UNCG Sponsored Programs

Facilitating Research, Scholarship & Creative Activity

UNCG procedures for proposal preparation, award management and project closeout.

 

[accordian][accordian-item heading=”Assumption of Risk Policy” item_no=”One”]

This policy defines the general parameters through which the Vice Chancellor for Research and Engagement might assume financial risks associated with sponsored research or projects prior to the receipt of a formal award or fully executed agreement or prior to the receipt of continuation support for multi-year projects; sets forth the necessary administrative review process; and designates who, within the University, authorizes an Assumption of Risk (AOR).

 

Definition

Externally sponsored programs frequently have start dates that precede the finalization or receipt of formal award documents or agreements. When time is of the essence or when an fund number is required to develop position descriptions and job announcements, the PI can request an AOR. The AOR authorizes the establishment of a restricted funds account from which the PI may make expenditures for 1-3 months.

 

The AOR can be requested for:

 

  • Preaward expenditures.
  • New awards.
  • The period between the end date of a current budget period and receipt of the next increment of funds.

 

  • The formal extension of the end date for multi-year projects.

 

If IRB or IACUC approval is pending, AORs will only be approved for the portion of proposed awards that does not require IRB/IACUC approval. Administrative Review AOR requests must be reviewed and approved by the OSP, the Office of Contracts and Grants (C&G), and the Vice Chancellor for Research and Engagement.

 

Procedure

  1. The PI completes an AOR request form and attaches supporting documentation: a. The AOR request form is here: Assumption of Risk Form.
    1. The first attachment is an itemized budget for the period requested (1-3 months). The second attachment is supporting documents or correspondence (email is fine) to show award is imminent.
  2. The PI then submits an AOR request to the OSP (preferably via email).
  3. The Offices of Sponsored Programs and Contracts and Grants review the request and make recommendations.
  4. If the AOR request is recommended by both OSP and C&G, it is returned to OSP to be entered into Ramses.
  5. The AOR request is then sent to the Vice Chancellor for Research and Engagement for approval and guarantee.
  6. Once ORE has approved the AOR, this is noted in Ramses and the AOR goes to Contracts and Grants so a fund number can be assigned. The PI will be notified when this is done.

 

Notes

  • If there are questions or issues with the AOR request at any point during this process, the PI will be notified.
  • When the award is officially received by UNCG, the AOR will be cleared as a part of the setup process. No further action by the PI is necessary.

[/accordian-item][accordian-item heading=”Grant Transfers” item_no=”Two”]

Award Transfers

Transferring to UNCG

The process of transferring awards from one institution to another is not a simple task and requires close coordination between three basic entities: the sponsoring agency, the old institution and the new institution. Normally, the OSP works in consultation with the principal investigator and his/her department at both the old and new institution.  Items that should be considered during a grant transfer include: the form of transfer, determination of the unobligated balance, differences in facilities and administrative (F&A) rates and the (possible) funding gaps created by the time required to closeout and re-issue the project. The transfer process can take several months depending on the complexity of the project being transferred and the number of parties involved. Since awards are granted to the Institution and not directly to the PI, institutional support is needed to smoothly and successfully transfer the award.

Transferring a UNCG Award to an Outside Institution

If you have accepted a position at another institution and want to transfer any current awards you may have at UNCG, you must, as early as possible, discuss the transfer with your Department Chair, the agency and Office of Sponsored Programs (OSP). Transferring an award from UNCG to another institution is an action which must be approved by the awarding agency, and all such requests must be routed through the OSP. Some agencies, such as National Science Foundation (NSF) and National Institutes of Health (NIH) have standardized this procedure and require submission of forms bearing institutional signatures. Other sponsors prefer that a substitute PI is designated at UNCG and the remaining work subcontracted to the new institution.

At UNCG, most award transfers involve the National Institutes of Health and the National Science Foundation.  The steps below typify the transfer process for these federal agencies.

Steps for Transferring a National Institutes of Health (NIH) Grant

  • Notify your Department Chair.
  • Notify the Departmental Administrative staff in the Office of the Associate Dean for Research
  • Notify the Program Officer at the awarding NIH institute or center
  • Notify your OSP Grants Specialist and provide the following information.
    • Agency name
    • Grant/Award number
    • Amount of unobligated funds remaining
    • Institution to which transfer is requested
    • Contact information for a Grants Manager or Authorized Representative at recipient institution
    • Requested date of award’s termination at UNCG
  • Grant terminated in accordance with 45 CFR 74.61 or 92.43

Steps for Transferring a National Science Foundation (NSF) Grant

  • Notify your Department Chair.
  • Notify the Departmental Administrative staff in the Office of the Associate Dean for Research
  • Notify the Program Officer at NSF.
  • Notify your OSP Grants Specialist and provide the following information.
    • PI’s name
    • Agency name
    • Grant/Award number
    • Amount of unobligated funds remaining
    • Institution to which transfer is requested
    • Contact information for a Grants Manager or Authorized Representative at recipient institution
    • Requested date of award’s termination at UNCG
  • A PI Transfer Request must also be initiated via FastLane. Detailed instructions on submission of the transfer request are available electronically on the NSF website

Steps for Transferring Awards from other Agencies/Corporations/Foundations

  • Notify your Department Chair.
  • Notify the Program Officer at the awarding entity.
  • Notify your OSP Grants Specialist and provide the following information.
    • Agency name
    • Grant/Award number
    • Amount of unobligated funds remaining
    • Institution to which transfer is requested
    • Contact information for a Grants Manager or Authorized Representative at recipient institution
    • Requested date of award’s termination at UNCG
  • Complete any agency/corporation/foundation form(s) as identified by your Program Officer and/or Contract Administrator.

Transfer and Disposition of Equipment

Equipment purchased using funds from an external sponsor may belong to the University or to the sponsor depending upon the sponsor’s regulations. When a PI needs to transfer equipment purchased with external funding, Fixed Assets should be contacted to provide information about ownership. In most cases, equipment purchased on currently active awards normally transfer to the new institution, but permission must be granted by the department chair for the transfer of equipment acquired from grants, but now owned by UNCG.

Things to Remember

  • Review sponsor requirements
  • Begin the transfer process as soon as possible
  • Send all required forms and documents to the OSP Grants Specialist
  • Review expenditure report with C&G Contract Specialist
  • Freeze project account fund as soon as possible so that the Final Financial Report can be completed
  • Delays are normally caused by:
    • Untimely notice to sponsor & university administrators
    • Incomplete or inaccurate relinquishment statements/notification of transfers
    • Outstanding final reports
    • Progress, invention, and financial
    • Over/Underestimating unobligated balances
    • Untimely submission of transfer application to sponsors (new institution)
    • Untimely submission of FSR from prior institution

[/accordian-item][accordian-item heading=”Use of On-Campus vs. Off-Campus F&A Rate” item_no=”Three”]

DEFINITIONS

“On‐campus” is defined as research that is conducted in space owned by the University and for which the University is bearing the space costs, from University funds. For space used for on‐campus research, the University has already included the costs associated with that space in the “facilities” portion of the on‐campus F&A rate.’

“Off‐campus” is defined as research that is conducted in space not owned by the University and not otherwise paid for by the University from University funds.  For space used for off‐campus research, an external source (typically, a research sponsor) provides funding, either paying directly for space, or reimbursing the University for its costs in renting or leasing the space, or otherwise directly providing space for research at no charge to the University.  Accordingly, the Facilities portion of the on‐campus F&A rate does not apply to the rental or lease costs of such space. “Rented or Leased Space” is defined as space that is used for research but not owned by the University, the costs of which are paid either from University funds or from funds provided by a research sponsor. Off-campus rates can be used only if 50% or more of the grant expenditures are for activity in off-campus locations.

 

The existence of a lease or a rental agreement does not, in and of itself, indicate that the facility is off-campus. When the rental or lease cost is billed as a direct cost and paid by a sponsor, such project activities are considered off-campus. This determination does not apply to F&A charges associated with subawards where UNCG is the prime entity. F&A on the first $25,000 of each subcontract is charged using the on campus rates. Should the criteria not be met, contact the Vice Chancellor for Research for review and approval to use the off-campus rate.

 

Both on-campus and off-campus rates may be used for a given project under certain circumstances. Contact your OSP Grants Specialist for additional guidance.

[/accordian-item][accordian-item heading=”Request an F&A Rate Waiver or Reduction
” item_no=”Four”]

The University has an F&A rate agreement negotiated with the U.S. Department of Health and Human Services. The University also has established rates for instruction/training and accepts rates stipulated by a sponsor’s published policy. PI’s who desire to use a rate lower than the applicable negotiated rate or the established sponsor rate must obtain approval from the Vice Chancellor for Research and Engagement and the Vice Chancellor for Business Affairs.  F&A rate waivers and/or reductions will only be approved in exceptional circumstances.

Principal Investigators (PIs) are not authorized to negotiate a reduction or waiver of F&A with a sponsor.  If the sponsoring agency’s policies restrict or prohibit payment of full F&A costs, a written copy of the restriction must be provided to the OSP at the time the proposal (and budget) is submitted for institutional review and approval.

Procedure for Requesting F&A Cost Reduction or Waiver

Department Chairs must review and approve all faculty requests for a reduction or waiver of F&A prior to the request being submitted to the Vice Chancellor for Research and Engagement and the Vice Chancellor for Business Affairs.

If the PI wishes to seek an internal, reduction in or waiver of F&A costs, he/she must submit a written request directly to the Vice Chancellor for Research and Engagement prior to finalizing the project budget. The VC for Research and Engagement will review the justification, assess the potential impacts on the institution, consult with OSP as necessary, and determine if the request will be approved. Once approved by the VC for Research, the request is then forwarded to the Vice Chancellor for Business Affairs for review and approval. The request must be submitted to the Vice Chancellor for Research and Engagement at least five (5) working days before the sponsor submission date. The PI must include a copy of the approved waiver request with his/her proposal submission.

Unacceptable Reasons for Individual Project F&A Waivers/Reductions

The University does not allow F&A waivers/reductions to be granted in the following circumstances:

  • The Principal Investigator failed to submit the proposal via approved institutional channels (e.g., through the Office of Sponsored Programs or other approved institutional channel) prior to submission to the Sponsor. In these cases, the Sponsor will be expected to pay the full applicable F&A rate or the department will be responsible for cost-sharing that portion of the F&A the sponsor refuses to pay.
  • To increase (or perceive to increase) the competitiveness of a proposal.

Processing of Reduced-Rate Proposals without Evidence of an Approved Waiver:

If a proposal is submitted to OSP at a reduced rate without evidence of an approved reduction/waiver, OSP will contact the PI or the PI’s unit to determine whether there is sponsor documentation or internal approval for the reduction/waiver. If a reduction request is in process, the OSP Grants Specialist will attempt to facilitate a quick decision. If the process cannot be completed prior to the Sponsor’s proposal deadline, the Principal Investigator is responsible for updating the proposal to use the full institutional F&A rate applicable to that type of project prior to its submission to the Sponsor.

At the End of the Project:

For fixed-price awards or other awards where the University is allowed to retain the unexpended balance, all reductions are granted with an understanding that if there is a balance at the end of the project, the F&A rate reduction will be rescinded. The published rate will be charged to the entire project and the value of the reduction will be subtracted from the remaining balance. For example, if a balance of $5000 remains at project end and the PI was granted a reduction valued at $1500, $3500 would be available for transfer to departmental account. However, if the balance was $500, no funds would be available for transfer to the departmental account and the effective reduction would then be $1000.

[/accordian-item][accordian-item heading=”Time and Effort Reporting” item_no=”Five”]

The University must comply with the federal Office of Management and Budget Circular A-21 (Cost principles for Educational Institutions) for documenting salary expenses charged directly or indirectly against federal sponsored projects.

 

The Time and Effort report must represent – in percentages totaling 100% – a reasonable estimate of an employee’s compensated effort for the period being reported. Effort reports must be completed and signed by either the employee or Principal Investigator/Project Manager. The Principal Investigator/Project Manager shall review and certify all Time and Effort reports associated with the sponsored project using suitable means of verification that the reported work was performed. Your Grants Specialist contact in the Office of Contracts and Grants is responsible for the collection, review, and retention of all Time and Effort reports. The Grants Specialist will make individually reported data available only to authorized auditors.  Time and Effort reports must be completed and signed following the end of the reporting period.

[/accordian-item][/accordian]