Policy RSCH-SPA-007

Responsible University Administrator:Vice President for Research
Responsible Officer:Associate Vice President for Research
Origination Date:N/A
Current Revision Date:10/04/17
Next Review Date:10/04/21
End of Policy Date:N/A
Policy Number:RSCH-SPA-007
Status:Effective

 

UNIVERSITY POLICIES GOVERNING EXTERNAL SUPPORT     

PDF Version

 


Policy Statement


All proposals that use the name and resources of The University of Southern Mississippi and that may result in an award to the university involving restricted funds must adhere to university policies and procedures for submitting a proposal, accepting an award and administering the project. The Office of Research Administration (ORA), under the direction of the Vice President for Research (VPR), is formally charged with the responsibility of providing services to faculty and staff for securing external support from federal, state, and nonfederal sources including foundations and business/industry. The VPR or approved designee is the authorizing official to commit the university in all related matters involving contracts and grants.

 

Proposals submitted and awards received for federal funding follow the regulations of 2 CFR 200 (“Uniform Guidance”), agency guidelines, and all other applicable laws and regulations. 

 


Reason for Policy/Purpose


The University of Southern Mississippi applies for and receives substantial external funding in support of its mission. Submitting proposals and managing funded projects requires adherence to sponsor and university policies and procedures in order to remain in compliance with applicable law and regulation. This policy provides guidance for proposal submission, proper budgeting of externally funded projects, and other administrative requirements. 

 


Who Needs to Know This Policy


All members of The University of Southern Mississippi community engaged in or supporting externally funded programs or projects. 

 


Website Address for this Policy


www.usm.edu/institutional-policies/policy-rsch-spa-007


Definitions


Cost Share/Match  The portion of the project cost that is not charged to the sponsor. It can be a specific dollar amount or a percentage of total costs.
Institutional Base SalaryOfficial job data salary record through Human Resources. This does not include overload pay or additional pay. 
Restricted Funds Funds that can be used for a defined purpose and that must be segregated from other funding. This includes all grants, contracts, and cooperative agreements awarded to USM. 
Sponsor or Agency The organization providing funding to USM. 

Policy/Procedures


ACKNOWLEDGEMENT OF FUNDING SOURCES

Any publication, recording, performance, presentation or other scholarly activity that is the result of a sponsored project should acknowledge the resources contributing financial support. This acknowledgment should recognize all funding sources including the university's contribution to projects. As an example, if funds were provided by the VPR for internal development efforts and the project resulted in a publication, performance, presentation, etc., the university should be acknowledged for providing this support. Some sponsors require specific language; PI/PD’s are responsible for reviewing their award documents for requirements.

 

AUTHORIZING OFFICIAL 

The Vice President for Research or approved designee is formally charged with the responsibility to commit the university on proposal submissions, acceptance of awards, and other related documents. This includes related certifications required by funding agencies during the proposal and award process as well as financial and closeout documents. The duly authorized official on the university's behalf of all projects and related matters is the VPR. PI/PDs should not sign documents unless directed to by a knowledgeable source such as ORA.

  

CERTIFICATIONS 

Various certifications (sometimes called assurances) are sometimes required at the time of proposal submission or award acceptance. These are used to assure federal agencies that the university has applicable policies and procedures in place to successfully carry out the project. These certifications usually require an authorized signature, which ORA will provide.

 

CONSULTANTS

Principal Investigators/Project Directors may require the services of consultants (internal or external) whose expertise is needed to carry out the goals and objectives of projects. These may be paid or unpaid contributors to projects. Intra-institutional consulting (within USM) is assumed to be a normal university obligation requiring no additional compensation. However, in unusual cases where consulting is across departmental lines or involves a separate or remote operation, and the work performed by the consulting faculty member is in addition to his or her regular responsibilities, charges for such work are allowable provided that the consulting arrangement is identified and budgeted in the proposal. Use of consultants should be discussed with ORA at the time of proposal submission.

 

COST SHARING

The university may be required to contribute to the costs of a sponsored project as stated in agency guidelines. In some cases, these expenses may be in the form of "in-kind" costs such as contributed effort of personnel (salary and fringe benefits) who are supported by nonsponsored funds. At other times, there may be a requirement for "cash," particularly for equipment related projects. 

When cost sharing funds are required, the PI/PD is required to discuss these needs with the respective chair, director, dean, or Vice President for Research. Voluntary committed cost sharing is allowable only with approval of the Vice President or Associate Vice President of Research.

Cost sharing may also come from non-university, third-party arrangements. These arrangements must be documented at the time of proposal submission. However, sponsored project funding cannot be used as cost share for another sponsored project without approval.

The university is required to document all committed (mandatory and voluntary) cost sharing/matching funds just as it tracks agency dollars. These become auditable expenditures.

Cost sharing is generally not expected for federal funding. Agencies cannot use cost sharing as a factor during the merit review of research proposals, unless the requirement for cost sharing is in accordance with awarding agency regulations and specified in a notice of funding opportunity.

 

FACILITIES AND ADMINISTRATIVE COSTS (F&A) (also called Indirect Costs or Overhead)

Facilities and Administrative costs are actual costs incurred by the university that cannot be readily identified or associated with a single sponsored project or activity. These costs are normal business activities of the university such as utilities, safety, libraries, building and equipment use and maintenance, accounting, payroll, and academic and sponsored programs administration. 

The determination of F&A rates is based on a cost proposal submitted by USM to our federal cognizant agency, the Department of Health and Human Services. This proposal contains all the F&A categories that relate to direct costs necessary to conduct the primary functions of the institution such as teaching, research and other activities. Rates are then negotiated and a final rate agreement is signed establishing the required rates for all projects submitted to external funding sources. A listing of the current negotiated rates can be found at http://www.usm.edu/research/forms-and-budget.

Unless stated through a published rule of the sponsoring agency, F&A costs are not usually waived or reduced. Should PIs wish to request a reduction of F&A based on unusual circumstances, they may do so through the Vice President for Research. Any reduction of rates must be documented at the time of proposal approval. 

Recovered F&A costs are distributed to the Vice President for Research, the USM general fund, and the college and department generating the F&A, unless another arrangement is agreed upon in advance of the proposal submission. Units receiving recovered F&A establish their own criteria and procedures for use of these funds.

 

FRINGE BENEFITS

Fringe benefits are direct cost personnel expenses associated with any salary or wage paid by the university such as workers’ compensation, health insurance, FICA, etc. Fringe rates are determined by the Controller’s Office. These rates are available from http://www.usm.edu/research/forms-and-budget and are used in calculating budgets. All salary and wages (including students) associated with sponsored project activity have a corresponding fringe rate to be charged.

 

INTERNAL APPROVAL OF PROJECTS

All proposals for external funding submitted by the university must be approved by the PI, unit chair/director, dean/vp prior to submission to the agency. ORA will advise on the specific routing chain based on specifics of the proposal.  Unless there are extenuating circumstances, all proposals must be received in ORA no later than five working days prior to the agency’s deadline.

 

LEGAL ENTITY

The University of Southern Mississippi is the legal entity for all obligations relating to contract and grant activity. This includes all activity for all USM campuses and sites. 

ORA coordinates all legal documents with University Legal Counsel, Office of Technology Development, and other appropriate units as necessary.  ORA also negotiates legal terms and conditions with the agency. PIs are not authorized to sign sponsored program agreements or other documents related to USM external funding.

 

LETTERS OF INQUIRY (ALSO CALLED LETTERS OF INTENT)

Sponsors, particularly foundations and corporations, often ask for a brief (e.g., three to five pages) concept paper of the proposed project prior to the application deadline. Letters of Inquiry do not need to be reviewed or processed through ORA unless the sponsor requires a budget or approval by an authorizing official.

 

MANAGEMENT OF SPONSORED PROJECTS

The Office of Research Administration approves or monitors all expenditures resulting from a sponsored project funding source. ORA will work with the PI/PD throughout the project management process to help ensure that funds spent conform to sponsor expectations and regulations.

All university policies and procedures relating to expenditure of funds must be followed for all sponsored project activity (e.g., purchasing rules, property management, human resources). 

ORA or the VPR are designated as the administrative point-of-contact with funding agencies relating to the management of external funding. If it is necessary for the PI/PD to contact the agency for administrative matters, ORA should be contacted first. 

 

PRINCIPAL INVESTIGATOR (PI) OR PROJECT DIRECTOR (PD)

The PI/PD must be appointed as a faculty member or staff member of USM at the time the proposal is submitted, must be qualified to lead the project both technically and administratively, and must not be in a position that is intended to be temporary (such as postdoctoral, adjunct, and visiting appointments). Those in a temporary position who wish to serve as a PI/PD require approval of the Vice President for Research along with the appropriate chair and dean.

Newly hired faculty and staff not yet resident at USM but who are submitting proposals through USM ahead of their arrival may be PIs/PDs with approval of the department chair and dean.

Approval to serve as a PI/PD is indicated by the appropriate department chair and dean, and Vice President for Research if necessary, when the proposal is routed for approval.

A Co-PI/Co-PD must meet the same requirements as a PI/PD described above.

State nepotism law prohibits a PI/PD from supervising a person related by blood or marriage (see Mississippi Code SEC. 25-1-53). If individuals related by blood or marriage are both qualified to serve as PIs/PDs, they shall be appointed to the project with equal responsibility as Principal Investigators/Project Directors.

 

SALARIES AND WAGES

Charging the sponsor for time spent working on a sponsored project is expected unless effort is minimal or the sponsor does not allow or otherwise limits that category of expense. PI/PDs who are not on a 12-month appointment may charge summer salary to the project based on their academic year institutional base salary. PI/PDs seeking academic year release time to work on a project during the academic year must secure approval from the respective departmental chair or director and dean of their college.

Compensation on sponsored projects must not exceed an employee's institutional base salary. The ORA staff will provide assistance to faculty/staff in calculating salaries for sponsored projects during the proposal development process prior to formal submission of projects. Additional pay for work on a sponsored project is generally not allowed.

Salary for administrative and clerical staff are normally part of F&A costs, but direct charging may be appropriate if all the following conditions are met:

  1. Administrative or clerical services are integral to a project or activity, AND
  2. Individuals involved can be specifically identified with the project or activity, AND
  3. Such costs are explicitly included in the budget or have the prior written approval of the awarding agency

 

STIPENDS

Stipends are defined as payments to students which do not require the USM student to perform work as a condition of receiving the stipend. Fellowships often require the university, through the student’s mentor, to administer and monitor the funds on the student’s behalf. 

If the student is required to perform work in order to receive compensation (e.g., undergraduate assistant or graduate assistant), the compensation becomes a part of the general salaries and wages requested on the project and is not considered as a stipend.

 

SUBAWARDS

Project activities sometimes require that USM provide a subaward to another organization, usually but not always another university. A subawardee provides programmatic, scholarly, scientific, or other creative decision making into the design and conduct of a project. Generally, subawardees do not provide goods and services as part of their normal business function.

Subaward documentation (budget, work statement, relevant forms, etc.) is included in the proposal submitted to the sponsor. Subawardees use their own federally approved negotiated F&A rate for their budget.

USM can also be a subawardee to another organization. Subaward proposals are treated the same as any other proposal for external funding.

 

 


Review


The Associate Vice President for Research is responsible for the review of this policy every four years (or whenever circumstances require immediate review).

 

 


Forms/Instructions


All forms related to external funding are located at http://www.usm.edu/research/forms-and-budget

 

 


Appendices


N/A 

 


Related Information


Policy for Compliance with Cost Accounting Standards (RSCH-CGA-001) https://www.usm.edu/institutional-policies/policy-rsch-cga-001 

 


History


Amendments: Month, Day, Year – summary of changes

11/01/11: Formatted for Institutional Policies website.

02/20/13: Formatted for template. Minor editing throughout.

10/04/17: Modified to reference current federal regulations. Removed items that were guidance, informational, or procedural but not policy. Minor editing throughout.