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Division of Research and Sponsored Programs
THE PRINCIPAL INVESTIGATOR'S HANDBOOK: Section I
(updated 16 Sep 2004)
- Section I
- Section II
100.00 INTRODUCTION
Tennessee State University (TSU) receives awards for research, training, and technical assistance from extramural funding sources, including the Federal Government and private organizations. Policies and procedures on research and sponsored programs are diverse and complex. The Handbook seeks to guide administrators, faculty and staff from the development of a research idea to the administration of an award. In addition to answering the most common questions, the Handbook provides information on Federal regulations and policies dealing with civil rights, and intellectual property on patents and copyrights. The Handbook also deals with compliance policies on OMB Circulars A-21, A-110, and A-133 as well as the protection from research risks involving human subjects, animal care and use, radiation safety, hazardous materials, and controlled substances. Principal investigators (PI) are encouraged to review the OMB Circulars which are available at the RSP website.
200.00 DIVISION OF RESEARCH AND SPONSORED PROGRAMS
The Division of Research and Sponsored Programs (RSP) provides research leadership, information, technical assistance, and a myriad of services to encourage faculty and staff to engage in research and training programs through extramural funding sources. One of the major goals of RSP is increase TSU’s research capacity while strengthening it’s instructional programs and infrastructure. The University displays a broad spectrum of sponsored programs including: basic research, applied research, training, faculty and student development. The programs range from individual projects to major research collaboratives. RSP serves as a liaison between funding agencies, principal investigators (PI) or project directors (PD), and the administrative units of the University. Some of the functions of RSP are as follows:
- locate potential funding sources,
- coordinate compliance policies on human subjects, animal care and use, research standards of conduct and integrity, and biosafety with federal, state, and local regulations,
- guide faculty and staff through the grant/contract application process,
- route proposals through channels for approvals and endorsements,
- maintain University award files and records,
- establish research partnerships, collaboratives, and cooperative agreements,
- conduct workshops and seminars on grant writing and administration,
- negotiate and manage intellectual property (IP) rights which include patents, copyrights, and publication agreements,
- administration of research grants, contracts, and cooperative agreements,
- disseminate information via RSP website on availability and deadlines for external funding opportunities in research,
- manage technology transfer, commercialization, and licensing of University’s IP, and
- review proposals for research and fiscal compliance which includes budget review and negotiation of indirect costs.
- 205.00 THE ORGANIZATION OF THE DIVISION OF RESEARCH AND SPONSORED PROGRAMS
- 210.00 RESEARCH AND SPONSORED PROGRAMS STAFF
- 215.00 RESEARCH COMMITTEES
205.00 THE ORGANIZATION OF THE DIVISION OF RESEARCH AND SPONSORED PROGRAMS
The Division of Research and Sponsored Programs consists of a vice president, director, research and technology specialist, program director of fiscal affairs, research compliance coordinator/officer, program development specialist, technical grant writer, contracts specialists/manager, technology transfer and licensing manager, and a biomedical faculty liaison. RSP works closely with Business and Finance and Technology and Administrative Services in the administration of grants, contracts, and cooperative agreements through purchasing agents and financial analysts that indirectly report into RSP. The RSP staff directory and organizational chart can be found at RSP website.
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210.00 RESEARCH AND SPONSORED PROGRAMS STAFF
210.05 Vice President
The Vice President for Research and Sponsored Programs is the academic officer responsible for the vision, direction and guidance of the University's research mission, policy formulation, and oversight related to the research process and education/training in the responsible conduct of research and creative thinking. The Vice President for Research and Sponsored Programs promotes the creation of a university environment that strongly encourages and supports faculty to move towards the forefront of knowledge as educators and on the leading edge of research as investigators. The Vice President for Research and Sponsored Programs is also responsible for patents, copyrights and technology transfer arising from inventions and discoveries by the faculty, research associates and adjunct professors of the University. All research centers and institutes report to the Vice President for Research and Sponsored Programs who reports directly to the President of the University.
210.10 Director
The Director of RSP develops procedures for implementing the policies set forth by the Vice President for Research and Sponsored Programs and is responsible for supervising the day-to-day office operations and staff. The Director assists in development of research plans for Research and Sponsored Programs staff and selected faculty, reviews proposal content and budgets, converses with various federal agencies on program announcements, active grants, contracts and cooperative agreements. This person manages university funded faculty incentive and research development initiatives, oversees university compliance committees on biohazards, human subjects, animal care and use, and intellectual property; and serves as a liaison between funding agencies and University staff. He/she provides oversight of research budgets, requests and negotiation of F&A/indirect cost rate reductions or waivers, approval of all matching funds (in-kind or cash), management of sponsored accounts, including federal related accounts as well as identifies funding sources to underwrite the University’s research objectives. The Director manages grant proposal development for the University including the oversight of the design, content and technical maintenance of the RSP web site and the evaluation of campus Centers, Schools, Colleges, Institutes, and Departments for planning of pre-award efforts for achieving the University’s funding goals.
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210.15 Program Director of Financial Affairs
The Program Director of Financial Affairs (PDFA) is responsible for proper management and administration of all grants and contracts and serves as a liaison between RSP and Grants Accounting. The PDFA works closely with the PI by assisting them in setting up accounts, making purchases, monitoring the rate of spending, recycling of funds, making reports, and closing out accounts. The PDFA is also responsible for all equipment purchased with federal funds and supervises Time and Effort certification for federally funded projects. Other responsibilities include preparing financial data for RSP reports and supervising the proper handling of documents that route through the division such as PAR forms, appointment recommendations, travel requisitions, etc. Additionally, the PDFA is responsible for managing RSP accounts.
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210.20 Proposal Development Specialist
The Proposal Development Specialist (PDS) is responsible for providing pre-award services and technical assistance to the faculty, staff and research associates; assist with proposal preparation and review, facilitate routing of proposals through endorsement and approval process; act as a liaison between RSP, principal investigators, university administration, and funding agencies. The PDS assists in program development to facilitate new research initiatives and maintains an electronic database for tracking pending proposals and funded projects.
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210.25 Specialist in Academic/Research Contracts
The Specialist in Academic/Research Contracts (SARC) for initiating and pre-approving all grants, academic/research contracts, cooperative agreements, and subcontracts for faculty and staff. The SARC works closely with faculty in developing the statement of work, generating a cost proposal, assisting with negotiating the terms and conditions of the contract, payment method and all other aspects of contract preparation. In addition, the SARC assists the faculty and staff with proper management and administration of all contracts throughout the duration of the projects by providing assistance with renewals, no-cost extensions, modifications and other contract management issues.
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210.30 Technical Grant Writer
The Technical Grant Writer (TGW) is responsible for assisting the Director of Research and Sponsored Programs in the training of the faculty and staff to write winning proposals. The TGW will assist the faculty and staff in taking a good idea in a specific area and developing it into a solid proposal. The main focus of the TGW is to edit and review all proposals for coherence, grant format, style, sponsor guidelines, budget and budget justifications, grammatical errors, spelling errors and syntax before grant application is submitted to the sponsor.
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210.35 Administrative Secretary
The Administrative Secretary (AS) performs administrative and secretarial functions for division. The AS is responsible for performing daily office functions and services such as coordinating routing of proposals, awards and other incoming documents for the division. The AS provides information regarding status of documents routed through the division.
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210.40 Compliance Coordinator
The Compliance Coordinator of RSP is responsible for coordinating the Animal Care and Use Committee, Biosafety Committee and Radiation Safety Subcommittee, Human Subject Committee, and the Research Integrity Committee.
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210.45 Biomedical Faculty Liaison
The Biomedical Faculty Liaison (BFL) is responsible for finding funds for faculty, research associates, post-doctoral fellows, and graduate students conducting biomedical research at TSU. The BFL manages the NIH EARDA grants, a project funded by the NIH, which is designed to encourage faculty to engage in biomedical research. The grants provide “seed money” for the faculty to conduct pilot research projects. (Click to go back)
215.00 RESEARCH COMMITTEES
Research at Tennessee State University has become an important part of the overall mission, goals, and objectives of the University. To ensure that research operations are efficient and in compliance with Federal, state, and local regulations, several research committees were established to advise the Office of Sponsored Research on its research and sponsored program activities. The Biosafety Committee, Radiation Safety Sub-Committee, Human Subjects Committee, and Animal Care and Use Committee approve all research involving hazardous materials, human subjects, and experimental animals. The Research Council advises RSP on policies and procedures governing the research programs at the University. The committees are:
- Research Council
- Institutional Review Board/Human Subjects Committee
- Biosafety Committee
- Radiation Safety Subcommittee
- Research Integrity Committee
- Animal Care and Use Committee
The purpose of the Research Council is to advise the Division of Research and Sponsored Programs in developing realistic goals, procedures governing the research programs, and new research initiatives at the University. The Committee reviews policies and procedures, makes appropriate recommendations and follow-ups to ensure adequate implementation on relevant issues.
The membership of the Research Council, as appointed by the VP of RSP, include the deans or their designee from various academic units, the directors of the research units, VP of RSP, selected members of the RSP staff, the VP of Business and Finance or designee, selected principal investigators, representatives from industry, government agencies, and other universities. The Research Council will meet at least quarterly or as needed.
See section 500.00 COMPLIANCE POLICIES for a detailed description of the roles and responsibilities of the remaining committees.
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300.00 FUNDING SOURCES
The University receives funding for research and sponsored programs from Federal agencies, corporations, small businesses, and private foundations. RSP will assist potential PIs in the earliest stages of the proposal by identifying potential sponsors for the project. The PI may access an enormous amount of information from the RSP website. RSP maintains webpage addresses, reference books, application kits, reports, electronic databases, guidelines, directories, and newsletters from federal, state, local and private agencies for PI information and use. A primary resource for funding sources is the Community of Science website, www.cos.com. This website contains information relating to funding for many disciplines including arts and sciences, social sciences, humanities as well as basic science and engineering. More information can be found on the RSP website.
(Click to go back)400.00 PROPOSAL DEVELOPMENT
All academic grants, contracts, and cooperative agreements are managed by the Division of Research and Sponsored Programs. The elements of a proposal generally include title page, abstract, project description, budget narrative, and appendices. The project description should clearly define the purpose, significance, objectives, methods, evaluation plan, and anticipated outcomes. PIs are encouraged to review and consult proposal guidelines from the funding agency for each proposal.
405.00 QUALIFICATIONS OF A PI/PD
Before a PI writes a competitive research proposal or a demonstration project for extramural funding, it is critical that the PI has a well-conceived idea that falls within his or her area of expertise. Competency in an area of expertise must be supported by the PI’s level of education, relevant experience, familiarity of the literature in the area of interest, and peer-reviewed publications and presentations. The PI should have an excellent research reputation in order to be seriously considered by external review panelists. It must be clear that the proposed PI has the ability and capacity to implement the proposed research project or activity. Some important components of qualified PIs or PDs are listed below:
- Earned degrees, dates, and institutions(s)
- Grants, contracts and cooperative agreements received
- Employment status at the University
- Recent refereed publications with relevance to proposed project
- Refereed presentations
- Research interests and teaching experience
410.00 PROPOSAL CONTENT
For the most part, each sponsor or funding agency will define specific requirements and guidelines for proposal components and content. In general, a solid proposal, based on a well-conceived idea, implementation plan and current knowledge in the field, will assume the following format:
- Cover Sheet
- Certification Pages (usually federal)
- Table of Contents
- Project Summary
- Project Description
- Evaluation
- Biographical Sketches
- References
- Budget
- Appendices
The principal investigator or project director should use a checklist that is relevant to the proposal. An online proposal checklist can be found on the RSP website.
410.05 Cover Sheet
Each federal or private sponsor usually provides its own cover sheet. Cover sheets normally consist of information about the applying institution such as its name, PIs name, funds requested, project duration, name of institutional representative, address, telephone, fax, e-mail, name of the project, and signatories. Only the President or the Vice President of Research and Sponsored Programs may sign as the authorized representative of the University on the cover sheet. The proposal preparation fact sheet provides much of the information requested about the University on agency coversheets and can be found on the RSP website.
410.15 Certification Pages
Federal agencies require that all PIs and Co-PIs certify by checking appropriate boxes on drug free workplace, lobbying activities, and debt/debarment and suspension by signing specific certification forms. The institutional representative must certify that statements contained in the proposal are true and complete to the best of his or her knowledge, and that the institution agrees to accept the obligation to comply with award terms and conditions. It is further required that the institutional representative certify that the University has implemented and is enforcing a policy on conflicts of interest. Only the President or the Vice President of Research and Sponsored Programs may sign as authorized representatives of the University.
410.20 Table of Contents
All solid proposals should contain a useful table of contents. It should point to each major topic in the proposal as well as important minor topics.
410.25 Project Summary
The solid proposal must contain a one page project summary of the proposed activity written in the third person and suitable for publication. The project summary should not be an abstract of the proposal, but rather a self-contained summary of the activities to be undertaken. It should contain project objectives, methods to be employed, anticipated outcomes and the significance. The project summary, for the most part, is usually written for a broad audience. Abstracts may be used instead of a project summary when appropriate and required by sponsoring agencies.
410.30 Project Description
The main body of the proposal should be a clear statement of the work to be undertaken. It should include the following:
- Objectives for the period of the proposed work (preferably measurable)
- Significance of proposed project
- Review of current knowledge in the field of study in which the application is made
- Work plan including project design of activities to be undertaken
- Description of experimental methods and procedures
Projects that involve collaborations or partnerships must be fully described and documented with an official letter from each collaborator or partner in this section of the proposal and reflected in the budget.
410.35 Evaluation
The purpose of an evaluative scheme is to determine whether the objectives of proposed project have been met. In general, formative evaluation will be used to monitor the day to day implementation of the project. Summative evaluation is normally employed to determine the final outcome of the project. For more information, contact the RSP staff.
410.40 References
All references should come from peer-reviewed journals (if at all possible). Citations must be complete, including full name of all authors, publication name, title and page location.
410.45 Biographical Sketches
The biographical sketch of the PI should contain information or document on his or her expertise in a specific area. It should also contain the overall qualification of the PI to conduct the proposed research or training program. Important components of a biographical sketch are listed below:
- Earned Degrees,
- Dates of Earned Degrees,
- Academic Institution(s) in which degree(s) were earned
- Grants and Contracts Received (include agency, brief project description and the dollar amounts)
- Recent Refereed Publications with relevance to proposed project,
- Refereed Presentations
- Research Interests and Teaching Experiences
410.50 Budget Development
The cost elements of a budget must correlate well with the objectives outlined in the project description. Cost estimates of individual line items should be carefully calculated so that the requested funds are adequate, but not excessive. Many proposals require cost sharing or matching funds to be included in the budget. Cost sharing may be either in the form of cash payments or special services provided by the University. A good budget always contains budget details, summary, and justifications. The budget falls into two broad categories: Direct Costs and Indirect Costs (Facilities and Administration or simply F&A).
Direct Costs
Direct costs usually include salaries and wages, fringe benefits, equipment, travel, participant support, and other direct costs.
A. Senior Personnel Costs
This section includes principal investigators, co-principal investigators, research faculty, project directors, and other senior research associates. The senior personnel may add an inflation factor of 3% to the base salary charged to the grant.
No extra service pay or any compensation may be paid from a sponsored project unless it is specifically identified as such and requested from the agency in the proposal and approved. Summer salaries for senior personnel shall not exceed 33% of the academic salary unless it is restricted by the funding agency.
B. Other Personnel Costs
Other personnel costs consist of post-doctoral associates, technicians, computer programmers, graduate students, undergraduate students, and secretarial/ clerical persons. Use current salary figures adding 3% inflation factor for post-doctoral fellows, technicians, computer programmers, and clerical/ secretarial persons. If these positions are new, contact the Director of Human Resources to establish an approximate grade and salary. Contact the Dean of the Graduate School for information on wages for graduate students.
C. Fringe Benefits
Fringe benefits include social security (FICA), retirement, unemployment, and insurance. The fringe benefits for full time principal investigators, project directors, faculty, computer programmers, clerical/secretarial persons, technicians and other non-student employees are 24% of salary and wages (for part-time 7.65%). Twenty four percent is established as a minimum for benefits. When a funding agency allows for a higher rate, the higher rate may be charged.
For graduate students and undergraduate students, the fringe benefits are 0%.
D. Equipment
Equipment at the University is defined as an item of property that has an acquisition cost of $5000.00 or more with a service life of more that one year. Items valued at less than $5000.00 are considered supplies.
E. Travel
Allowable travel must adhere to OMB Circular A-21 and TSU policy. It includes professional meetings, travel for consultation, field work, project director’s meetings, relevant workshops, and visits with directors and managers at Federal agencies. There are two broad kinds of recognized travel at the University, domestic and foreign:
- Domestic Travel: Travel within the continental United States is considered to be domestic. Domestic travel includes air (economy) and ground (car, rail, bus, and taxi), lodging, food (per diem), and parking.
Per diem rates, mileage rates, lodging limitation rates for in-state and out-of-state are available in the Division of Business and Finance. Information may also be obtained from the TSU Travel website.
- Foreign Travel: All foreign travel must be approved by the President of TSU and the Tennessee Board of Regents. Proposals that involve foreign travel are non-standard. All persons on foreign travel must include adequate insurance for coverage of accidents, sickness, and death. Refer to the TSU Travel website for more information concerning foreign travel.
F. Participant Support Costs
This budgetary category refers to costs of transportation, per diem, stipends, and other related cost for participants or trainees (participants or trainees are not employees) in connection with conferences, meetings, training activities, and workshops. Indirect costs are not generally allowed for trainees and consultants.
G. Other Direct Costs
Other direct costs include materials and supplies, publications, subcontracts, consultants, computer services, all communication costs, repair, and maintenance.
Materials and Supplies
The budget should indicate in general terms the type of expendable materials and supplies that are required, with the estimated costs. All materials and supplies must be in compliance with OMB Circular A-21.
Publications
The budget may request funds for the costs to document, prepare, disseminate, and publish the findings from the research activity.
Subcontracts
Collaboratives or research partnerships may include closely related and coordinated activities with another institution. The intent to enter in such an arrangement with another institution(s) should be fully disclosed and detailed in the proposal. These arrangements may result in a subcontract.
Consultant Services
This category consists of services rendered by others to Tennessee State University. It includes consultant and professional services, honoraria, and speaker fees.
Computer Services
The cost of computer services, including computer-based retrieval of scientific, technical and educational information as well as telecommunication services.
Communications
This budget category includes telephone, facsimile, postage, advertising, data lines, and associated costs.
Repairs and Maintenance
This section includes costs for maintaining property such as maintenance contracts, computers, photocopiers, and other office equipment.
Indirect Costs (Facilities and Administration or F&A)
Indirect costs are those that are incurred in conducting research and sponsored program activity at an educational institution. At Tennessee State University, the Department of Health and Human Services negotiated and approved indirect cost rate (F&A) is 49% of base salaries and wages on-campus and 19.5% for off-campus (>75% of work conducted off-campus). This rate can be applied to all grants that require the use of a negotiated indirect cost rate. In some cases, private foundations and corporations may allow the use of a rate based on the actual cost of research administration that is higher than the negotiated indirect cost rate. Please contact RSP if there are questions concerning the indirect cost rate. Refer to the RSP website for additional information and to verify the current negotiated indirect cost rate.
420.00 PROPOSAL ROUTING AND APPROVAL FORM
All PIs are required to complete a Proposal Routing and Approval Form (RSP Proposal Routing Form). The form should be completed in its entirety prior to submission of the proposal to RSP for authorization and final approval. The Proposal Routing and Approval Form provides pertinent information concerning the proposed activity and the resources required to complete the project. A copy of the proposal should be attached to the approval form; in addition, an electronic copy of the proposal should be forwarded to RSP as a MS Word document or Adobe Acrobat pdf file. The department head and dean must complete the required information, review and approve the approval form before forwarding to RSP. The proposal approval form must be completed, approved and transmitted to RSP at least five working days prior to submission deadline.
Prior to writing the proposal, the PI should contact RSP to obtain guidance concerning the proper forms and the formatting specifications. The PI may also obtain forms from the RSP website. The important checklist should generally include:
- Cost sharing contributions and percentages
- Appendix materials allowable
- Maximum budget allowed
- Special budget forms and application checklist
- Table of contents requirements
- Indirect costs (F&A) allowed and percentages
- Special assistance forms and required format
- Prior approval signatures
- Mailing address for proposals
- Application deadline (postmarked or received)
- Minimum and maximum of proposal pages per section
- Number of copies required
- Project duration (number of years of support allowed by sponsor)
430.00 Proposal review, Approval and Submission
Prior to submission and institutional approval, all proposals should be reviewed by the PI’s department head/director, dean and a Proposal Review Panel (PRP). Details of University’s proposal review, approval and submission process are explained in the sections below. The process is graphically depicted the Proposal Routing and Review Flowchart.
After obtaining the required information and signatures of the department head and dean, a proposal packet should be submitted to the Division of Research and Sponsored Programs (RSP) no less than 5 business days before the proposal deadline. The proposal packet should contain the following items.
- Proposal routing form
- Agency coversheet
- Proposal narrative
- Proposal budget
- Agency certification and assurance forms
- Approval of appropriate compliance committee(s), if required
- Letters of University endorsement (if applicable)
Only complete packets will be considered for RSP review and VP RSP signature. Incomplete proposal packets will be returned to the PI before processing.
430.05 Review by Department Head/Director
To process a proposal, the PI submits the proposal to the department head/director for review and approval. Since the head/director is charged with directing the PI’s efforts at the University, this is a critical step in the proposal review and approval process. The review will focus on the following:
- the substance of the proposal, including the academic appropriateness and desirability of the proposed research or other sponsored activity;
- commitments of faculty and staff time, and their possible effects on the teaching and other obligations of the personnel involved (not to exceed 100% effort);
- salary arrangements (e.g., provision for summer support or a distribution of effort supported during the academic year);
- proper identification of proprietary information;
- requirements for space and facilities;
- the budget, especially a verification that all costs, including indirect costs, are provided for, that all needs are realistically estimated and stated, that items included are in compliance with the policies of the University and the sponsor, and that cost sharing funds are available when indicated in the proposal; and
- the identification of special conditions requiring review, such as the use of human subjects, biohazards, radioactive materials, etc. (If applicable, the proposal is sent to the appropriate committee for simultaneous review).
Once approved within the department/center, the proposal is forwarded to an Proposal Review Panel (PRP). The roll of the PRP is described below.
430.10 Proposal Review Panel
The purpose of the PRP is to ensure that all proposals have merit and are well written. Also, in the event that a dean, director or department head refuses to approve a proposal, members of the PRP would serve as mediators between the PI and administrator.
Each department of a school, college or center of the University should establish its own PRP. Small schools, colleges or centers may wish to have only one PRP. Each PRP should meet regularly to review proposals and to promote scholarly activity among faculty and staff. However, special call meetings can be held to address urgent matters or to meet impending deadlines.
A good proposal has, as its core, a good idea. It must be innovative, forward-looking and creative as well as address a specific need. In a research proposal, the "good idea" must emanate from good science, education, engineering or technology. It normally takes considerable time and effort to transform a good idea into a solid proposal. A solid proposal is a document with sponsor-oriented structure. It should describe the "WHAT," "WHY," "HOW," "WHEN," and "WHO." Each panel member should address the intellectual merit of the proposal via the following queries:
- How important is the proposed activity to advancing knowledge and understanding within its own field or across different fields?
- To what extent does the proposed activity suggest and explore creative and original concepts?
- How well conceived and organized is the proposed activity?
- Is there sufficient access to resources?
In addition, panel members may also consider the following to address the broader impacts of the proposed activity:
- How well does the proposed activity advance discovery and understanding while promoting teaching, training and learning?
- How well does the proposed activity broaden the participation of the underrepresented groups (e. g. gender, ethnicity, disability, geographic locations, etc.)?
- To what extent will it enhance the infrastructure for research and education, such as facilities, instrumentation, networks, and partnerships?
- Will the results be disseminated broadly to enhance scientific, educational, and technological understanding?
- What are the benefits of the proposed activity to society?
- What is the potential for commercialization and creation of intellectual property assets?
430.15 Compliance Committee Review
If applicable, proposals are forwarded by the department head/director to the appropriate compliance committee for review. Approval must be obtained from a compliance committee before it is forwarded to the VP RSP for signature. In the interest of expediency, the compliance committee review takes place simultaneously with other steps in the review and approval process (see Proposal Routing and Review Flowchart). Section 500 contains detailed information on the role and activities of all University committees.
430.20 Review by Dean
After receiving approval from the department head, proposals are forwarded to the college dean. The dean’s approval is required to insure that the proposal is in keeping with the goals and objectives of the college. In the event that a dean is inclined to reject a proposal, members of the PRP would serve as mediators between the PI and the dean.
430.25 Review by RSP Staff
After obtaining the required information and signatures of the department head and dean, a proposal packet should be submitted to the Division of Research and Sponsored Programs (RSP) no less than 5 business days before the proposal deadline. The proposal packet should contain the following items detailed in section 430.00.
The RSP staff review is conducted to insure that all proposals are in compliance with University guidelines for externally funded projects. Additionally, the RSP review emphasizes fine tuning elements of the proposal that may have been overlooked by previous reviews. Without refinement a technically outstanding proposal may not be funded.
The RSP review focuses on the following.
- Abstract - More reviewers read the abstract than the proposal itself. Great care should be given to its preparation; its importance cannot be overrated.
- Format - A clean, flawless format facilitates a professional evaluation of the science and relevance of the proposal, and prevents diversion by trivial considerations (e.g., typos, format errors).
- Clarity and Consistency - Proposals that are too general, too ambitious, or unfocused with unclear objectives and unfounded hypotheses or work plans draw the most common criticism.
- Document Details - Relatively minor matters such as poor spelling, low grade typing and copying, inadequate exposition, and incorrect citations of the literature are common weaknesses that are viewed unfavorably.
430.30 University Authorization
All proposals must be signed by an official authorized to sign on behalf of the University. The signature of the authorized official is necessary to indicate University endorsement of, and commitment to, the project. In many cases this authorization certifies compliance with federal regulations. In other cases the authorization represents pre-acceptance of terms and conditions of the award.
The Vice President of Research and Sponsored Programs is the authorized institutional official for TSU. Please use the name and information below when referring to the authorized institutional official for all grant proposal cover pages, certifications, etc.
Dr. Marcus W. Shute, P.E.
Vice President for Research and Sponsored Programs
3500 John A. Merritt Boulevard
Nashville, Tennessee 37209-1561
Phone (615) 963-7631
FAX (615) 963-5068
E-Mail Address: research@tnstate.edu
430.35 Submission to Agency
Once a proposal has been signed by the VP RSP, it is ready for submission to the funding sponsor. It is the responsibility of the PI to duplicate and mail proposals. The number of copies of a proposal required by sponsoring agencies varies. In addition to the original to be submitted to the sponsor, one copy is required for the official University file maintained by RSP. If in doubt, the PI should contact the sponsor to determine the number of copies required if the guidelines do not give specific instructions.
To ensure timely proposal submission, the PI should be aware of what type of deadline the sponsor has indicated.
- A receipt deadline is the date by which the sponsor must receive the proposal.
- A postmark deadline means that the proposal must be postmarked by that date, not necessarily received by the sponsor.
In most instances a proposal will not be considered if it misses the agency deadline. To meet a critical deadline, familiarity with the available express courier services will facilitate timely proposal submission.
430.40 Electronic Submission of Proposals
An increasing number of funding agencies require electronic submission of proposals. Electronically submitted proposals are subject to the same University review and approval process as paper proposals. Proposals should not be transmitted to the sponsor until the University review and approval process is complete – this includes obtaining the signature of the VP RSP on the TSU Proposal Approval form. Each sponsor has a different procedure for electronic submission. Please consult the agency’s web site for submission instructions.
500.00 COMPLIANCE POLICIES
The Compliance Coordinator of RSP is responsible for coordinating the Institutional Animal Care and Use Committee, Biosafety Committee and Radiation Safety Subcommittee, Institutional Review Board/Human Subject Committee, and the Research Integrity Committee. The Research Compliance Committee members are recommended by the Director of RSP to the Vice President for Research and Sponsored Programs. Compliance issues involving the Office of Management and Budget (OMB) and its Circulars, particularly, Circular A-21, A-110 and A-133 are summarized.
- 505.00 HUMAN SUBJECTS COMMITTEE/ INSTITUTIONAL REVIEW BOARD
- 510.00 BIOSAFETY COMMITTEE
- 515.00 ANIMAL CARE and USE
- 520.00 RESEARCH INTEGRITY COMMITTEE
- 530.00 OFFICE OF MANAGEMENT and BUDGET (OMB) CIRCULARS
- 535.00 OMB DEFINITIONS OF RESEARCH and INSTRUCTION
- 540.00 OMB DEFINITION OF UNALLOWABLE COSTS
- 545.00 OMB DEFINITION OF ALLOWABLE COSTS
- 550.00 COST ACCOUNTING STANDARDS
- 555.00 DISCLOSURE STATEMENTS
505.00 HUMAN SUBJECTS COMMITTEE/ INSTITUTIONAL REVIEW BOARD
The University adheres to 45 CFR 46, Protection of Human Subjects, as amended by federal policy, effective August 19, 1991. These Federal regulations require the University to submit to the funding agency a statement of specific assurance for each research proposal involving human subjects. It is therefore required that each proposed project seeking funds from a external agency involving human subjects be reviewed by the Institutional Review Board/Human Subjects Committee, except where expedited review procedures are implemented by the Chair of the Human Subject Committee or the Compliance Coordinator of RSP. Expedited review procedures may be carefully used only when:
- Some or all of the research appearing on the list and found by the reviewer to involve no more than minimum risk.
- Minor changes in previously approved research during the period of one year or less for which approval is authorized.
The Human Subjects Committee has the authority to suspend or terminate approval of research that is not being conducted in accordance with the Human Subjects Committee’s requirements or that has been associated with unexpected serious harm to subjects. In the event of a suspension or a termination of approval, a statement indicating the justifications for such actions taken by the Human Subjects Committee will be issued to the principal investigator.
The general requirements for Informed Consent, where a human is used as a research subject, mandate that the principal investigator obtain the legally effective informed consent of the subject or the subject’s legally authorized representative. A principal investigator shall seek such consent only under circumstances that provide the prospective subjects or the authorized representative sufficient opportunity to consider whether or not to participate and to avoid the minimal possibility of coercion or undue influence on the subject. The information given to the subject or authorized representative must be in understandable language. No Informed Consent, whether oral or written, may include any exculpatory language through which the subject or the authorized representative is made to waive or appear to waive the subject’s legal rights or releases. Also, it must not appear to release the principal investigator, the sponsor, the University or its agents from liability for negligence (45 CFR 46.16).
The Human Subjects Committee shall prepare and maintain adequate documentations of committee activities, including the following:
- Copies of all research proposals reviewed, scientific evaluations, if any, that accompany proposals, approved sample consent documents, progress reports submitted by principal investigators, and reports of injuries to subjects
- Minutes of the Committee meetings which shall be sufficient in detail to show attendance at the meetings, actions taken by the Committee, votes on these actions taken including the number of members for, against, and abstaining. Minutes should contain the basis for changes in or disapproving the research, and a written record of the controverted issues
- Records of continuing review activities of Human Subjects Committee must be carefully filed
- Copies of all correspondence between the Committee and the PIs
- A list of the Committee members in detail as in section 46.103(b)(3)
- Written procedures for the Committee in detail as in section 46.103(b)(4) and 46.103(b)(5)
- The records required by this policy, shall be retained for at least 3 years after completion of the research. All records shall be accessible for inspection and copying by authorized representatives of the Office for the Protection from Research Risks (OPRR)
- Statements of significant new findings provided to subjects as required in section 46.116(b)(5).
In the event research is undertaken without the intention of involving human subjects, but is later proposed to involve human subjects in the research, the research project must be first reviewed and approved by the Human Subjects Committee, as provided by this policy, the research and certifications must be submitted by the University to the Office for the Protection from Research Risks (OPRR). Each Human Subjects Committee shall have at least five members with varying backgrounds to promote a complete and adequate review of research activities commonly conducted by the University. The Human Subjects Committee at the University, as required by 45 CFR 46, should have a community person, attorney, psychologist, and physician to deal with the varying array of human subjects research projects. The Committee usually meets twice per month to review research projects, and to participate in seminars and workshops on the protection of human subjects against research risks (See Clearance Form III). Call meetings are scheduled according to need.
510.00 BIOSAFETY COMMITTEE
The University conducts research and academic laboratory activities that involve the use of hazardous materials. These materials, if not properly used, stored, transported, and disposed of, may pose a risk to persons or the environment by virtue of their properties such as toxicity, corrosiveness, reactivity, flammability, infectivity, and others. It is the University’s position that it will adhere to 49 CFR 173. To be in full compliance with local, state, and federal regulations, TSU seeks to provide a research environment free from recognized biohazards and comply with agencies such as the Tennessee Occupational Safety and Health Administration (TOSHA), the Tennessee “State Regulations for Protection Against Radiation,” Department of Environment and Conservation (Division of Radiological Health), Occupational Safety and Health Administration (OSHA), and the Environmental Protection Agency (EPA). The Biosafety Committee includes the Radiation Safety Subcommittee, a special subcommittee designed to ensure the safe use of radioactive materials, radiation-producing equipment, and all uses of ionizing radiation within the confines of Tennessee State University. The Radiation Safety Subcommittee must have a Radiation Safety Officer (RSO) to provide expertise as well as training for the Subcommittee, the faculty and students who are involved with radiation research. The Radiation Safety Officer of the Subcommittee and the Compliance Coordinator of RSP are responsible for obtaining and maintaining a permit (license) to conduct research involving the use of radioactive materials. The Radiation Safety Officer is also required to conduct at least three workshops per annum (Fall and Spring semesters, and Summer) on radiation safety, storage, monitoring, and disposal.
The membership is minimally comprised of faculty representatives from the departments generally involved in the use of hazardous materials. The Committee usually meets on a quarterly basis or by special reviews on urgent proposals by electronic mail. The membership consists of six members plus the Chair and the Radiation Safety Officer. The duration for both memberships (Committee and Subcommittee) is four years.
515.00 ANIMAL CARE and USE
Federal regulations require that institutions using animals as research subjects must carefully monitor animal care and use. The University adheres to Subchapter A, “Animal Welfare” of Title 9 of the Animal Projects Act. The standards contained in the PHS/NIH Guide for the Care and Use of Laboratory Animals govern the use of animals in research and teaching at Tennessee State University. The Committee is charged with the responsibility of approving all studies and proposals involving experimental animals. Its functions include inspection of the facilities; evaluation of programs and animal activity areas; submission of reports to the Director of Research and Sponsored Programs; review of proposed uses of animals in research, testing or education; and establishment of a mechanism for receipt and review of concerns involving the care and use of animals at the University.
It is the responsibility of the Committee to oversee and evaluate the University's animal program, procedures, and facilities to ensure that they are consistent with the recommendations of the Federal Animal Welfare Regulations (referred to as AWRs - CFR 1085) and the PHS Policy. It is also the responsibility of the University through RSP to provide suitable orientation, background materials, access to appropriate resources, and if necessary, specific training to assist the members of the Animal Care and Use Committee in the understanding and the evaluating issues brought before the Committee. The Committee membership should be broadly comprised of diverse individuals from the community and the University. The Committee meets on a quarterly basis or by electronic mail as necessary. The Committee membership should include the following:
- A Veterinarian, who is certified with the American College of Laboratory Animal Medicine (ACLAM) or well versed in the use of the species in question,
- At least one practicing scientist who is experienced in research involving animals, and
- At least one public member to represent the general community’s interests in the proper care and use of animals. The public member should not be a laboratory animal user, affiliated with Tennessee State University, or members of the immediate family of a person who is affiliated with the University.
520.00 RESEARCH INTEGRITY COMMITTEE
To ensure research at Tennessee State University is conducted effectively, objectively and without improper influence or the appearance of improper influence, the Research Integrity Committee was established. This Committee is not required by the Office of Research Integrity, but serves a very useful purpose in meeting several PHS requirements on allegations involving scientific misconduct in research and other requirements by the Alcohol, Firearms and Tobacco (AFT) Organization. The Committee has oversight of all inquiries and investigations associated with allegations of scientific misconduct. Many queries involve questions of "honest differences” in interpretation or judgments of data, which are specifically excluded under the PHS definition (45 CFR 50,102). These inquiries and investigations on scientific misconduct include the following:
- Research Fraud
- Falsification
- Plagiarism
- Fabrication
- Other Serious Deviations
520.05 ACTION STEP I: INQUIRY OF RESEARCH MISCONDUCT
STRUCTURE
The inquiry process at Tennessee State University is handled by the Research Integrity Committee. It is the responsibility of the Committee to ensure that the inquiry is conducted in a fair and just manner. The members of the Committee must not have a conflict of interest involving the inquiry process. Members with conflicts of interests or the appearance of a conflict of interest must withdraw from the inquiry process.
Tennessee State University will consult with its legal counsel to minimize the risk of liability for actions taken in the conduct of the inquiry and investigation. The University will make clear any policies on providing legal help to complainants and respondents involved in the allegation.
PURPOSE
When an allegation or a complaint involving the possibility of fraud is made, the Chair of Research Integrity Committee will initiate the inquiry. In the inquiry stage, factual information is gathered and expeditiously reviewed to determine if an investigation of the charge is warranted. An inquiry is not a formal hearing; it is designed to separate allegations deserving further investigations from frivolous, unjustified, or clearly mistaken allegations.
PROCESS
Upon the initiation of an inquiry, the Committee is responsible for notifying the respondent within a reasonable amount of time of the charges and the process that will follow. It will depend upon the nature of the allegations and the evidence available whether or not a case can be reviewed effectively without the involvement of the complainant. Cases that depend specifically on the observation or statements of the complainant cannot proceed without the open involvement of the alleged principal investigator.
FINDINGS
The completion of the inquiry is marked by determination of whether or not an investigation is warranted. There must be a written documentation to summarize the findings. Some cases that can rely on documentary evidence may permit the complainant to remain anonymous. While it may be desirable to keep the identity of the complainant confidential during the inquiry phase, local laws that provide for open access to certain records may make such confidentiality impossible. During the inquiry, confidentiality is desirable in order to protect the rights of all parties involved.
When the inquiry is initiated, the respondent should be reminded of the obligation to cooperate by providing material necessary to conduct the inquiry. Due to the sensitivity of allegations of fraud, the University will make every effort to resolve all cases expeditiously. Deadlines will be established to facilitate the process.
THE INQUIRY PROCESS MUST BE COMPLETED WITHIN 30 DAYS (1986 PHS guidelines and 1987 NSF regulations). The PI may consult with the Compliance Coordinator in RSP, or download additional information on federal policies and procedures from the RSP website. The respondent should be informed by the Committee whether or not there will be further investigation. If there is a complainant, he or she should also be informed.
Allegations found to require investigation should be forwarded immediately to RSP who will then notify the agency sponsoring the research. If an allegation is found to be unsupported, but has been submitted in good faith, no further formal action, other than informing all parties involved, should be taken.
The proceedings of an inquiry, including the identity of the respondent, should be held in strict confidence to protect the parties involved. If confidentiality is breached, reasonable steps must be taken to minimize the damage to reputations that may result from inaccurate reports.
520.10 ACTION STEP II: INVESTIGATIONS OF RESEARCH MISCONDUCT
STRUCTURE
The Chair of the Research Integrity Committee may select ad hoc members to the Committee to participate in the investigative process to avoid conflicts of interest or the appearance of conflicts of interest of official members of the Committee. Regardless of the structure chosen, conflicts of interest must be examined scrupulously and any relationship with “parties to the matter” must be fully disclosed.
PURPOSE
An investigation should be initiated when the inquiry issues a finding that an investigation is warranted. The purpose of an investigation is to explore further the allegations and determine whether fraud has been committed. In the course of an investigation, additional information may emerge that justifies broadening the scope of the investigation beyond the initial allegations. The respondent should be informed when significant new directions of the investigation are undertaken. The investigation should focus on accusations of fraud (as defined previously) and materials of each case.
PROCESS
Upon receipt of the inquiry findings that an investigation is warranted, the Committee will initiate the investigation promptly while notifying both the complainant and the respondent of such investigation. All involved parties are obligated to cooperate with the proceedings in providing information relating to the case. All necessary information should be provided to the respondent in a timely manner to facilitate the preparation of a response. The respondent should have the opportunity to address the charges and the evidence in detail. The University’s policies and procedures will address the role of legal counsel in the investigation. The University’s policy requires that an investigation be conducted as expeditiously as possible. The Committee must complete the entire investigation of the case within 120 days to be in compliance with the PHS guidelines and NSF regulations. If the deadline of 120 days of investigation cannot be met, the Committee may request an extension from the Director, Research and Sponsored Programs through the Compliance Coordinator.
FINDINGS
The findings of the Committee should be submitted in writing to the Director, RSP. The respondent should receive the full report of the investigation. When there is more than one respondent, each shall receive all those parts that are pertinent to his or her role. All federal agencies, private foundations, or other entities initially informed of the investigation, must also be notified promptly. The University should retain the findings of the investigation in a confidential and secure file. Investigations into allegations of fraud may result in various outcomes, including:
- a finding of fraud,
- a finding of serious scientific misconduct short of fraud,
- a finding that no culpable conduct was committed, but serious errors were discovered
- a finding that no fraud, misconduct, or serious scientific error was committed.
Thus, an investigation of fraud may disclose evidence that requires further action even in those cases in which no fraud is found. Every effort should be made to prevent retaliatory action against the complainant if the allegations, however incorrect, are found to have been made in good faith. If the allegations are found to have been maliciously motivated, disciplinary actions may be taken against those responsible.
APPEAL/FINAL REVIEW
The University may chose to provide respondents with an additional appeals process at this point through a written appeal of the Committee’s decision. Appeals must be restricted to the body of evidence already presented, and the grounds for appeal should be limited to failure of the Committee to follow appropriate procedures in the investigation or arbitrary and capricious decision making.
New evidence may warrant a new investigation. The appeal should be filed promptly after a finding has been made. On some critical cases, after an appeal is concluded, the University through the Chair of the Committee may decide to have a final review done by the President or his designee. The decision of the review made by the President of the University is final.
DISPOSITION
The responsibility for determining the nature and severity of disciplinary action should be specified in the University’s policy. This may, but need not necessarily, be done through the University’s regular faculty disciplinary or grievance procedures. Many actions may be available to the University. They may include, but not limited to:
- Removal from the project
- Letter of reprimand and special monitoring of future work
- Probation
- Salary reduction
- Suspension
- Rank reduction
- Barred from University sponsored leaves
- Termination of Employment
- Ineligible for University Awards
- Termination of Research/ Training Incentive Pay
- Travel Restrictions
- Barred from Conducting Future Research Projects at TSU
Consideration in the process will also be given to the formal notification of other concerned parties not previously notified, such as:
- Funding Sources
- Co-authors, Co-investigators, and Collaborators
- Editors of Journals in which Fraudulent Research was Published
- State Professional Licensing Boards
- Professional Societies
- Criminal Authorities where Appropriate
- Other Colleges , Universities, and Corporations
The Committee meets on a quarterly basis to promote high standards of research integrity, make inquiries, and perform investigations on allegations of fraud in research at TSU. Special call meetings are held as often as needed to address urgent cases of research misconduct or fraud. The Research Integrity Committee also has oversight of research on ethical issues such as the use of controlled substances, research with racial overtones, and unauthorized human subjects experiments. All controlled-substances, including absolute alcohol, must be purchased through the Compliance Coordinator or the Committee Chair.
The membership consists of at least five regular committee members, a community person, an attorney, co-chair, the committee chair, and the Compliance Coordinator. The Vice President for Academic Affairs, Vice President of RSP, Director of RSP, and the Deans of Schools and Colleges are ex-officio members. All members, including the chair and co-chair, are recommended to the Vice President of Research and Sponsored Programs by the Director, RSP, for appointments up to four years.
The membership reflects broad expertise of tenured senior level faculty members from diverse backgrounds of research areas of specialization. They are the stakeholders of research and creative thinking at Tennessee State University. Ad hoc members are selected by the Chair or the Compliance Coordinator to serve on the Committee when special expertise is needed or conflicts of interest or the appearance of conflicts of interest exist within the regular membership.
530.00 OFFICE OF MANAGEMENT and BUDGET (OMB) CIRCULARS
The predominant mission of the Office of Management and Budget (OMB) is to assist the President of the United States in overseeing the preparation of the Federal budget, and to supervise its administration with the Executive Branch agencies. In an effort to formulate the President’s spending plans, OMB evaluates the effectiveness of agency programs, policies, and procedures. It also assesses the competing funding demands among agencies, and sets funding priorities. In addition, OMB oversees and coordinates the Administration’s procurement activities, financial management, information, and regulatory policies.
The OMB Circulars are identified by the letter “A” and a number. When an instruction in an OMB Circular is revised, the pertinent circular will be re-issued with the same number and a new date. There is a large number of OMB Circulars in existence at the Office of Management and Budget, which includes A-21, A-110, and A-133.
OMB Circular A-110 sets forth standards for obtaining consistency and uniformity among federal agencies in the administration of grants to and agreements with institutions of higher education. OMB Circular A-133 is issued pursuant to a Single Audit Act of 1984, P.L., 98-502, and Single Audit Act Amendments of 1996, P.L., 104-156. It sets forth standards for obtaining consistency and uniformity among federal agencies for the audit of State and Local Governments, and non-profit organizations expending federal awards. Although OMB Circulars A-110 and A-133 are important, only OMB Circular A-21 is directly applicable to most research, training and service (or outreach) issues of educational institution. A-21 supercedes Federal Management Circular 73-8, dated December 19, 1973.
The purpose of OMB Circular A-21 is to establish principles for determining costs applicable to grants, contracts, and cooperative agreements with educational institutions. The principles deal with the subject of cost determination and make no attempt to identify the circumstances or dictate the extent of agency and institutional participation in the financing of a particular project.
535.00 OMB DEFINITIONS OF RESEARCH and INSTRUCTION
Major functions of the University refer to instruction, organized research, other sponsored activities, and other institutional activities. The following Office of Management and Budget descriptions are summarized below:
535.05 OMB DEFINITION OF ORGANIZED RESEARCH
Organized research means all research and development activities of the University that are organizationally structured and separately budgeted and accounted for. It includes the following:
Sponsored Research
Sponsored Research means all organized research and development activities that are sponsored or funded by federal agencies or private organizations. This term includes activities involving the training of individuals in research techniques where such activities utilize the same facilities as other research and development activities, and where such activities are not included in the instructional category.
University Research
University Research includes all organized research and development activities that are separately budgeted and accounted for by the University under an internal application of institutional funds.
535.10 OMB DEFINITION OF INSTRUCTION
Instruction involves the teaching and training activities of the University. It includes all teaching and training activities, whether they are offered for credits toward a degree, certificate or on a non-credit basis; and whether they are offered through regular academic departments or separate divisions. Also, considered as a part of this major function, are departmental research, and in some cases, university research.
Sponsored Instruction and Training
Sponsored instruction and training are specific instructional or training activity established by grant, contract, or cooperative agreement. For purposes of cost principles, this activity may be considered a major function even though the University’s accounting treatment may include it in the instruction function.
Departmental Research
Departmental research means research, development and scholarly activities that are not organized research and consequently, that does not have a separate budget and account. Departmental research is not considered a major function, but a part of the instruction function of the University. For all practical purposes, departmental research at Tennessee State University is designed to train students the methods of research, and the ways in which scientists work and solve problems.
535.15 OMB DEFINITION OF OTHER SPONSORED ACTIVITIES
Other sponsored activities mean programs and projects financed by federal agencies and private organizations which involve the performance of work other than instruction and organized research.
535.20 OMB DEFINITION OF OTHER INSTITUTIONAL ACTIVITIES
Other institutional activities include all activities other than instruction, departmental research, organized research, and other sponsored activities.
540.00 OMB DEFINITION OF UNALLOWABLE COSTS
The costs listed below, whether direct costs or indirect costs, cannot be charged to the sponsored agreement on grants, contracts or cooperative agreements unless specially approved in such grant or contract, as outlined in OMB Circular A-21. The PI may obtain full information on this issue through the RSP website under Federal Regulations and Policies. The list includes:
- Advertising, Public Relations Costs, ALCOHOL, Alumni Activity Costs, Bad Debts, and Local Civil Defense Costs not on the University’s premises;
- Commencement and Convocation Costs;
- University Furnished Automobile Costs for Personal Use, Contingency Provision Costs, Defense and Prosecution of Criminal and Civil Proceedings, Claims, Appeals and Patent Infringement Costs;
- Depreciation Reserves Costs, Donations or Contributions, and Entertainment Costs (Includes amusement, diversion and social activities);
- Executive Lobbying Costs, Fines and Penalties (including late fees);
- Goods and Services Costs for Personal Use, and Housing and Personal Living Costs;
- Insurance Costs to Protect against Defects in the University’s Materials or Worksmanship, and Interests, Fund-Raising and Investment Management Costs;
- Loses on Other Sponsored Agreements, and Student Activity Costs;
- Membership Costs in Civic Clubs, Community Organizations, Country Clubs, Social or Dining Clubs or Organizations;
- Recruiting Costs for Help-Wanted Advertising, and Pre-Agreement Costs Prior to effective Date of Agreement;
- Selling and Marketing Costs of Products or Services of the University;
- Severance Costs in Excess of the University’s Normal Severance Pay;
- Specialized Service Facilities Charges in an amount more than an Aggregate Costs of Service over a Long-Term Period; and
- Airfare Travel Costs in Excess of the Lowest Available Commercial Discount Airfare or Customary Standard Coach Airfare
545.00 OMB DEFINITION OF ALLOWABLE COSTS
a) A cost is allocable to a particular cost objective if the goods or services involved are chargeable or assignable to such cost objective in accordance with relative benefits received or other equitable relationship. Subject to the foregoing, a cost is allocable to a sponsored agreement under the following conditions:
- It is incurred solely to advance the work under the sponsored agreement.
- It benefits both the sponsored agreement and other work of the University, in proportions that can be approximated through use of reasonable methods.
- It is necessary to the overall operation of the University and, in light of the principles provided in this Circular, is deemed to be assignable in part to sponsored projects. Where the purchase of capital items ( or equipment) are specifically authorized under sponsored agreement, the amounts thus authorized subsequently be made part of the capital items (or equipment) involved.
b) Any costs are allocable to a particular sponsored agreement under the standards provided in this Circular. Such costs may not be shifted to other sponsored agreements in order to meet deficiencies caused by overruns or other fund considerations, to avoid restrictions imposed by law or by terms of the sponsored agreement, or other reasons of convenience.
c) Any costs allocable to activities sponsored by industry, foreign governments or other sponsors may not be shifted to federally-sponsored agreements.
d) The allocation and documentation standard include the following:
- Cost Principles: The recipient University is responsible for ensuring that costs charged to a sponsored agreement are allowable, allocable and reasonable under these cost principles
- Internal Controls: The University’s financial management system shall ensure that no one person has complete control over all aspects of a financial transaction
- Direct Cost Allocation Principles: If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost should be allocated to the projects based on the proportional benefits. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then notwithstanding subsection b, the costs may be allocated or transferred to benefited projects on any reasonable basis, consistent with subsection d. (1) and (2) of this Circular.
- Documentation: Federal requirements for documentation are specified in this Circular, Circular A-110, “Uniform Administrative Requirements for Grants and Agreements with the Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations,” and specific agency policies on cost transfers.
550.00 COST ACCOUNTING STANDARDS
The Cost Accounting Standards Board (CASB) was established by Congress and currently located in the Office of Management and Budget (OMB) is authorized to promulgate and maintain standards to achieve uniformity and consistency in measuring and allocating costs to negotiated defense and civilian contracts and subcontracts.
Prior to January 5, 1995, educational institutions were exempt from cost accounting standards (CAS) as well as disclosure statements. Under this requirement, educational institutions receiving contracts in excess of $500,000 must be CAS-covered. There are four cost accounting standards applicable to educational institutions:
501) Consistency in Estimating Accounting and Reporting Costs
502) Consistency in Allocating Costs Incurred for the Same Purpose
505) Accounting for Unallowable Costs
506) Cost Accounting Period
555.00 DISCLOSURE STATEMENTS
Educational institutions receiving more than $25 million in a federally-sponsored agreement during their most recently completed fiscal year, must file CASB’s disclosure statement (DS-2). There are two types of disclosure statements:
Disclosure Statement 1(DS-1): DS-1 applies to Commercial Contractors
Disclosure Statement 2 (DS-2): DS-2 applies to Universities
The actual disclosure of the statement (CASB DS-2) is found in the OMB circular a-21. Each reporting unit is required to complete various portions of the casb ds-2. The CASB DS-2 is a 20- page document that provides a summary of an educational institution’s cost accounting system for federal grants and contracts. Download from the RSP website.