Grant Policies and Procedures Manual Taylor University

Transcription

1 2014 Grant Policies and Procedures Manual Taylor University Office of Sponsored Programs Taylor University

2 Table of Contents General Overview I. Grant Assistance... 2 II. Development/Advancement Grants... 2 III. Academic Grants... 2 Pre-Award IV. Searching for Funding... 2 V. Developing the Proposal... 3 VI. Taylor University Fact Sheet... 5 VII. Pre-Award Role of Office of Sponsored Programs... 6 Step 1: Discussion of Advisory Form... 6 Budget Development... 6 Step 2: Pre-Submission Approval Form... 6 Step 3: Cover Sheet... 6 Submit Proposal to Granting Agency... 6 VIII. Step 1 Proposal Advisory Form... 7 IX. Step 2 Pre-Submission Approval Form... 9 X. Step 3 Internal Proposal Cover Sheet Post-Award XI. Post-Award Role of Office of Sponsored Programs XII. Step 4 New Award Process Checklist XIII. Budget Revisions Form OSP Policies XIV. Sponsored Award Incentive Policy XV. Responsible Conduct of Research (RCR) Policy XVI. Wages and Salaries on External Funding Policy XVII. Work Effort Certification Policy XVIII. Work Effort Pay Request XIX. Indirect Costs and Distribution Policy XX. Financial Conflict of Interest Policy for Federal Research Grants XXI. Financial Conflict of Interest (FCOI) Disclosure Form XXII. Cost Transfers Policy XXIII. Overruns Policy XXIV. Federal Policy Mandates XXV. Principal Investigator Eligibility and Assurance XXVI. Principal Investigator Status Regarding Debarment and Suspension XXVII. Human Subjects in Research (IRB) XXVIII. Recombinant DNA XXIX. NSF Project Outcomes Report Requirement XXX. NIH PubMed Central Policy XXXI. Export Control Regulations Apr-14 Page 1

3 General Overview I. Grant Assistance The purpose of the Office of Sponsored Programs (OSP) is to assist Taylor faculty with funding for scholarly projects, curriculum development and research. The office assists with the proposal and award process (internal and external), budget development and compliance with agency requirements. Additionally, the office oversees the University s compliance with regulations governing the expenditures and work performed using restricted funding. Electronic copies of our forms and policies can be found on our website at The office is overseen by Academic Affairs and the Director reports to the Provost. Additionally, OSP works with the Business Office to maintain financial records and make timely requests for payments. To assist faculty in Taylor s grant solicitation process, the components and steps to submitting and administering an award are outlined in the following sections. For specific information or assistance, please contact OSP at x85188 or Sue Gavin, the Director of Sponsored Programs, at ssgavin@tayloru.edu. II. III. Development/Advancement Grants The Development Office assists faculty and programs with grants related to trustee-approved capital or capacity-building projects. For more information or assistance, please contact Sherri Harter, the Associate Vice President for Development, at shharter@taylor.edu or x Academic Grants Since the University is the recipient for most academic grants, a Pre-Submission Approval Form must be submitted for review. The form can be found in section IX of this manual or online at Pre-Award IV. Searching for Funding Taylor University's Advancement office, the Zondervan Library, and OSP desire to equip the University community with the resources and tools necessary to conduct research for grants and other funding sources. SPINPlus, a search database provided by OSP, offers a wide range of opportunities for discovering funding for your project. The Foundation Center Collection, co-sponsored by TU's University Advancement and the Zondervan Library, also provides a way to find funding. All of these search options can be found at When considering solicitations and agencies, there are several questions that should be asked and answered to find the best grant option: What are the agency objectives and how well do the agency objectives or interests match the university and the investigator s focus? What other proposals has the agency funded? What are the financial and time constraints for this solicitation? Can you complete a reasonable amount of work within those constraints? Apr-14 Page 2

4 Does the agency have needs that are met by your project? How closely does your project align with the agency s needs? Is the university required to match the award amount with financial or in kind funds? Are there limitations placed on what can be used as matching? Is there enough time to complete the application and write a well thought-out proposal? Does the agency have a program officer or contact person that you can talk with about your project? It is recommended that the Primary Investigator (PI) schedule a verbal conversation with the program officer. Depending on the agency, this may begin with an that includes a brief summary of the proposed work (see chart on page 5). Ask if the work aligns well with the solicitation and if the officer can provide any comments or criticisms. Other solicitations ask for a letter of intent to be sent (either required or requested) prior to submitting the proposal. Be aware of what is needed by the agency some things that seem unimportant to you can make the difference between consideration and rejection. Agencies are looking at how well investigators complete the proposal package. Those who submit proposals without following directions are finding their proposals returned without review. V. Developing the Proposal Developing a strong proposal that has the potential of receiving funding involves discussions with colleagues, program officers and the university. Today s funding environment is collaborative, interdisciplinary and includes undergraduates as well as peers. Questions that should be asked and answered in the development process include: What is the current literature regarding my research topic? Is anyone doing something similar? If a similar project exists, how is your work different? (If your work is similar it may be perceived as duplication of effort and not be funded. If sufficiently different or an improvement can be clearly shown, it may receive funding) How will your work add to the existing body of knowledge? Do you know anyone that may be interested in collaborating? Is there anyone from another institution, from NGOs, or from industry who would be a valuable asset on the project? (Think beyond letters of support and think letters of commitment & collaboration) How might this be beneficial to students (especially undergraduates)? Is the scope of the project manageable? Larger projects may need to be broken down into several smaller projects. What is the amount of time needed to complete the project? (Academic and summer) Can some of the work be done as a class - senior capstone or directed research? If the work is offsite during the summer, can analysis be done during the academic year? What are the resources needed to complete the project? Do you need release time? Will students work during the academic year or only during the summer? Is travel involved - to collaborators, to resource sites, to conference presentations? Do you need supplies specifically for this project? It may be helpful to use a budget template to capture what is needed. As part of the proposal development, Taylor University has three forms that assist the university in supporting your work. These forms can be found at Along with internal documents, external discussions and forms should be completed in a timely manner. The following table explains when and what should be completed to contribute to your success. Apr-14 Page 3

5 Time Frame As soon as possible at least one month prior to submitting proposal (depending on the size of the project this may be up to 3 months before submitting proposal) Two weeks (ten business days) prior to submitting the proposal (depending on the time of the year may need more time if President s signature is needed) One day (24 hours) prior to submitting proposal External Talk with a program officer Complete Required Documents budget, CV, supporting documents, cover letter, letters of commitment Review specific guidelines (What is and is not allowed?) If uploading documents to a website, have everything loaded and check for errors Actions Internal Complete the Proposal Advisory Form (Step 1) Talk with your chair & OSP if you have not done so already Submit Pre-Submission Approval Form (step 2) Any cover letters or forms that need signatures should be done Submit rough draft of proposal to OSP with Pre-Submission Approval Form Submit Cover Sheet (step 3) along with final or almost final version of proposal to OSP. Apr-14 Page 4

6 VI. Taylor University Fact Sheet Taylor University, Inc. Quick Facts Revised March 5, 2014 Name of Applicant Taylor University, Inc. 236 West Reade Ave. Upland, IN (765) or (800) Employer Identification No.: N DUNS Number: Corporate & Gov t Entity (CAGE): 1KUL7 Compliance Congressional Districts United States: IN-05 Indiana Senate: District 9 Indiana House of Representatives: District 32 Human Subjects Federal Wide Assurance No.: FWA Indirect Cost Rates Indirect cost rates are based on Modified Total Direct Costs (MTDC), which is the total direct cost less equipment over $5,000, patient care costs, participant support costs, alterations/renovations, and rental of off-campus space and subcontract expenses in excess of $25,000 for each subcontract, student stipend and tuition. Project Type On-Campus Off-Campus Research, Instruction, 38% 17% Public Service (FY 14/15) Off-Campus Definition: For all activities performed in facilities not owned by the institution and to which rent is directly allocated to the project(s) the off campus rate applies. If more than 50% of a project is performed offcampus, the off campus rate will apply to the entire project. Indirect cost agreement date: July 17, 2013 Cognizant agency: DHHS Point of Contact: Denise Shirlea, (214) Administrative/Fiscal Official and Authorized Institutional Official Name Stephen Olson Title Vice President for Finance/CFO Address 236 W Reade Ave Freimuth Upland, IN Telephone (765) Fax (765) stolson@taylor.edu Apr-14 Page 5

7 VII. Pre-Award Role of Office of Sponsored Programs OSP can assist in the proposal stage (pre-award) as well as the administration of the award (postaward). Pre-award assistance: Step 1: Discussion of Advisory Form o Establish timelines (Documents to OSP, budget, unusual requirements) o Letters/certificates from university officials requested o Identify matching if necessary (PI, Dept. Chair, Dean, Business Office, Provost, Advancement) Budget Development o Compliance with agency and federal policies Wages, reassignment (release) time, allowable expenses o Discussions with external collaborators Contact Information - University Sponsored Programs or Industry / Non-profit finance personnel Gather information from collaborators (cv s, letters, unique requirements for proposal submission) o Planning for post grant maintenance costs for instruments / equipment Step 2: Pre-Submission Approval Form o Sub-Award Documents received by OSP 10 days prior to submission of proposal o Pre-Submission Approval form received by OSP 10 days prior to submission of proposal o Check required forms for accuracy and compliance with agency requirements Step 3: Cover Sheet o Review proposal and supporting documents o Signatures Submit Proposal to Granting Agency o Complete submission process Apr-14 Page 6

8 VIII. Step 1 Proposal Advisory Form (PAF) The proposal advisory form is due four weeks prior to grant due date. This form is to be completed by the Primary Investigator and all Co-I / Senior Personnel and submitted to the Office of Sponsored Programs with signatures. Lead PI: CO-I / Sr. Personnel: CO-I / Sr. Personnel: CO-I / Sr. Personnel: Dept. Dept. Dept. Dept. Program Title Sponsoring Agency RFP # or hyperlink Submission Deadline Total Amount / year(s) Outside collaborators PI or CO-I / Senior Personnel: I HAVE DISCUSSED MY APPLICATION TO THIS PROGRAM WITH MY CHAIR (OR DEAN OR AUTHORIZED INDIVIDUAL) AND CLARIFIED THAT THIS APPLICATION WILL INCLUDE THE ITEMS CHECKED BELOW. Signature Date Yes No Reassignment Time and / or additional pay for faculty in my dept / school Cost Share / Matching Waived or Limited Indirects (attach documentation) Purchase, installation, and / or maintenance of equipment Undergraduate students summer / directed research project Human Subjects involved (IRB approval needed) Vertebrate animals involved (IACUC approval needed) Chair, Dean, or authorized individual: I HAVE DISCUSSED THIS APPLICATION WITH THE PI AND/OR CO -I / SENIOR PERSONNEL AND UNDERSTAND THAT THIS APPLICATION WILL INCLUDE THE ITEMS CHECKED ABOVE. Signature Date Signature Date Office of Sponsored Programs Date Received: Apr-14 Page 7

9 F&A Reduction Request Form Attach this form to the Proposal Advisory Form (PAF) when the F&A (indirects or overhead) amount is less than what the University is entitled to claim. This form is NOT required if the F&A rate in the proposal is the maximum permitted by the sponsor s written policy. In those cases, attach a copy of the sponsor s policy to the PAF. Program Title Sponsoring Agency RFP # or hyperlink Total Amount / year(s) Amount of Reduction requested: Reason / justification for the request: (Facility and administrative costs reimbursed by the sponsor pay for utilities, maintenance of buildings and grounds, security, administrative costs of the department, etc. Please indicate below the reasons the University should consider approval of this request and explain how the project will benefit from the reduction): The electronic copy of this form can be found at Apr-14 Page 8

10 IX. Step 2 Pre-Submission Approval Form Today s Date: Primary Investigator(s): Was a Proposal Advisory Form completed for this work? Y/N What agency is this proposal being submitted to? Which solicitation? (provide the specific name and/or # of the request for proposal) Please provide a summary of the solicitation: When is the proposal due? What is the title of your proposal? Other Personnel (faculty or staff) who will be part of this project: Direct Costs $ Indirect Costs $ Total Amount Requested $ Is Taylor University required to match the funding? Y/N If yes, how much is required and how will the match be met? What is the proposed period for the grant? What university resources, equipment or facilities are needed to complete the work? Are you collaborating with anyone outside of Taylor? Y/N If yes, please list the collaborator(s) Summary of Grant Proposal: Proposal Objectives: Project Plan or timeline: Apr-14 Page 9

11 Final Budget: (attach a detailed budget) Are university resources being committed that are not in-kind (inclusion of work in a course, release time, etc.)? Is there any deviation from normal procedure for external grants (indirect costs, etc.)? Official Signatures of Approval: (Please note that the signatories require 10 calendar days after acknowledging receipt of this request before signing. Please include a rough draft or summary of the proposal with this form. If the granting agency is a private foundation, Ben Sells must sign off on it. Jeffrey Moshier, Provost Date Stephen Olson, Vice President for Finance Date Susan Gavin, Office of Sponsored Programs Date Department Chair(s) (and Deans if multi-disciplinary) Date The electronic copy of this form can be found at Apr-14 Page 10

12 X. Step 3 Internal Proposal Cover Sheet T a y l o r U n i v e r s i t y C o v e r S h e e t Please attach a copy of the proposal to this cover sheet. The proposal should be in final or near final form, and include all documentation needed for submission to the granting agency. Amount of Proposal: Type Here Matching Funds: Type Here Primary Investigator: Type Here Submitted for Internal Review on: Type Here Date grant must be submitted to agency by: Type Here Agency and Solicitation # or Title: Type Here Proposal Title: Type Here Date (proposed period) for Grant: Type Here Has this proposal been modified from Step 2: TU Internal Grant Proposal Pre-submission Approval Sheet? If yes, how? Type Here Official Signatures of Approval: The signatories require 48 hours after acknowledging receipt of this request before signing. A Pre-Submission Approval Form must be submitted and signed before this will be signed. If there are any significant deviations from the Pre-submission Approval Form more than 24hrs will be needed before final approval is given. Jeffrey Moshier, Provost Sue Gavin, Office of Sponsored Programs Date Date The following signatures required as deemed necessary by the above signatures. Date Date The electronic copy of this form can be found at Apr-14 Page 11

13 Post-Award XI. Post-Award Role of Office of Sponsored Programs OSP role in the post-award process: Review the new Award Process Checklist (Step 4) for details on award acceptance. This form is provided in the following section or may be found at Before work can begin, several steps must be reviewed to ensure compliance with university and federal policies. o Acceptance of Award Unless the proposal is to a fellowship or an individual, all awards are given to Taylor University. Taylor s authorized agent is Stephen Olson. He is the only person who can accept an award. o Between the submission of the proposal and the award, the budget may have changed. At times, an agency will notify the PI of a need to reduce (or in rare instances expand!) the budget or that only a portion of the work will be funded due to funding issues. Please forward the final budget with any changes to OSP. o The following may or may not be needed. OSP will assess prior to creating the award in Banner. IRB or IACUC approval Financial Conflict of Interest forms completed Responsible Conduct of Research training for students Subaward agreements signed OSP will review Banner for allowable and allocable expenses. Unallowable expenditures will be moved from the restricted funding account to the department budget within 30 days unless the PI provides sufficient documentation following notification by OSP. OSP will work with the PI to complete financial reports in a timely manner. Revisions to the budget may be allowed if the awarding agency allows changes. Approved revisions will be sent to the business office using the Internal Budget Revision form. Progress and final reports are the responsibility of the PI. OSP s responsibility includes being familiar with agency reporting requirements and sending timely reminders to the PI. Apr-14 Page 12

14 XII. Step 4 New Award Process Checklist New Award Process Congratulations! A grant award is wonderful news for you, your department and the university. Before the award is accepted and work begins, there are several things that must happen. This document will help answer your questions and provide the university with the information to assist you in successfully managing the award. Policies related to this process can be found in the master policy manual. If you need additional assistance, please contact Sue Gavin in the Office of Sponsored Programs at ssgavin@taylor.edu or Acceptance External awards (those given by a government agency or private foundation) are typically given to the university on behalf of a faculty or staff member. Therefore, the university s financial officer (Stephen Olson) is the only one who can accept the award. The following must be completed prior to acceptance: The final budget and budget justification sent to the business office and Office of Sponsored Programs (OSP) Information about external collaborations (including co-investigators or consultants) OSP will send W-9 and subaward or agreement forms IRB or IACUC approval (human or animal subjects) - a copy of the committee s authorization letter needs to be forwarded to the Office of Sponsored Programs Students who will be working on the project need to enroll in the Responsible Conduct of Research (RCR) training. The student may already have the required certification therefore, submit student names to OSP. If the student worker has not completed the training, the OSP will set up the online training and the on site discussion. Complete Financial Conflict of Interest form (if external funding) Advertising When an external grant is awarded to Taylor University on behalf of a faculty or staff member, the Office of Sponsored Programs will notify the Provost, Dean of the school, and University Relations. University Relations may determine that the university will put a press release out for wider distribution. Set Up Once the award is accepted by the university and all information is forwarded to OSP, the Business Office will set up the account. Funds received from external or internal agencies (internal includes Women s Giving Circle, Randall Endowment, and Provost s office) are considered restricted and cannot be transferred into department accounts. OSP notify Business office of new account and budget OSP notify Payroll of any faculty or student payroll needs Apr-14 Page 13

15 Budget and Reports Once an award is set up, the OSP will generate a New Award Form with the relevant grant information including Taylor University s Banner fund number and the indexes for billing to the grant, the agency award number and contact information, the approved budget and reporting requirements. OSP will provide regular budget vs. expenditure reports to the PI OSP will assist the Business Office with invoicing and work effort certification. OSP will review charges to award. Unallowable charges and expenditures exceeding the grant award amount will be charged to department after consulting PI. Report due dates will be monitored by OSP. An award close out will be completed within 90 days of the final report. An award close out is done by the OSP and usually involves the PI and the Business Office. The electronic copy of this form can be found at Apr-14 Page 14

16 XIII. Budget Revisions Form Taylor University Grant Budget Revision Internal Approval Sheet This form is to be used if a budget revision is requested after receipt of the award and is for internal purposes. Each award agency has its own rules regarding expenditure revisions. Please contact OSP for assistance with changes. Project Title: TU Fund Number: Awarding Agency & Award #: Amount of Grant: Grant Period: Primary Investigator or person requesting revision: Today s date: Awarding Agency Policy regarding budget revisions: Reason for Grant Budget Revision: Original and Proposed Budget Revision: Official Signatures of Approval: (Please note that the signatories require 10 calendar days after acknowledging receipt of this request before signing. Stephen P. Olson, Vice President for Finance Dean(s) of School (if multi-department grant) Chair(s) of Department Susan Gavin, Office of Sponsored Programs Date Date Date Date The electronic copy of this form can be found at Apr-14 Page 15

17 OSP Policies XIV. Sponsored Award Incentive Policy Taylor University wants to increase the resources available to the University community and to recognize outstanding performance. Taylor University is aware that many members of the faculty have the interest and ability to develop very robust scholarship, service and/or educational projects that can generate substantial amounts of external funding. Therefore, Taylor University will offer incentive compensation to full-time faculty, paid from the Dean s Indirect Recovery Account, for recognition of their efforts in obtaining and managing sponsored agreements for the University's mission of research, teaching, and service. The compensation is a portion of the release time recovered from an award that requires course release for completion. It is limited to no more than 10% of a faculty member s base salary per year. The complete policy may be viewed in the Master Policy Manual> Academics> Sponsored Programs. XV. Responsible Conduct of Research (RCR) Policy The Taylor University Responsible Conduct of Research (RCR) Policy identifies the expectations for faculty, staff and students conducting research while they are members of the Taylor University community and the greater research community. All members of the Taylor University community acknowledge that in conducting research, certain responsibilities and expectations must be identified and fulfilled in order to ensure honesty and integrity in all research endeavors. These responsibilities and expectations include: The need to avoid conflicts of interest and commitment The need to interact with others honestly and in good faith The need to preserve confidentiality The need to comply with applicable laws, rules, and regulations The need to make timely and accurate public disclosures The need to protect human subjects and organizations The need to protect animal subjects Each student participating in a research project must successfully 1) complete the online training seminar that includes topics appropriate to the academic area as well as a RCR general training module and 2) participate in the on-site discussion of responsible research during the student s first academic semester or first summer of research work. The complete policy may be viewed in the Master Policy Manual> Academics> Sponsored Programs or on OSP s website at XVI. Wages and Salaries on External Funding Policy In compliance with federal regulations, Taylor University will charge faculty and staff wages based on the faculty or staff member s base salary during the year the original work is proposed. For multi-year proposals, a projected salary increase of 2% each year is acceptable and allowable. During the summer, nine month faculty may receive up to 2/9ths of their base salary for effort done outside of the academic year. Staff such as research engineers or lab managers may have a portion of their time covered by the sponsored agreement. The staff member cannot be paid additional wages for the time spent on the Apr-14 Page 16

18 sponsored agreement. However the time may be transferred from the department budget to the award, freeing department funds for other uses. For all sponsored agreements, faculty and salaried employees will be compensated during the performance period and not after the work is completed unless stipulated by the awarding agency. OSP will work with the Payroll Department to set up appropriate payroll lines for salaried workers and time sheets for hourly workers including students. The complete policy may be viewed in the Master Policy Manual> Academics> Sponsored Programs or on OSP s website at XVII. Work Effort Certification Policy Effort is defined as the amount of time an employee devotes to fulfilling his/her institutional responsibilities. University compensated effort includes teaching, administration and other scholarly activities including research for which an individual receives compensation of salary, wages, supplementary salaries and overloads from the University. In addition, after one s first year of teaching at Taylor, advising students is part of each faculty member s duties. Effort is not hours but the total of a person s professional time spent to complete the objectives for which the individual is compensated for. Effort on externally funded awards must be certified as accurate at least once within a six month period. University compensated effort must be reasonable, allowable, and allocable to the sponsored research in order to be properly charged and certified to the sponsored program. For faculty and salaried personnel working on a sponsored agreement, effort must be certified by a person who has knowledge of the work at least once in a six month period. For salaried personnel, this certification process is completed through the Banner payroll / finance system by 1) the employee who did the work and 2) the PI or supervisor with knowledge of the work. Certification will occur as follows: Work completed between June 1 and August 31 certified before October 1 Work completed between September 1 and December 31 certified before February 1 Work completed between January 1 and January 31 certified before March 1 Work completed between February 1 and May 31 certified before June 15 The complete policy may be viewed in the Master Policy Manual> Academics> Sponsored Programs or on OSP s website at Apr-14 Page 17

19 XVIII. Work Effort Pay Request Request to Payroll for Work Effort Pay This form is used when work is done by a faculty member or salaried person on a sponsored award (internal or external). The payroll is tied to completion or attempt to complete specific objectives / tasks as stated in the award proposal or statement of work. Work Effort will be certified at the end of the performance period or at least once during a six month period in accordance with University policy. Office of Human Resources 236 W. Reade Ave. Upland, In Phone: Fax: Employee Name: Title: Contract / Award: Phone: Date requested: PayPeriod(s) covered by this effort: Total Amount of Salary for this request Account for Wages / Salary Account(s) for Benefits - FICA, etc. Requestor (person completing this form) Position on Award / Contract: Objectives for effort: Primary Investigator (PI) Director OSP Apr-14 Page 18

20 Reviewed by HR: Approved by VP for Finance: ROUTING OF THIS PAPERWORK Internal Use Only-HR Form 2 Original: Goes to OSP for approval before going to Payroll Amount Paid Processed by Date The electronic copy of this form can be found at Apr-14 Page 19

21 XIX. Indirect Costs and Distribution Policy Taylor University encourages faculty and staff to seek external funding for research, scholarship and improvements to the facilities. Funding which allows for the recovery of Facilities and Administrative costs (also commonly referred to as F&A, indirect costs, or overhead costs) reduces the burden of maintaining research at the University. Recovered F&A costs have the added benefit of increasing available funds for other activities such as publishing, student research projects, and research related personnel and equipment. Taylor University understands that there are some grants that do not permit full F&A costs recovery. In this case, a determination of value will be made in conjunction with the PI, Chair, Dean, Provost, and OSP. If a solicitation does allow recovery of the full F&A rate, faculty members are expected to request Taylor s full rate. As of May 1, 2013 Taylor s negotiated F&A cost recovery rate is 38% Modified Total Direct Costs (MTDC) for on campus activities. Off campus activities use a negotiated rate of 17%. The complete policy may be viewed in the Master Policy Manual> Academics> Sponsored Programs or on OSP s website at XX. Financial Conflict of Interest Policy for Federal Research Grants This Financial Conflict of Interest Policy is designed to maintain the trust of the public, research volunteers and the University research community. This policy governing financial conflicts of interest (FCOI) applies to all Investigators at Taylor University who apply to or receive external research support from the following federal agencies: the National Science Foundation (NSF) and Public Health Service (PHS) Agencies, including but not limited to the National Institutes of Health (NIH). The Provost, acting as the Institutional Official, is responsible for ensuring implementation of this policy and may suspend all relevant activities until the financial conflict of interest is resolved or other action deemed appropriate by the Institutional Officer is implemented. Federal regulations governing grants from certain federal agencies (i.e. NSF and PHS agencies including NIH) require that the University adopt, monitor, and enforce a Financial Conflict of Interest Policy covering financial conflicts that may arise as a result of research funded by such agencies (see regulations at 42 CFR and following). The University recognizes that these conflicts may arise due to interests and investments that faculty and their families may have. The existence of a significant financial interest and any resulting financial conflict(s) is not prohibited in and of itself, but such conflicts must be disclosed to the University and managed appropriately. For these reasons Taylor University adopts the Financial Conflict of Interest Policy. All investigators who apply for or receive grants from the Federal agencies identified above are required to follow established procedures and complete training prior to beginning their award. The complete policy may be viewed in the Master Policy Manual> Academics> Sponsored Programs or on OSP s website at Apr-14 Page 20

22 XXI. Financial Conflict of Interest (FCOI) Disclosure Form A Financial Conflict of Interest (FCOI) form is needed for EVERY proposal submitted to or awarded by NSF or NIH. If awarded, the form is reviewed and updated each year of the award. *NAME: *DEPARTMENT: *What is your role on this project? (choose one) PI/PD CO-I Senior/Key Personnel Consultant Other (include description) *Who is the Project Lead PI / PD? *What is the Project Period? *What is the Project Title? *1. Do you or any member of your immediate family (spouse or partner and dependent children) have any Significant Financial Interests (SFI) in a Publicly Traded Entity that might reasonably appear to be related to your Institutional Responsibilities? (An SFI for publicly traded entities exists if the value of any equity interest as of the date of disclosure combined with any remuneration in the past 12 months exceeds $5,000) Yes/No- If yes, attach a separate sheet* with the name of the entity, nature of the interest, value and any documentation *2. Do you or any member of your immediate family (spouse or partner and dependent children) have any Significant Financial Interests (SFI) in a Privately Held Entity that might reasonably appear to be related to your Institutional responsibilities? Yes/No- If yes, attach a separate sheet* with the name of the entity, nature of the interest, value and any documentation *3. Have you or any member of your immediate family (spouse or partner and dependent children) received any income related to intellectual property rights and interests that might reasonably appear to be related to your Institutional Responsibilities? (Do not include any intellectual property that has been assigned to Taylor University) Yes/No- If yes, attach a separate sheet* with the name of the entity, nature of the interest, value and any documentation *4. In the past 12 months, have you undertaken any travel related to your Institutional Responsibilities that was either reimbursed or paid for by any individual or entity other than a Federal, state or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research instituted that is affiliated with an Institution of Higher Education. Apr-14 Page 21

23 Yes/No- If yes, attach a separate sheet* with the purpose of the trip, name of the sponsor / organizer, destination, duration and approximate monetary value. *Submit all supporting documentation to the Provost in a sealed envelope marked Confidential CERTIFICATION BY INVESTIGATOR: A. I have read and understand Taylor University s Financial Conflict of Interest policy. B. To the best of my knowledge, I have made all required financial disclosures. C. I agree to comply with any conditions or restrictions imposed by Taylor University for the purpose of managing, reducing, or eliminating actual or potential conflicts of interest in connection with this award. If I am unable to comply, I understand that the University may decline the award or terminate the funded research program. Check if applicable: CERTIFICATION BY PRINCIPAL INVESTIGATOR / PROJECT DIRECTOR: The following people (or roles) meet the definition of Investigator for the above project and I certify that they all will comply with the disclosure requirements of the Taylor University Financial Conflict of Interest policy. Signature of Investigator Date CERTIFICATION BY PROVOST: No Financial Conflict of Interest appears to exist. A Financial Conflict of Interest may exist. Proposal may be submitted but if the grant is awarded, research may not begin until an approved management plan is in place and the sponsor has been notified. A Financial Conflict of Interest may exist. No research may go forward until an approved management plan is in place and the sponsor has been notified. Signature of Provost Date The electronic copy of this form can be found at Apr-14 Page 22

24 XXII. Cost Transfers Policy Proper management of funds is essential to uphold the fiduciary responsibilities of the university. It is the policy of the institution that costs are charged to the appropriate sponsored project when the cost is initially incurred. However, there may be circumstances when it is necessary to transfer expenditures to a sponsored project subsequent to the initial recording of the charge. These transactions require monitoring for compliance with university policy, Federal regulations, sponsor specific guidelines and the cost principles that guide fiscal activities on sponsored projects. All cost transfers to sponsored grants should be made within 90 days of the original charge. Any cost transfers removing expenses from a grant must be made without regard to this time limit. There may be unusual circumstances when a cost transfer may be appropriate after the 90 day deadline but transfers of this nature will be subject to increased review. The transferred cost must be allowable under the terms of the grant receiving the charge. Written justification and documentation must accompany the cost transfer request. To do this, use the Cost Transfer Request and Explanation Form. Cost transfers must be authorized by the PI and be reviewed and approved by OSP prior to being processed. Cost transfers are appropriate when their purpose is to: Correct errors in processing the original charges Move costs between funds for closely related work (as defined by the project scope) that is supported by more than one funding source Transfer pre-award expenses in accordance with the provisions of OMB Circular A-110, Section c.25 Retroactively adjust salary costs between projects to reflect an individual s actual effort on the project Cost Transfers are inappropriate, but are not limited, in the following circumstances: Transfers solely for the purpose of utilizing an unexpended balance Transfers for the purpose of avoiding a cost overrun by charging another, unrelated sponsored project Transfers to circumvent pre- and/or post-award restrictions The complete policy may be viewed in the Master Policy Manual> Academics> Sponsored Programs or on OSP s website at XXIII. XXIV. XXV. Overruns Policy Coming Soon! Federal Policy Mandates Government policies relating to federal grant awards can be found at Principal Investigator Eligibility and Assurance Full-time Taylor University employees acting in their capacity as a Taylor University employees are eligible Principal Investigators (PIs). Emeriti may be a Co-PI as long as a full-time faculty member has been identified as their Co-PI. Part-time faculty may also undertake the role of Co-PI when the other Co-PI is a full-time Taylor University faculty member. Apr-14 Page 23

25 XXVI. Principal Investigator Status Regarding Debarment and Suspension It is the policy of Taylor University that all faculty participating in sponsored research: a) Are not presently debarred, suspended, proposed for debarment, declared ineligible, sentenced to a denial of Federal benefits by a State or Federal court, or voluntarily excluded from covered transaction by any Federal department or agency; b) Have not within a three-year period preceding this application been convicted of or had a civil judgment rendered against them for commission of fraud or a criminal offense in connection with obtaining, attempting to obtain, or performing a public transaction; violation of Federal or State antitrust statuses or commission of embezzlement, theft, forgery, bribery, falsification or destruction of records, making false statements, or receiving stolen property; c) Are not presently indicted for or otherwise criminally or civilly charged by a governmental entity with commission of any of the offenses enumerated in paragraph(b); and d) Have not within a three-year period preceding this application had one or more public transactions (Federal, State, or local) terminated for cause or default. XXVII. XXVIII. XXIX. XXX. Human Subjects in Research (IRB) The Taylor University Institutional Review Board (IRB) Policy exists to protect people who participate in original research conducted at Taylor University or by a member of the University community. Research that involves interviewing other persons, distributing surveys, conducting experiments on people, or even observing particular people in their daily lives is classified as research on human subjects, and all such research requires some level of approval from the IRB. For more information, please refer to the Taylor University IRB Policy at af6cad00c212.pdf. Recombinant DNA Recombinant DNA is DNA that has been artificially created. If a faculty member will be conducting funded research that involves rdna, the Provost must review the research and certify that the rdna research falls under a NIH exempt category before funds will be made available. NSF Project Outcomes Report Requirement As of January 2010, NSF requires that an Outcomes Report be submitted electronically via Research.gov within 90 days of the expiration of the grant. The report is a brief summary prepared specifically for the public, describing the nature and outcomes of the project within the context of NSF s review criteria the intellectual merit and/or broader impacts of the work written for the lay reader. NSF will automatically attach all publications resulting from an award as reported annually in the FastLane project reporting system to the Outcomes Report. 1 This requirement is met by the investigator and is a term/condition of the award. NIH PubMed Central Policy NIH PIs are required to ensure that publications derived from research funded by the National Institutes of Health are submitted to PubMed Central. From the NIH: The Director of the NIH shall require that all investigators funded by the NIH submit or have submitted for them to the National Library of Medicine s PubMed Central an electronic version of their final, peer-reviewed manuscripts upon acceptance for publication, to be made publically available no later than 12 months after the official date of publication accessed February 20, accessed February 20, 2014 Apr-14 Page 24

26 To ensure compliance, the PI should disclose to the publisher upon submission of an article that it is subject to this NIH policy. The journal s author instructions and copyright transfer or publication agreement should be reviewed for any language that may prohibit the PI from complying with submission to PubMed Central. NIH recommended language is as follows: Journal acknowledges that Author retains the right to provide a copy of the final peer-reviewed manuscript to the NIH upon acceptance for Journal publication or for public archiving in PubMed Central as soon as possible but no later than 12 months after publication Journal. 3 XXXI. Export Control Regulations Over the past few years, the Federal government has become increasingly involved with protecting information and technology from disclosure to overseas interests. New laws impact research, foreign travel and the transfer of technology and information to certain countries and also impose sever criminal and civil fines for noncompliance. The materials and equipment potentially covered by export controls sometimes have no obvious commercial or military value, and the restricted destinations include many of the closest allies of the United States. Export control regulations also apply to certain transfers of technical information and money outside the United States. Failure to comply with these regulations can result in severe civil and criminal penalties for both the employee moving the item/information out of the country and for the University. Examples include when a Taylor University employee: Carries a laptop computer into one of the Office of Foreign Assets Control embargoed countries Carries a cellular phone that has a GPS system into a restricted country Ships computers or other tangible items to a foreign country Collaborates with a foreign national or releases information to a foreign national on a research project for the federal government It is Taylor s policy to comply with all United States export control laws and regulations, including those implemented by: The Department of Commerce through its Export Administration Regulations (EAR) The Department of State through its Internal Traffic in Arms Regulations (ITAR) The Treasury Department through its office of Foreign Assets Control (OFAC) Assets-Control.aspx If foreign travel and/or the exportation of tangible items will be a part of any sponsored research project, PIs should contact OSP well in advance of proposal submission. If approved tangible items related to a sponsored project are shipped overseas, PIs must keep soft or hard copies of all export documentation, including financial records and shipping documentation in their research project files for a period of five years from the date of export, re-export or transfer of a tangible item abroad or of controlled information to a foreign national outside od or within the US (a deemed export ). 3 Section B(3), accessed February, 20, 2014 Apr-14 Page 25