights and seriously affect the ongoing research of the University.
- Note: These issues deal with contracting with industry when the company's internal funds are being used to pay for the University’s services. When the University is a subcontractor to an industrial organization under a prime contract with the government, any of the issues above and up to 50 Federal Acquisition Regulations clauses can be involved. Industry usually attempts to "flow-down" their prime contract obligations to the University. The Division of Research & Economic Development and Economic Development must convince the industrial and government contracting personnel to utilize the appropriate clauses written specifically for non-profit educational institutions.
Letters of support (DORED – SP – 17 – 081513)
Unless specifically designated in the entity solicitation, all letters of support will be provided and signed by either Vice Chancellor for Research & Economic Development or the dean of principal investigator’s school or college. Requests for letters of support should be submitted to the associate vice chancellor for research administration. For proposals requiring or requesting a letter of support from the chancellor or the provost, the request must be made to DORED one week before the closing date for the solicitation. DORED will forward a draft letter to the chancellor or provost. The letter of support will be completed and returned to DORED for processing with the proposal.
Modification (incremental funding) of an award (DORED – SP – 18 – 081513)
The guidelines for requesting a modification to an award are normally provided in the federal agency guidelines. If the award is with the state or a private agency the terms are normally stated in the award document. In the absence of guidelines, DORED will provide guidelines.
Incremental funding is issued through the funding agency as a modification to the original award. The modification must be reviewed by DORED to validate funding level increases and period of performance before the release of the additional funding.
Modification may be used to change the statement of work, change in principal investigator (PI), any federal administrative changes, de-obligation of funding, or any transaction that has to be documented as an action to the award. The procedure for administering the modification must follow federal guidelines to insure the appropriate representatives authorize the change order.
- The director of sponsored programs receives modification requests to increase the funding limitation. He or she forwards the modification to the appropriate grant administrator (GA).
- The GA reviews the modification request and checks the RAMSeS database to identify the agency agreement number and the Banner number and to see whether a new proposal was submitted.
- The GA reviews the modification to the agreement. If the modification does not need to be negotiated, the request for modification is signed by ARO then sent to the agency indicating acceptance for approval.
- If the modification needs to be negotiated, the associate vice chancellor for research administration must sign the letter before it is sent to the agency. In special circumstances, the GA may need to request a Banner number from the Office of Contract & Grants. If so, Contracts & Grants logs the request and establishes a Banner number.
- When the GA receives agency approval, the GA requests a Budget Allotment Revision Form from the PI. Once it is received and approved, the GA updates the project module in RAMSeS, provides notification to the PI, and emails a copy to Contracts and Grants.
Overhead determination and negotiation (DORED – SP – 19 – 081513)
The Office of Management and Budget (OMB) Circular A-21 establishes principles for determining costs applicable to grants, contracts, and other agreements with educational institutions. These principles are designed so that the federal government pays a share of the total cost for the services provided under all grants and contracts. Before 1980, overhead rates were applied only to salaries and wages. A major revision in 1979 led to the establishment of Modified Total Direct Costs (MTDC) as the standard basis for distributing indirect costs among projects.
Direct costs are those that can be identified specifically with a particular project or that can be assigned directly to such activities with a high degree of accuracy. The MTDC are all direct costs except capital expenditures and subcontracts greater than $25,000.
Indirect costs are real costs incurred in the conduct of the research enterprise that cannot be specifically identified as benefiting any particular project. Indirect costs include depreciation or use charges on buildings and equipment, physical plant operations and maintenance, administration and general expenses, departmental administration, sponsored projects administration, library, and student administration and services. A portion of these institutional expenses are allocated to research based on the extent to which they support only the research activity. Allocations are based on space occupied, number of people involved in research activities, or on research expenditures.
The Department of Health and Human Services is the "Cognizant Federal Agency" for negotiating N.C. A&T’s overhead.
The associate vice chancellor for business and finance is responsible for the submission of all overhead rate proposals and for negotiating all overhead rates on behalf of the University.
Only the vice chancellor for research & economic development may alter or waive overhead costs. Requests for waivers must be submitted to the associate vice chancellor for research administration in writing for the vice chancellor’s approval.
Property management (DORED – SP – 20 – 081513)
Agency-owned property must be maintained in accordance with N.C. A&T property procedures and applicable federal guidelines. The University procedures outlines property tasks for which the principal investigator/project director (PI/PD) is responsible. The Division of Research & Economic Development, Division of Business and Finance, and Office of Property Management are responsible for insuring that N.C. A&T is in compliance with contractual terms and conditions relating to the acquisition and disposition of property.
Proposal identification number (DORED – SP – 21 – 081513)
The proposal identification number identifies proposals before funding is awarded. Upon receipt of the award document, either an existing or new project number is assigned by the Office of Contracts and Grants in accordance with the guidelines of the Banner system. All awards have a grant number and sometimes a fund number.
Project files in RAMSeS (DORED – SP – 22 – 081513)
Project file folders maintained by the Division of Research & Economic Development are the official files of sponsored programs. Copies of all documentation for each proposal, award, and contract are attached in RAMSeS to the Proposal Administration, Award Administration, Award Project Administration, and Subcontract Administration sections within the system.
Records retention in RAMSeS (DORED – SP – 23 – 081513)
Project files are attached in RAMSeS and can be found by proposal number, account number, award number, and/or PI name. Project files are processed according to the status of the projects.
- Active project files in RAMSeS are listed as Active.
- Closed out files in RAMSeS are listed as Inactive. These files will remain in RAMSeS.
Report of invention to the federal government (DORED – SP – 24 – 081513)
Most contracts between the University and the federal government contain Clause 52.227-11 of the Federal Acquisition Regulations, which sets forth the procedure for reporting inventions to the government. Clause 52.227-12, which has more stringent reporting requirements, may be used. The Sponsored Program Office should alert the Office of Technology Transfer when Clause 52.227-12 is used.
The Report of Inventions and Subcontracts Form, DD Form 882, must be used when reporting inventions to the Department of Defense. Other agencies may require other forms in lieu of or in addition to the DD 882.
- Note: All inventions should be reported, regardless of whether the inventor considers them patentable.
The Federal Acquisition Regulations require the University to report inventions to the sponsoring federal agency within two months of receiving a written invention disclosure from the researcher. It also requires the University, within specified time limits, to elect title to the invention and to file for U.S. and foreign patents to protect elected inventions.
The prompt written disclosure of an invention is crucial to protecting the interests of the University and the inventors. principal investigators/project directors (PI/PDs) are responsible for reporting inventions to the Office of Technology Transfer. However, there are two safeguards to assure that inventions are reported in a timely manner:
- The project initiation package includes reporting requirements for any technology developed under the project, and
- The Office of Sponsored Programs forwards a Patent Questionnaire at the closeout of the project.
The PI/PD should promptly document any possible invention on an invention disclosure form and submit it to Office of Technology Transfer. Click here for the Invention Disclosure form.
If an invention was created under a nongovernmental sponsored project, the research contract must be reviewed. The Office of Technology Transfer is responsible for reviewing the research contract and determining whether the sponsor has any proprietary interest in the invention. If the sponsor does have an interest, the Office of Technology Transfer will notify the sponsor.
Request for a budget revision (DORED – SP – 25 – 081513)
The guidelines for budget revisions are normally provided in the awarding federal agency’s guidelines. If the award is with the state or a private funder, the terms are normally stated in the award document. If there are no guidelines or regulations covering a particular situation, the Division of Research and Economic Development will be responsible for providing or obtaining the applicable guidelines. In generally the following guidelines apply.
A budget plan is the financial expression of the project or program as approved during the award process. It may include either the federal and non-federal share, or only the federal share, depending upon the federal awarding agency’s requirements. The University and the University’s sub-recipients are required to report deviations from the budget and program plans and request prior approvals for budget and program plan revision in accordance with the funding agency guidelines.
- The principal investigator (PI) contacts the grant administrator (GA) for guidance on budget revisions for the agency. The PI prepares the budget revision request letter, which includes appropriate departmental approvals. The budget revision request must be prepared by agency categories showing the increase and decrease of funds by category. The GA reviews the request for accuracy and sends it to the agency.
- If the agency denies the budget revision, the GA notifies the PI.
- If the agency approves the budget revision, a request for a budget allotment revision and a copy of the approval letter are sent to the PI. A copy of the approval letter is sent to the Office of Contracts & Grants with the budget revision. A copy of the approval letter is attached in RAMSeS.
The PI prepares a budget allotment revision and forwards it to DORED. The DORED budget manager reviews the form for accuracy.
Request to change principal investigator (DORED – SP – 26 – 081513)
Guidelines for changing the principal investigator (PI) are normally provided in the awarding agency guidelines. If the award is with the State or a private funder, the terms are normally stated in the award document. If there are no guidelines or regulations covering a particular situation, DORED will be responsible for providing or obtaining the applicable guidelines.
The University will request from the awarding agency or entity approval to change key personnel that are specified in the application or award document. Any request to change key personnel must be submitted to DORED for submission to the agency. Based on federal regulations and Office of Management and Budget Circular A-110, an authorized University official must approve the request to change key personnel. All internal procedures must be followed to assure the request meets all criteria outlined by the University and the agency. In general, the following guidelines should be considered.
- With guidance from DORED, the department chair prepares a request to change the PI. The request is signed by the chair, dean, current PI, and new PI. The request should provide the proposed new PI’s qualifications and current and pending support for research from all sources.
- DORED reviews the document and submits it to the agency.
- If the agency approves the request, a copy of the approval is sent to the PI, the Office of Contract and Grants and the department chair or dean. The original letter is uploaded into RAMSeS.
- If the agency does not approve the change, the PI is notified. The original letter is filed in the award folder. DORED will follow the instructions from the agency for the next steps.
Request for foreign travel (DORED – SP – 27 – 081513)
Guidelines for requesting foreign travel are normally provided in the awarding federal agency’s guidelines. If the award is from the state or a private funder, the terms are normally stated in the award document. If foreign travel was proposed in the original award proposal, approved requests for foreign travel must follow N.C. A&T internal processing procedures for travel. If the travel was not proposed in the original award proposal, a request for foreign travel to the funding agency is required at least 60 days before the travel date to ensure appropriate approval is obtained from the agency and N.C. A&T officials before departure. If travel is approved, N.C. A&T procedures must be followed.
Expenses for transportation, lodging, subsistence, and related items incurred by project personnel and outside consultants are generally allowable as prescribed in the agency’s governing cost principles. Written documentation to support actual costs incurred will be in accordance with agency requirements and N.C. A&T policy. Applicable travel regulations set maximum travel per diem allowances for foreign travel. Special request for rates for travel within a foreign region may be approved by the University. If the rates are approved, they must be within the federal travel rate for that particular foreign region. Written justification must accompany the request for travel. Requests must include:
- Date, time, and point of departure;
- Destination, date of return, and point of arrival;
- Name of each passenger and relationship to PI;
- Authorization for travel; and
- Purpose of travel.
The PI prepares a request for foreign travel, including itinerary, travel dates, itemized cost of travel, and a justification for request to the Office of Sponsored Programs.
A grant administrator (GA) checks the regulations for foreign travel and submits the request to the agency. If the agency approves the request, DORED sends a copy of the approval to the PI and the Office of Contracts & Grants. The GA files the original approval letter in the award folder. If the agency denies the request, a copy of the denial is sent to the PI and the original letter is uploaded in RAMSeS.
After approval, the PI submits a travel authorization to the Office of Contract & Grants, which forwards the request to the Chancellor‘s Office for approval.
Request to purchase additional equipment (DORED – SP – 28 – 081513)
Guidelines for requesting additional equipment are normally provided in the awarding federal agency’s guidelines. If the award is with the state or a private funder, the terms are normally stated in the award document. Generally, the following applies.
For each purchase, the Principal Investigator (PI) will assure that the equipment is:
- Necessary for the research or activity supported by the grant,
- Not otherwise reasonably available and accessible,
- Of the type normally charged as a direct cost to sponsored agreements, and
- Acquired in accordance with organizational practice.
The grant administrator (GA) provides the PI with the appropriate agency regulations for equipment purchase documentation requirements, the PI submits a letter to the Division of Research & Economic Development to request additional equipment. The letter justifies the request for additional equipment, providing an itemized list of requirements plus cost quotes from a supplier, identification of funds available for the equipment, and a budget revision as necessary. The GA reviews the letter of request and submits it to the agency.
If the agency denies the request, the PI is notified by the GA.
If the agency approves the request, a routing sheet, a copy of the approval letter, and the PI’s request are sent to the PI and Office of Contracts and Grants. The original letter is uploaded into RAMSeS.
Request for a residual account (DORED – SP – 29 – 081513)
Residual accounts may be requested for certain projects, generally firm fixed-price contracts. Principal investigators must request the establishment of a residual account through his or her Dean and the Vice Chancellor for Research and Economic Development. This request should include a budget that outlines how the funds will be spent. The Vice Chancellor for DORED will review the request and, if acceptable, forward it to the Director of Contracts and Grants.
The principal investigator must provide the Office of Sponsored Programs with the following for the vice chancellor’s review:
- Sponsor or company
- Proposal number or Banner number
- Period of performance
- Award amount, including total direct and indirect costs
- Residual amount
Principal investigators and project directors must follow appropriate guidelines for the expenditure of residual funds.
- A separate trust fund account will be established for funds remaining on fixed-price contracts.
- The account will be utilized by the principal investigator or project director to benefit the program.
- Any funds remaining on a fixed-price contract must be spent within 18 months after the residual account has been established. The account cannot be established until the final fiscal report has been filed with the agency and all funds have been received.
- The expenditure of funds from the established trust fund account is restricted to non-personnel costs within state guidelines. The purchase of office furniture, carpet, draperies, and office furnishings is prohibited. However, special consideration for personnel costs may be requested through the appropriate vice chancellor.
- All expenditures from the established trust fund will be monitored by the Office of Contracts and Grants.
Any funds not spent in the 18-month period will revert to a general scholarship fund.
Request to submit funding for a subcontractor (DORED – SP – 30 – 081513)
Provisions for funding a subcontractor and mandatory flow down clauses are normally provided in the awarding federal agency’s guidelines. If the award is with the state or a private funder, the terms are normally stated in the award document. Sub-agreements are the administrative mechanism by which funds are made available to collaborators for the purpose of completing a sponsored project. Agencies must specifically approve the use of subcontractors to complete a sponsored project.
If a sub-agreement is approved by the agency, the principal investigator (PI) is responsible for managing the sub-recipient relationship, including monitoring project performance, monitoring expenditures and sub-recipient cost sharing for allowability and adherence to budget limits, and approving claims for reimbursement. The University is accountable for adherence to all federal and state regulations and any applicable federal and state certifications.
Agency approval is required when it becomes necessary to contract or otherwise transfer a significant part of the research or substantive effort after an award has been made when the subcontractor was not proposed in the original award. The PI will submit a request to the Division of Research & Economic Development. The request must be approved by the funding agency. It must include at a minimum:
- Statement and schedule of work,
- Budget and budget narrative,
- Technical requirements,
- Collaborating project director contact information,
- Non-disclosure agreement (if applicable), and
- Any appendices not available in the primary award package
PI submits a request to fund a subcontractor to DORED that includes information as directed by the agency. The grant administrator (GA) checks the agency regulations for specific requirements. The GA determines the type of sub-award agreement and establishes sub-account number. The request must include schedule, statement of work, prime agreement, deliverables, patent clause, non-disclosure agreement, and other items as determined by the agency.
The request is signed by the associate vice chancellor for research administration and sent to the agency for approval. If the agency accepts the request, the GA prepares the sub-award to the PI and requests a Vendor Create Form to set up a profile in Purchasing to submit payment.
The PI submits a Vendor Create Form to DORED. The GA prepares the sub-award package, sends a copy to the Office of Contract & Grants, and updates the sub-award information in RAMSeS.
Request to transfer an award/project (DORED – SP – 31 – 081513)
Guidelines for transferring an award when the principal investigator (PI) leaves the University are normally provided in the awarding federal agency’s guidelines. If the award is with the state or a private funder, the terms are normally stated in the award document. If there are no guidelines or regulations covering a particular situation, the Division of Research & Economic Development will be responsible for providing or obtaining the applicable guidelines. These guidelines generally apply:
When a PI plans to leave the University during the course of an active award, the University has the prerogative to nominate a new Principal Investigator for the University or to request the funding agency to transfer the project to the institution where the original PI will be employed. The dean must nominate the new Principal Investigator to submit to the funding agency. If the agency determines that neither the nominated PI nor the transfer of the award is an option, the agency may terminate the project and request close-out.
In cases where the original PI and the University agree to transfer the award, N.C. A&T must submit a request for modification to the funding agency. The agency may facilitate a transfer of the grant, and the assignment of remaining unobligated funds may be committed to the PI’s new institution. The transfer of the award request will include:
- A brief summary of progress to date,
- A description of work yet to be accomplished,
- Total estimated disbursements to date, and
- A detailed line-item budget for the transfer amount and any outstanding continuing grant increments.
A modification from the funding agency, changing the end date and de-obligating the unexpended funds, will be sent to the University. The Office of Contracts and Grants must verify the de-obligated amount before the vice chancellor signs the modification.
The funding agency will issue an agreement to the institution where the original PI will be employed.
- Special circumstance: In rare occasions, the University may keep the award but subcontract with the original PI’s new university to have the original PI continue the project. In such a case, the agency may accept a new Principal Investigator nominated by N.C. A&T, and the University will submit a sub-agreement to the new institution for the original PI to continue the work.
Requesting contingency funds (DORED – SP – 32 – 081513)
Requests for contingency funds (an advance of funds on a sponsored program) are reviewed on a case-by-case basis. Contingency funds usually are issued to support major multiple-year awards that have already completed at least one year. Normally, contingency funds are approved where funds are delayed by the agency due to administrative procedures, acts of God, or additional requests from the contracting officer that must be reviewed before the release of funds from the agency. If N.C. A&T is a subcontractor to a university, funds to N.C. A&T could be delayed due to the administrative process at the other university.
The chair and dean must support the request for contingency funds. The request is reviewed by the vice chancellor for DORED and approved by the vice chancellor for business and finance. The dean must provide a letter supporting the request, which includes collateral (an account where by the funds can be repaid to Business and Finance) if the funds are not released from the funding agency. All requests must be reviewed by DORED for adherence to internal policy and procedures.
A letter of commitment is sent from the agency to the principal investigator (PI), who then prepares a request for contingency funds. This request should include a letter of agreement from the agency/university that includes the funding level and start date with appropriate signatures. A grant administrator in the Office of Sponsored Programs reviews the request. Normally, an agency will not commit in writing until the official award is issued. N.C. A&T will have to assess the risk to determine liability to the University if funds are not awarded. The vice chancellor may support an advancement of funds based on knowledge of program.
When preparing the contingency letter, the PI must include the proposed start date, an itemized list of contingency funds requested, and all payment requests on the appropriate forms. The contingency letter is then sent to the PI’s department chair for approval. If the request is approved by the department chair, the PI’s dean must provide an account number where funds are committed if funds are not received from the agency/University after approving contingency funds.
If the chair does not approve the request for contingency funds, he or she makes a recommendation for an alternative plan to support the program until the funds are received from the agency. If the dean approves the contingency funds request, the PI submits the request with backup documents to the Office of Contracts & Grants. Contracts and Grants reviews the documents and recommends approval or disapproval to the vice chancellor for business & finance.
If the vice chancellor for business & finance approves the request, a copy of the documents and account number is sent to DORED. The Banner account number is sent to the PI for action.
Requesting a no-cost extension on an award (DORED – SP – 33 – 081513)
Awards should be managed to avoid excessive requests for no-cost extensions (NCE). In cases where a NCE is absolutely required, the principal investigator (PI) should submit a justification letter to the vice chancellor for research & economic development through the Office of Sponsored Programs. The letter should include:
- A summary of progress to date (copy of the progress report),
- The reason why the work has not been completed,
- Length of additional time required to complete the project and justification,
- An estimate of remaining funds, and
- A detailed spending plan.
The vice chancellor for DORED will decide on the merits of the request based on a number of factors, including what percentage of the money has been spent; the history of the project, including previous NCE, if any; the merits of the proposed spending plan; etc. The vice chancellor may consult with the dean or associate dean of the school or college.
Upon approval by the vice chancellor and other appropriate university officials, the Grant Administrator (GA) will forward the request to the sponsor for consideration. If the agency approves the extension, the GA will update RAMSeS and notify the Office of Contracts and Grants, with a copy to the PI. If the extension is not approved, the PI will be notified.
Guidelines for extending the period of an award are normally provided in the awarding agency’s guidelines. If the award is with the state or a private funder, the terms are normally stated in the award document. If there are no guidelines or regulations covering a particular situation, DORED will be responsible for providing or obtaining the applicable guidelines.
Restrictive disclosure agreements (DORED – SP – 34 – 081513)
Whenever possible, avoid receiving proprietary information from third parties. If such information must be received, care should be taken to avoid receiving information that may impair the activities of University researchers. Before receiving such information, a written agreement must be signed by the vice chancellor for DORED and the party providing it. Such agreements should include these conditions:
- Only information provided in writing and marked as "proprietary" will be held in confidence by the University.
- The University will use the same degree of care to protect third party's proprietary information as it uses to protect its own.
- The University will not normally hold information in confidence longer than three years from the date it is disclosed.
It may also be necessary for the University to convey information of a proprietary nature to a third party. If so, a written agreement is required.
The Office of Outreach and Technology Transfer is responsible for processing all restrictive disclosure agreements. The appropriate (i.e.” receiving”) campus department is responsible for protecting the data. The Technology Transfer Office will provide notification to the campus department of such responsibility.
Screening industrial sponsors for business risk (DORED – SP – 35 – 081513)
All industrial proposals, submitted to the Division of Research & Economic Development for processing, are screened to determine whether the funder is a good business risk. First, the funder’s name will be checked against a debarred sponsors list. This can be accomplished by searching the federal government debarred list. No proposal will be submitted to any company appearing on this list.
Then the funder’s name will be checked against the delinquent payment list in the Office of Contracts and Grants. If a funder appears on this list, DORED will confirm with Contracts and Grants that the deficiency is still in effect. The assistant vice chancellor will notify the principal investigator/project director (PI/PD) that the proposal cannot be processed until the payment deficiency is satisfied. DORED holds the proposal until notified by Contracts and Grants that all payment issues have been resolved.
Finally, the database will be searched for records of previous dealings with the funder.
- If there are pending proposals or executed contracts with the funder, a printout of those projects will be attached to the proposal, which is then reviewed by the associate vice chancellor for research administration and assigned to a grant administrator (GA).
- If there have been no previous contracts with the funder, DORED requests a Dunn & Bradstreet (D&B) rating.
- If the funder is not listed or if the rating is less than satisfactory, the associate vice chancellor will determine the risk associated with the funder and the amount of funds that will have to be paid in advance if the proposal is funded. The amount must be noted in the budget section of the proposal and in the transmittal letter submitted with the proposal to the funder. If the funder accepts the proposal, N.C. A&T will not assign an account number until Contracts and Grants confirms that the advance payment check has cleared the bank.
Unofficial proposals (DORED – SP – 36 – 081513)
To reduce misunderstandings with funders or potential funders as to whether a document is an official proposal and who is authorized to enter into agreements on behalf of N.C. A&T, these disclaimers are to be included on any unofficial proposal (sometimes referred to as a “white paper"):
- Cover page and budget page: This document has not received final review or approval by North Carolina A&T State University, Division of Research & Economic Development and, therefore, should be considered only as information to permit your organization to determine whether a basis exists for further discussion. North Carolina A&T State University, Division of Research & Economic Development (336-334-7995) is the only office authorized to submit official proposals and negotiate research and development grants and contracts.
- Bottom or top of all other pages: This document is not an official proposal.
Waiver of overhead (DORED – SP – 37 – 081513)
As a general policy, N.C. A&T will not waive overhead. When estimating the cost of a research proposal, the overhead rate is applied to the Modified Total Direct Cost (MTDC). This provides a means for N.C. A&T to recover the indirect costs incurred by the total research activity but which cannot be directly assigned to an individual project. Failure to apply the overhead to a proposal is tantamount to offering to perform the research at less than the total cost to N.C. A&T. Since these are real costs and are paid, some other university budget is impacted. N.C. A&T’s policy is that state funds (or other resources) should not subsidize research.
The only exceptions are:
- When a foundation, not-for-profit corporation, or other agency has a written policy (or law) limiting the amount of overhead it will pay, N.C. A&T, based on the discretion of the vice chancellor for research & economic development, can reduce the overhead rate to the maximum allowed.
- Except as noted above, any request to waive (either partially or fully) overhead must be approved by the vice chancellor for research & economic development. In general, a very strong justification must be made even to warrant consideration.
Non-funded cooperative agreements (DORED – SP – 38 – 081513)
A non-funded cooperative agreement (NFCA):
- Is a written legal instrument that documents a relationship between the U.S. government and a state Department of Agriculture, college, university, other research institution, or organization, private agency or organization, or any other party.
- Does not provide for an exchange of funds.
- Does provide for non-monetary support, including supplies, equipment, chemicals, personnel, etc. from or to a cooperator.
In most circumstances, it may be more appropriate to establish a funded cooperative agreement if funds are to be provided.
A NFCA is appropriate when:
- All parties to the NFCA have a mutual interest in the agreement’s objectives;
- All parties exercise their own authority independently but cooperatively;
- All parties maintain control of their own resources, unless state otherwise in the NFCA; or
- An authorized ARS mission is supported.
Steps for processing NFCAs are:
- The PI provides a statement of work and/or supporting documents from the funding agency.
- The PI uploads into RAMSeS, including percentage of effort, and $1 in the budget.
- The PI routes for departmental approvals.
- Once the proposal is approved, a grant administrator (GA) submits it to the agency.
- After receipt of a fully executed award document, the amount received is entered as $0.
- The award type is entered as “OTHER.”
- The Award Project Number is used for tracking; no Banner Award Number is required.
Non-funded cooperative agreements from the U.S. Department of Agriculture
Annual and final reports are required.
For the Office of Sponsored Programs to process the request, PIs must upload the document into RAMSeS. The actual percentage of effort should be included in the “Investigators/Research Team” section. Although the research is non-funded, indicate $1.00 in the budget section. Once completed, the PI should submit it and certify for routing authorization by the department chair and dean.