Intellectual Property The Handbook is currently under review. If you have questions, please contact your administrator. Accepting outside funding to conduct research in the name of The University of Alabama in Huntsville carries public and professional responsibilities. It is important that the University researcher and his/her support staff understand and adhere to the University's policies and procedures regarding sponsored project activity. What? This handbook is intended as an overview of information concerning The University of Alabama in Huntsville's policies and procedures for sponsored research proposal preparation and submission as well as post-award contract and grant administration. The printed version of this handbook provides copies of some of the referenced documents, policy statements and forms referenced in the text. It is advised that the Principal Investigator use the internet version, which contains links to all documents. It is located here in the UAH Principal Investigator Handbook and will have the most current information. Who? The primary users of this handbook are UAH research Principal Investigators, other research personnel, and the employees who provide administrative assistance and support to the research effort. When? Any individual contemplating a first-time proposal to request sponsored project funding should read this handbook PRIOR TO INITIATING THE PROPOSAL PROCESS. It should be consulted by any individual engaged in sponsored project activity at UAH as procedural questions arise. Why? Proposing and accepting an award under the auspices of The University of Alabama in Huntsville carries responsibilities. The University, the Principal Investigator, other University employees involved in the research, and research support staff effort share these responsibilities. The employees will be expected to conduct the research in a professional manner and charge the funding agency in accord with all relevant agency, Federal, State, and University rules and regulations. A proposal submitted in the name of The University of Alabama in Huntsville must be internally reviewed to assure that it meets the standards of the University and adheres to agency guidelines. To be an official proposal, it must be signed by a University official who is authorized by The Board of Trustees of the University of Alabama to commit the University. Awards received by UAH will be reviewed to ensure that the terms and conditions are acceptable to the Principal Investigator and to the University as an entity of the State of Alabama. What is a Sponsored Project or Funded Research? Most grants, contracts, cooperative agreements and other agreements from sources outside the university are considered "sponsored projects" or "funded research". If a project meets any of the following criteria, it is considered a sponsored project and should be coordinated through the Office of Sponsored Programs (OSP): the University is bound by a specific statement of work; invoices, separate accounts or reports of expenditures are required; unexpended funds must be returned to the sponsor at the project end; the funds are accompanied by an agreement with specific terms and conditions; Other indicators of a sponsored project might be: the project has a specific period of performance; a report or some other "deliverable" is required. Donations or gifts to the University which do not have any of the above criteria associated with the transaction should be coordinated through the Office of University Advancement. When in doubt, the sponsoring agency should be contacted for clarification of their intent. Responsibility for Sponsored Project Administration Although the sponsored project award is based on the Principal Investigator's experience and expertise, always remember that The award is a legal agreement made to the university for a specific purpose. The Principal Investigator must bear in mind that he/she is using University (public) resources to conduct the project. The key figures in the sponsored project process and their responsibilities are: Principal Investigator/Project Director is the person responsible for conducting the proposed project as contractually agreed by the University. This includes expending funds within the guidelines of the sponsoring agency and delivering required reports in a timely manner. In most cases, a Principal Investigator must be a full-time University employee. Vice President for Research and Economic Development is the chief research officer of the University and, under supervision of the President, provides overall executive leadership and coordination in the support and documentation of research in the academic departments and research units of the University. He is responsible for oversight of all sponsored programs in the University and for the management of resources and services required for the research operations. He is responsible for the Research Centers and the Center Directors report directly to him. The Office of Sponsored Programs reports to the Vice President for Research and Economic Development. Provost and Vice President for Academic Affairs is responsible for review and approval of any proposed sponsored effort involving academic courses at the University. They must also approve any cost sharing commitments from academic units. Vice President for Finance and Administration is responsible for many of the offices on campus that serve the research effort, including the Office of Finance and Budgets (Contracts & Grants Accounting and Accounts Payable), Computer & Network Services, Human Resources, Business Services (Purchasing and Central Receiving), and Facilities and Operations. The proposal/award process is divided into two phases: pre-award (proposal preparation through negotiation) and post-award (execution of the award document through contract/grant closeout.) Pre-Award What is a proposal? A proposal is a request for support, usually financial. The simplest proposal consists of a cost estimate. Normally, proposals have at least two sections—technical and financial. More involved proposals might have a separate management section. The technical section is a description of work to be performed including proposed goals or accomplishments, the items to be delivered to the agency ("deliverables"), and project milestones. The financial section is a calculated estimate of the financial resources necessary to accomplish the proposed goals. The two most basic proposal types are "solicited" and "unsolicited." A solicited proposal is submitted to a funding agency in response to an agency-issued request for proposal (RFP), request for quote (RFQ), or a program announcement. Solicited proposals generally have firm submission deadlines and require adherence to specific technical, management and cost guidelines. An unsolicited proposal results when a researcher develops an idea and formally requests funding to support the effort. Although an unsolicited proposal is not submitted in response to an agency funding announcement, many agencies do have specific format and submission guidelines for unsolicited proposals. A renewal proposal requests continued funding of an existing project which is nearing its funding limit. In most cases, this proposal is similar in content to the initial proposal and includes a full technical or cost section. These proposals are often considered competitive by the funding agency. A continuation proposal is usually non-competitive and is a request for the next year's funding under a multi-year award. In most cases, a continuation proposal consists of a budget (usually the original budget for that project year with the rates updated), a progress report and a brief statement of the next year's intended research. A revised proposal is submitted as the result of funding agency-university negotiation. Most agencies require a revised budget to reflect the final negotiated funding agreement. If the negotiated cost difference is ±10% of the original budget, it will be necessary to obtain UAH internal signature approval again. Proposal Approvals All university proposals must be approved by the Principal Investigator, Department Chairman (if proposed by a member of an academic department), Dean or Center Director, Vice President for Research and Economic Development and the Director of the Office of Sponsored Programs. Proposals with more involved cost or technical issues such as human or animal subjects, cost-sharing requests or security requirements will require additional approvals. The Principal Investigator should understand the requirements of the University's "Routing and Approval Procedures for Contracts and Grants" and should ensure that there is adequate time for each signer to review the complete proposal prior to signing. How to Submit a Proposal Proposals should be viewed as a team effort with each member contributing expertise to ensure a successful proposal resulting in a contract/grant award. The Principal Investigator contributes technical knowledge, expertise, and management planning to the proposal and provides the Contract Administrator (or Contracts and Grants Coordinator where appropriate) sufficient budget information to allow the Contract Administrator to prepare the budget in one of the standard university formats. The Contract Administrator contributes knowledge of the agency regulations as well as University policy and is the focal point for coordinating the various pre-proposal activities. As with any team, each member has specific responsibilities: Principal Investigator Eligibility Any individual who holds one of the following positions can be identified as a PI and submit proposals to external sponsors: tenure-track faculty (full, associate, and assistant professors) non-tenure track research faculty (full, associate, and assistant professors) non-tenure track clinical faculty (full, associate, and assistant professors) instructors adjunct faculty emeritus faculty senior research investigators librarians curators On a case-by-case basis, an individual who holds one of the following positions can be identified as a PI upon approval from the Vice President for Research and Economic Development: visiting faculty visiting scholars lecturers In general, research associates may not serve as PIs, but may seek approval from the Vice President for Research and Economic Development. Postdoctoral fellows and research assistants (graduate students) may not serve as PIs. Principal Investigator Notify the Contract Administrator or Contracts and Grants Coordinator as soon as you decide to submit a proposal and let him/her know if you are responding to an agency solicitation. Coordinate your proposal with your Chairman or Dean/Director before the proposal signature date. Cross-organizational commitments, fiscal responsibility and cost sharing issues must be resolved prior to finalizing the proposal. Provide the basis for the budget estimate to the Contract Administrator or Contracts and Grants Coordinator. Obtain vendor or catalog quotes for equipment items and proposals or letters of collaboration from proposed subcontractors or consultants. If cost sharing from a source outside the University is proposed, a letter of commitment from the cost-sharing source must be obtained. Prepare the technical and management sections of the proposal. Consult agency guidelines for format and page limits, and to ensure that all required elements have been addressed. Check the draft budget and convey any changes to the Contract Administrator or Contracts and Grants Coordinator. Approve the final budget and provide a final technical proposal and other proposal elements to the Contract Administrator for assembly of the complete proposal approval package. Budget and proposal should be in OSP five (5) working days prior to the date of submission. Oversee approval signature routing through the Dean/Director level and be available to answer questions that the signatories might have concerning your proposal. Inform the Contract Administrator if copies in addition to the usual courtesy copy are required. Contract Administrator or Contracts and Grants Coordinator Obtain a database proposal number and open a file. Obtain and study the agency solicitation guidelines and notify the Principal Investigator of any point that might require special attention. Provide advice on UAH policy if requested or required. Interface regularly with the Principal Investigator to ensure that you understand the budget requirements. Prepare the budget in accordance with University policy and agency guidelines. Convert the final, approved budget to agency budget forms, if required. Prepare other forms and certifications as required and assemble the full proposal approval package. Release electronic proposal Internal Coordination Sheet, transmittal letter and, if necessary, shipping package. Ensure that the Principal Investigator fully understands the implications of the fiscally responsible campus unit. Track the progress of the proposal as it routes through the signature approval cycle. Obtain the final approval signatures, reproduce the required number of copies and ship proposal. For electronic submission, ensure that electronic submission is on time. Confirm proposal arrival (mail or electronic) at the funding agency and log proposal information into the Office of Sponsored Programs database. Internal Coordination of Your Proposal The proposal preparation period is the time to coordinate the project objectives and needs with your Chairman/Dean or Center Director. They can provide guidance and concurrence during the planning process. Laboratory space, use of equipment or recharge centers, additional personnel, release time and cost sharing—both in-kind and cash—are all matters that require thoughtful planning and agreement. The University's proposal Internal Coordination Sheet documents the required approvals and summarizes the basic information about the proposal. The signatures required on the proposal Internal Coordination Sheet and, possibly, on the proposal come from the following individuals performing the functions listed: Principal Investigator certifies that he/she is responsible for this proposal and will conduct the research activities as stated in the proposal. Co-Investigator is a second UAH individual acting in a major contribution capacity. He/she should sign in the space indicated. If a named co-investigator is not a UAH employee, UAH requires certain documents from the Co-Investigator's institution. The individual will NOT be listed as a co-investigator on the proposal if we do not have these documents. Department Chair (if Principal Investigator holds an academic appointment) reviews the proposal for technical soundness and compatibility with the Department's plans. He/she also reviews and approves faculty time allocation and cost sharing requests. College Dean/Research Center Director determines if the proposed task, period of performance, and estimated costs are reasonable when considered for technical relevance and the plans and programs of the University. Provost/Vice President for Academic Affairs reviews and approves any proposal requesting funding for development of academic courses or programs involving teaching. Also, any academic department or college committing cost-sharing funds must coordinate with the Provost/Vice President for Academic Affairs. Assistant Vice President for Finance determines that the proposal conforms to the fiscal policies of the University Vice President for Research and Economic Development reviews technical and cost proposals for a determination of technical soundness and compatibility with the University's research program goals. He also approves all cost sharing commitments made by the Research Centers. Director of Office of Sponsored Programs certifies that the proposal conforms to the University and funding agency policies for contract/grant administration. The Director of Office of Sponsored Programs is authorized by The Board of Trustees of the University of Alabama System to commit the University in regard to research or service activities. NO PRINCIPAL INVESTIGATOR IS AUTHORIZED TO OFFICIALLY COMMIT THE UNIVERSITY. The Principal Investigator's signature on the Internal Coordination Sheet indicates agreement with and acceptance of the terms of the various funding agency-required compliance certifications. For each applicable certification checked, the signatories are also agreeing to abide by the terms of the certification(s). Cost Sharing Commitment The cost sharing commitment screen of the Internal Coordination Sheet is used when University resources are committed for a particular proposed effort. The category of funding committed (salaries, supplies, etc.), the amount committed and the source of the commitment should be documented. If cost sharing resources (cash or in-kind) are coming from an off-campus source, a letter from the source documenting the category of funding committed, amount, and source should be obtained by the Principal Investigator. Always remember that a contract or grant is awarded to the university, not to the individual principal investigator. Proposal Format Most funding agencies have standard formats for proposal preparation and these will be provided in their solicitations or general proposal guidelines. These instructions should be followed carefully. For agencies that do not provide guidelines, a suggested format is: Transmittal letter (usually not part of the formal proposal); Signature/title page; Technical abstract; Table of contents; List of tables and figures (optional); Introduction; Objectives; Procedures; Evaluation; Dissemination of results; Special test equipment and facilities; Personnel and management plan; Cost narrative (budget justification); Cost estimate and support documentation; Biographical data; References (sources cited); Appendices (to include letters or support or collaboration or reprints of professional publications). Funding agencies are becoming increasingly more restrictive of page length. It is, therefore, important that a Principal Investigator write a concise proposal that addresses the points required in the agency solicitation. Also, electronic submission of proposals is a growing trend with the Federal funding agencies. It is important that the Principal Investigator and his/her Contract Administrator understand the electronic and hard copy submission requirements well before the submission date. If an electronic submission system will be used for the first time, be sure to allow enough time to understand the way the system works. Electronic proposals must complete the same signature approval process as hard copy proposals PRIOR to the electronic submission. Planning a Project Budget A project budget should accurately reflect the Principal Investigator's best estimate of all costs necessary to complete the project as proposed. The Principal Investigator should be familiar with the University's Policy Regarding Charges to Grants and Contracts ("Cost Policy") which provides guidance relevant to charging direct and indirect costs to contract/grant accounts. The Principal Investigator might want to seek the advice of his/her peers, Department Chairman or Dean or Research Center Director as the budget is developed. When planning a budget, Facilities and Administrative Costs ("F&A" or "indirect costs") must be considered. In addition to the cost estimate part of the proposal (the numbers), a Principal Investigator should also prepare a budget justification or budget narrative section. This section provides important information for the funding agency as to the Principal Investigator's reasons for requiring certain cost items. The budget narrative is particularly important if the University is requesting direct charge of items which are normally charged as F&A costs. It is extremely important to work closely with the Contract Administrator to ensure that both understand the budget requirements and that they are accurately and clearly reflected in the proposal cost estimate section. Some common budget considerations are: Project start date and period of performance: These two factors affect the labor and tuition rates and, in some instances, the F&A rate. Merit raise escalation of salaries: The University's merit raise escalation takes effect on October 1st of each year. For the purposes of cost estimation, the present merit raise escalation rate of 5% of the prior year salary is used. Students do not receive merit raises. Percent of effort: The percent of effort of personnel required to accomplish the proposed project will determine the salary requirements. Be careful of over-commitment of effort. Agencies are starting to monitor and track committed effort. Graduate Research Assistants: Graduate Research Assistants (GRA) have several appointment levels based on academic milestones. Each academic department determines the salary range for the different levels and these figures can be obtained from the Dean of Graduate School. A GRA is usually not allowed to work in excess of 20 hours/week. Except for rare cases, a Graduate Teaching Assistant (GTA) cannot be charged to a research contract/grant and their charge to a departmental account cannot be used as cost sharing. Undergraduate Research Assistants: Undergraduate Research Assistants have hourly rates based on position type, class standing and years in the position. Current hourly rates can be obtained from the Office of Financial Aid. Undergraduate Research Assistants receive no fringe benefit compensation. Fringe Benefit Rates: Employee fringe benefits are calculated on all non-student faculty/staff salaries or wage. For proposal estimation purposes, a rate of 34% is used for all non-student employees. This rate is an average based on benefit program participation by sponsored program-funded individuals. The funding agency is invoiced for the individual's actual fringe benefit rate. Operating Costs: This cost category includes such items as laboratory supplies, page charges, travel, subcontracted services, publication costs, machine shop time, parts and materials, service center costs, etc. The cost estimate items should always have some basis for the amounts proposed, such as a proposal from a potential subcontractor, quotes from vendors or travel agents, established University rates (Machine Shop, recharge centers) or "based on prior experience." Travel: Travel in support of research is proposed and reimbursed in accordance with University regulations ("UAH Campus Implementation of University of Alabama System Travel Guidelines"). During the budget preparation, provide the Contract Administrator a list of the proposed trips citing the destination, purpose, length of trip, number of travelers and any out of the ordinary charges. Subcontracts, Consultants and Risk Accounts: Potential subcontractors or consultants should submit a proposal or cost estimate to the University in response to a request from UAH. As soon as it is known that a subcontractor or consultant will be involved, let your Contract Administrator know to give him/her sufficient time to obtain the proposal or cost estimate. If the proposed subcontract is not competitive and is in excess of $100,000, the Principal Investigator must provide a sole source justification using the form found at this link. F&A cost is charged on the first $25,000 of each subcontract. Any proposed cost sharing of subcontract F&A must have the prior written approval of the Vice President for Research and Economic Development. Machine Shop or Recharge Centers: The Machine Shop and the Recharge Centers operate on an hourly rate basis. Check with the Shop Supervisor or the person in charge of the appropriate Recharge Center for an estimate of cost for the task. Equipment: If possible, proposed equipment needs a written price quote or a copy of a catalog price. The equipment requirement should be clearly documented in the budget justification of the proposal. The dollar threshold for determining "equipment" at UAH is $5,000. Most funding agencies do not consider personal computers to be equipment unless it can be justified that the PC is special test equipment or part of a laboratory apparatus dedicated to the project. F&A (or indirect) costs are not assessed against equipment. Parts to Fabricate Equipment: If the Vice President for Research and Economic Development provides written approval, these items—parts for fabrication of a defined piece of equipment—can be proposed with no F&A costs. The cost items above (and others) are considered direct costs. Direct costs are "those costs that can be identified specifically with a particular sponsored project, an instructional activity, or any other [sponsored] activity" (OMB Circular A-21). Facilities and Administrative (or "indirect") Costs are assessed on specific direct costs. Facilities and Administrative Cost Recovery Rates: F&A Costs are calculated as an established percent of specific direct costs. This cost covers the facilities and administrative services necessary to support the research effort but which " … cannot be identified readily and specifically with a particular sponsored project, an instructional activity, or any other [sponsored] activity" (OMB Circular A-21). This cost includes such items as depreciation on equipment and buildings, operations and maintenance, general administration, departmental administration, sponsored projects administration and a portion of library costs. The rate is negotiated periodically with the Department of Health and Human Services. The Principal Investigator should let the Contract Administrator know if the effort will be performed on-campus or off-campus at a site provided by the funding agency. This will determine the correct F&A Cost rate. The off-campus rate does not include the "facilities" component because the funding agency is providing the facilities so UAH is not incurring that cost. Cost Sharing: In some instances, a funding agency requires the proposer to bear part of the cost of the project. The funding agency solicitation should be carefully reviewed to ensure that the cost-sharing restrictions are accommodated. All cost sharing commitments must have written documentation—the Internal Coordination Sheet for UAH funds and letters of commitment for external funds or in-kind commitments. Cost sharing commitments must be administered in compliance with the Cost Sharing and Matching Costs on Sponsored Programs Policy. Compliance Certifications The University is required to adhere to numerous laws and regulations regarding its legal and fiscal conduct relative to the research effort and must certify that it has policies and procedures in place to ensure compliance with these laws and regulations. In some instances, the certification is required at the time a proposal is submitted and, in other instances, the certification is required at the time of award acceptance or periodically during the award period. A Principal Investigator should be aware of the compliance requirements—in some cases compliance may require additional funding or may restrict who can be employed on the research effort—at the time he/she prepares the proposal. A brief overview of common compliance topics and UAH's policies and procedures follow: After-the-fact Time & Effort Certification: Any UAH employee charging time to a sponsored award account (or a corresponding cost sharing account) must complete a time and effort certification (lower left corner of the Biweekly Labor/Leave Report form) and submit a form for each pay period in which he/she charges to the account(s). This is required by OMB Circular A-21, Principles for Determining Costs Applicable to Grants, Contracts, and Other Agreements with Educational Institutions, section J.8.b.(2). Animal Care & Use: Any Principal Investigator proposing sponsored project research using vertebrate animals MUST receive project approval from UAH's Institutional Animal Care and Use Committee (IACUC). Instructions for submitting a project application to the Committee, a tutorial on the Public Health Service's Policy on Humane Care and Use of Laboratory Animals, and other useful information can be obtained at the link above. Conflict of Interest: According to UAH's Faculty Handbook, Section I, a conflict of interest exists when a University faculty member's [for the purpose of funded research activities, this requirement extends to all relevant employees] responsibility for teaching, research, or service is threatened or harmed because of an external relationship which directly or indirectly affects the financial interest of the faculty member, a family member or an associate. Any request for sponsored program funding (a proposal submitted through the Office of Sponsored Programs) must have a conflict of interest disclosure form completed by the Principal Investigator. If the Principal Investigator is issuing a subcontract under a sponsored program award, he/she must submit a conflict of interest disclosure form relative to the potential subcontractor. The University's policy and forms can be obtained at the link above. Some award documents may impose further conflict of interest requirements on the University and the Principal Investigator. These are addressed as part of the award acceptance process. Cost Policy: UAH's present cost policy is the result of requirements in OMB Circular A-21, Cost Principles for Educational Institutions. Every Principal Investigator should be familiar with the main points of the cost policy and should understand the difference between direct and indirect costs, their applicability to a project, and their allowability under the cost policy. The cost policy and the agency regulations govern expenditures on sponsored project awards. Cost Sharing and Matching Costs on Sponsored Programs Policy: Funding agencies sometimes require the University to share the cost of a project. As resources available to support cost sharing are limited, commitment of cost-sharing funds or in-kind goods or services should be carefully considered. The University's guidelines for consideration of cost sharing can be found at the link above. Upon award, a cost sharing commitment becomes part of the legal obligation of the University and the Principal Investigator is responsible for ensuring that all elements of the cost-sharing contribution are properly expended and documented for reporting to the funding agency. Expenditure and accounting of cost-sharing funds must be made in accordance with UAH's cost sharing policy. Debarment: In accordance with several Public Laws and Executive Orders, an individual, institution or firm that is debarred, suspended or excluded from doing business with the Federal, State or local governments cannot participate in government procurements or receipt of particular government monies. UAH's "Certification Regarding Debarment, Suspension and Other Responsibility Matters – Primary Covered Transactions" is signed by the Research Administrator on behalf of the University and the principal participants in the proposal. Every Principal Investigator should read this certification and understand that he/she has the responsibility to report any debarment situations to the Vice President for Research and Economic Development. Defense Priorities and Allocation System: Certain Federal and Federal pass-through awards have a priority code to ensure that they receive preferential acceptance and performance to support certain national defense and energy programs. An award with a "DX" or "DO" rating will contain a statement on the distribution "green sheet" instructing the Principal Investigator that all requisitions must have a "needed by" date on any requisition. The Purchasing Department assigns priority status to these requisitions. Drug-Free Workplace: The University is subject to the Drug-Free Workplace Act of 1988 and maintains a policy to ensure compliance with the Act. All UAH employees are bound by this Policy. Proposals to Federal agencies must contain a certification that the University complies with this Act. Federal contracts and grants normally contain clauses binding the University to the requirements of the Act. Ethics Law: The State of Alabama Ethics Law imposes certain limitations upon all State employees. These limitations include a prohibition against using State facilities, time or equipment for personal financial gain and a prohibition against conflicts of interest. A sponsored project's funding agency (State or otherwise) may place additional ethics requirements on the University and the researcher. Equal Employment Opportunity/Affirmative Action: Several Public Laws, Executive Orders, and State laws impose equal opportunity and affirmative action program requirements upon University transactions. UAH outlines its procedure for compliance with these requirements in its 'Equal Employment Opportunity/Affirmative Action Policy'. All employees should be familiar with and in compliance with this policy. Export Control Laws: Export Control Laws are Federal laws implemented and enforced by the Department of State through its International Traffic in Arms Regulations (ITAR) and the Department of Commerce through its Export Administration Regulations (EAR). Although most university research and other interaction with foreign nationals are exempt from ITAR and EAR requirements, the Principal Investigator must sufficiently understand the definitions and situations which might require restriction and control of the export of a technology item or information. Additional information can be obtained at the link above. Prior to a proposal as PI, you MUST complete the Export Control training. Training seminars are offered periodically by the OSP or you can become Export Control certified through an online seminar presentation ("Become Export Control Certified via the web"). Human Subjects: Any Principal Investigator proposing sponsored project research using human subjects MUST receive prior approval from UAH's Use of Human Subjects Committee. Information about the Committee's purpose and responsibility, the project approval process and the required forms are located on the OSP web page. Principal Investigators applying for NIH funding of projects involving human subjects must also provide a copy of a certificate (which fulfills the NIH requirement for an institutional training course). The certificate is issued by NIH upon the Principal Investigator's completion of an on-line tutorial of Federal regulations governing human subjects in research as well as the responsibility of the investigators and the institutional review boards in protecting the human subjects. ALL "key personnel" involved in the project should complete this tutorial. Immigration Matters: Sponsored program issues affecting non-US citizens--employees, students or subcontractors--should be referred to the Office of Research Security PRIOR to engaging the non-US citizen for sponsored project work. Intellectual Property (inventions/discoveries/new technology): UAH research personnel supported with Federal funds are required to report any inventions, discoveries or new technology developed or discovered during the course of their research. The Principal Investigator acknowledges and agrees to this requirement by his/her signature on the proposal internal coordination sheet. Lobbying Activities: Most sponsored project award documents require certification: "that no Federal appropriated funds have been paid by or on behalf of the University to influence or attempt to influence an officer or employee of any agency, a member of Congress, an officer or employee of Congress, or an employee of a member of Congress in connection with awarding of any Federal contract, making any Federal loan, entering into any cooperative agreement or extending, renewing, continuing, amending or modifying any Federal contract, grant, loan or cooperative agreement". If such activity has taken place, the University must disclose the activity using Standard Form LLL, "Disclosure Form to Report Lobbying." Failure to disclose lobbying activity carries a substantial monetary penalty. Overrun Account Procedures: It is the Principal Investigator's responsibility to ensure that costs charged to his/her sponsored project awards are allocable (demonstrate a cost-benefit relation), allowable (as per "OMB Circular A-21", project terms and conditions & institutional regulations), reasonable (do they stand the test of good judgment and common sense) and consistent (in relation to like circumstances). To assist with this responsibility, the Principal Investigator should use the services and reports issued by the Office of Sponsored Programs and Contracts & Grants Accounting, review cost transactions and monthly account statements in a timely manner, and resolve financial errors quickly. A sponsored project account showing an overrun (expenditures exceed credited funds) during the course of the award period of performance or after project end is subject to the procedures outlined in the University's "Policy on Overruns on Sponsored Research Contracts and Grants". Procurement Integrity: The "Procurement Integrity Act" places certain responsibilities on agencies/institutions seeking Federal contracts. Responsibility for compliance with the provisions of this Act is passed down to the appropriate individuals involved in the proposal and award process. In some instances, the Director of Office of Sponsored Programs must sign certifications of compliance with the provisions of the Act and, in order to do so in a knowledgeable manner, the Principal Investigator and other key individuals in the proposal/award process may be required to sign an acknowledgment of their responsibilities under the Act. A summary of the Procurement Integrity Act can be found at the link above. Proposal Routing and Approval Procedure: Principal Investigators requesting outside funding for their projects/programs must submit their requests (proposals) to the funding agencies through the Office of Sponsored Programs. All requests for sponsored funding must be approved in accordance with UAH's "Routing and Approval Procedures for Grant and Contract Proposals" which can be found at the link above. Scientific Misconduct/Ethical Conduct in Research: All University researchers are required to adhere to the UAH "Policy Regarding Ethical Standards in Research and other Scholarly Activities" obtained at the link above. In some instances, a researcher may be required to sign a certification signifying knowledge of and intent to adhere to the standards of the policy. Additional Responsible Conduct of Research Training currently required. Safety & Environmental Hazards Requirements: Principal Investigators engaging in research involving the use of hazardous chemicals, biohazards, lasers, radioisotopes or other potentially hazardous activities must complete a project registration form prior to commencing such research. This action notifies the Office of Environmental Health and Safety (OEHS) of the activity. Upon receipt of the form, the OEHS will provide guidelines and manuals specific to the hazard to insure protection of the University community and facilities, and to ensure compliance with applicable regulations governing the use of such materials or activities. Radiation Safety: Use of radioactive materials in University research is regulated by the State Board of Public Health, which licenses and inspects UAH's radiation safety program. All users of radioactive materials must receive proper training and authorization by the Radiation Safety Committee prior to obtaining or using radioactive materials. Recombinant DNA: Researchers contemplating sponsored project activities using recombinant DNA must complete the Recombinant DNA Registration Form and submit it to the Office of Environmental Health and Safety for review prior to the commencement of the project Security: The Office of Research Security should be contacted about any sponsored project issues involving security clearances, badges and other clearances for access to government facilities, and industrial security matters. Subcontracting Goals: Federal contracts in excess of $500,000 must contain a Master Subcontracting Plan and percent goals for purchases placed with small businesses and small disadvantaged businesses. The University's Master Subcontracting Plan, negotiated with the Office of Naval Research, is on file in the Office of Research Administration. During the proposal process, the Principal Investigator and the Contract Administrator develop purchasing goals specific to the particular contract. A semi-annual report of purchases made is submitted to the funding agency. Travel Guidelines: All UAH employees traveling under sponsored project awards must abide by the "UAH Campus Implementation of University of Alabama System Travel Guidelines". To ensure the protection of the University and the traveler, a travel authorization form should be fully approved prior to the commencement of the trip. Employees contemplating foreign travel with funding from a Federal agency received either directly or indirectly through another agency, must be aware of and adhere to the U.S. Flag Carrier regulations. The University travel policy, travel authorization forms, and travel reimbursement request forms can be found at the link above. Negotiation of awards Negotiation of an award can run the gamut from telephone agreement of minor budget changes to full formal negotiation proceedings. The Contract Administrator is the University individual authorized to officially negotiate the award with the funding agency's contractual counterpart. Any substantive change will be discussed with the Principal Investigator prior to agreement—particularly changes involving the statement of work, report requirements or deliverables. The Principal Investigator may be called upon to participate in the formal negotiation proceedings. The Principal Investigator is not authorized to negotiate award terms and conditions. The funding agency or the University might require additional agreements addressing such subjects as protection of proprietary information or treatment of intellectual property. These agreements are made between the funding agency and the University, not the funding agency and the Principal Investigator. Once the negotiations are finalized, the funding agency proceeds with the award. If the agency accepts the University's proposal with no changes, the award can be made without negotiation. Post-Award An award of support is made in the form of a contract, grant, cooperative agreement, purchase order or some other written instrument. The terms and conditions of the award will vary according to the type of instrument and the awarding agency's regulations. Accepting an award An award is accepted by the Office of Sponsored Programs in the name of The University of Alabama in Huntsville. A Principal Investigator may NEVER accept an award in his/her name or in the name of the University. The Office of Sponsored Programs uses a Document Approval Sheet (DAS) as the cover sheet documenting acceptance of the award. The Principal Investigator is notified of receipt of the award by telephone or email. If the award document has any terms and conditions requiring the Principal Investigator's concurrence, he/she will be asked to review the award document and sign the DAS. It may be necessary to circulate the DAS to others within the pre-award signature loop if the award significantly differs from the proposal or if there are security or legal issues. If there was no proposal, the Principal Investigator's department or research center will be required to agree by signature to accept contractual and fiscal responsibility for the award (the same agreement which they would have made on the proposal Internal Coordination Sheet). If the award is fixed-price, the fiscally responsible department/center will be required to agree by signature to cover any cost overruns that may occur in fulfillment of this contract. The Director of Office of Sponsored Programs will sign the award for the University. The Principal Investigator bears the prime responsibility for the technical, management, fiscal and administrative conduct of the research project. He/she should: be familiar with applicable agency and University guidelines; conduct the project in a professional manner; ensure that all administrative issues are addressed (e.g., patents, publication restrictions, human subjects, animal care, etc.) expend funds in compliance with agency and University regulations and maintain proper budgetary control; and submit reports and deliverables in a timely manner. The Office of Sponsored Programs acts as a liaison between the Principal Investigator and the funding agency contractual authority. While the funding agency's technical officer can provide guidance to the Principal Investigator and monitors the progress of the contract/grant effort, he/she CANNOT issue contractual direction or changes. The funding agency's contracting officer must issue any change affecting a contract requirement. Post-Award Administration The Office of Sponsored Programs and your Contract Administrator or Contracts and Grants Coordinator should be called upon for assistance with a variety of post-award administrative actions. Some of these might be: Establishing the Award File After the award is accepted, the Contract Administrator will establish the award file. This will involve the following actions: Obtain an org number(s) for budgeting the award funding. All sponsored projects are processed through the UAH accounting system, specifically Contracts and Grants Accounting. The accounts are based on six digit numbers where the first 2 digits for research centers and the first 3 digits for academic departments designate the fiscally responsible unit for the account. These initial digits are followed by a "5" which indicates the account as a research account, and the remaining digits are an index number to the account. Set up the account budget (based on the proposal cost estimate budget) by submitting a "Request for Budget Change" form to Contracts & Grants Accounting. Only the amount authorized for spending by the funding agency will be set up in the budget. (We might receive an award for $200,000 with $100,000 authorized for spending. The account budget would be $100,000.) Enter the new award/account information into the Office of Sponsored Programs database, distribute a copy of the award document via email and the "green sheet" transmittal sheet to the Principal Investigator and Contracts & Grants Accounting, and set up the administrative files. If the award has cost-sharing requirements, a University cost sharing account will be established, if required. Contracts and Grants Accounting will be informed of all cost sharing commitments. The Principal Investigator is responsible for ensuring that cost sharing commitments are met, particularly documentation of in-kind cost sharing, and that the Contracts and Grants Accountant receives this documentation in a timely manner. In some cases, an award may result in "program income" which requires a separate research account. The University has a written procedure for administering program income funds. Prior Approvals or Expanded Authority During the course of a funded project, it may be necessary to change the budget or scope of work from what was proposed. Also, other actions, not anticipated at the time of the original proposal, might be advisable in order to conduct the funded effort in the most efficient manner. These changes usually can be accommodated by either making a request to the funding agency's contract/grant officer or by exercising the University's prior approval or expanded authority as allowed under the award. Most agencies require a written request for substantive financial changes ("substantive" varies from award to award), changes to the scope of the award, termination of the Principal Investigator, or a significant reduction in the Principal Investigator's effort on the project. In some instances, any changes must be approved in advance by the funding agency. The Office of Sponsored Programs has an Institutional Prior Approval System (IPAS) for consideration of requests for changes within its authority. This authority is limited to GRANTS or sub-awards made to us under grants. A quick guide to grant actions (for our most common Federal award agencies) which can and cannot be performed under the IPAS is at this link. A written request for IPAS consideration, preferably on this form, should be made to the Research Administrator stating the proposed change and how it will benefit the project. This request should be made, and the agency or IPAS approval should be received prior to initiating the desired action. Requests for changes which require funding agency approval are sent to the agency contracts/grants office with a copy to the project technical officer. The Principal Investigator may wish to provide additional information to his/her technical officer separately but should remember that official approval will come from the agency contract/grant officer. Pre-award Costs Some of the Federal agencies recognize the need for pre-award costs and, under the prior approval/expanded authority privilege, allow a 90-day pre-award coverage. This does NOT apply to contracts, but to grants and, usually, cooperative agreements. If the Principal Investigator has some assurance of a pending award from a Federal agency and the award will allow pre-award costs, an account can be established—at risk—to allow these costs. This is most commonly used to order equipment to ensure it is available at the intended start of the project. The Principal Investigator must submit a Risk Memo with his/her request to the Contract Administrator stating the need for pre-award expenditures. Upon receipt of the award, the Contract Administrator will notify the funding agency that the University is authorizing pre-award costs for the requested period. Pre-award costs are incurred at the University's risk. If the University does not receive the award or the award is delayed more than ninety days past the anticipated start date, the Risk Memo account must bear the costs not covered by the award. No-cost Extension In many cases a funding agency will allow an unfunded (no-cost) extension of the contract period of performance to allow the researcher additional time to complete the project. A no-cost extension should be requested prior to the award end date, preferably more than 90 days prior to the end date. The request should be made in writing to Research Administration providing the length of the desired extension and the reason that it is required. Contract requests are always submitted to the funding agency. Most grants and cooperative agreements allow the University one opportunity to authorize its own no-cost extension (with proper notification to the agency). Subsequent requests must be made to the funding agency. The required period of notice prior to the original end date differs from agency to agency so check with you Contract Administrator and Contract and Grants Coordinator. The IPAS form can be used for this request. The desire to expend remaining funds without any corresponding technical benefit to the project is NEVER an acceptable reason for a no-cost extension. Account Statements Contracts & Grants Accounting maintains on-line access to the award cost sharing accounts. Every Principal Investigator and his/her administrative assistant should obtain an access password from Computer and Network Services using the "FRS Budget Account and Screen Access Request Form" and review his/her account on, at least, a monthly basis. A modified current balance of an account can be obtained on any date, but note that the Facilities and Administrative (indirect) Cost is computed at month end. Therefore, a current balance statement will not include that month's F&A cost. It is the Principal Investigator's responsibility to address account statement errors promptly with the appropriate Contracts and Grants Accounting accountant to avoid improper charges to the funding agency. Budget Changes and Re-budget Actions Your award budget can be changed in a variety of ways. Several of the changes are accomplished with the University's "Request for Budget Change" form. The form is used at the beginning of an award to credit the authorized funds to the account. The Office of Sponsored Programs prepares this form based on the proposal budget and submits it to Contracts and Grants Accounting for entry into the University's financial record system. During the course of the award period it may be necessary to re-budget funds from one sub-code to another or, in certain cases, from one account to another. Funds can be moved between accounts ONLY if both accounts are under the same award. This action is also done with a "Request for Budget Change" form and can be initiated by the Principal Investigator. All re-budget actions must be sent to the Office of Sponsored Programs for approval prior to submission to Contracts and Grants Accounting for action. The office initiating the re-budget action should be aware of all funding agency and UAH regulations which might affect this action. In some instances funding agency approval is required prior to action. Some basic information about re-budget actions can be found in the Office of Sponsored Programs "Quick Reference Guide". A list of common sponsored program-related sub-codes can be found on the OSP web page. Charge Transfers If an erroneous charge is made to an account or the Principal Investigator determines that a charge should more appropriately be debited to another account, he/she should use a "Transfer Authorization" form. This transaction moves an existing charge, not funds, from one account to another. Under the appropriate conditions, a charge can be moved between accounts under different awards. The form should be completed by listing the "credit" account (the account from which you are moving the charge) and the "charge" account (the account to which you are moving the charge.) A description of the charge, the amount and the reason for the transfer must be on the form. Documentation of the previous charge must accompany the form and can be a copy of the original purchase order, highlighted charges on the original account statement, etc. Only the amount of the direct cost should be on the form. The appropriate F&A charge will be credited and debited along with the transferred charge. All authorization forms must be reviewed and approved by the Office of Sponsored Programs. Remember that the original charge must have occurred during the active period of the account to which it is transferred and it must be relative to that account's purpose. PAYROLL CHARGES CANNOT BE TRANSFERRED WITH THIS FORM. A payroll charge must be changed using a corrected Bi-weekly Labor/Leave Report. Purchases Supply items, equipment, airline tickets, etc., are made through the University's Purchasing System. The Office of Business Services provides a manual explaining its procedures and other information and forms. Please note that any equipment requisition or a requisition with sub-code "4570" (parts to fabricate equipment/no F&A) and "4571" (parts to fabricate equipment/with F&A) require the approval of the Office of Sponsored Programs. A requisition for an item of equipment (individual item costing in excess of $5,000) or for any computer (regardless of cost) must be accompanied by a screening form, "Equipment and Computer Products Purchase Approval Form." If you requisition is electronic, fax the screening form to the Office of Sponsored Programs (824-6677). Travel Travel reimbursed under a funded award must relate to the proposed effort. All travel must have a pre-approved "Approval for Official Travel" form. (Note that faculty and staff use different forms.) The traveler should be familiar with the University's policy, "Travel Guidelines," regarding reimbursement for in-state or out-of-state travel. This will ensure that expenditures submitted for reimbursement are allowed and can be reimbursed. In addition to this policy, the award itself may impose additional restrictions and, if an award is more restrictive than UAH policy, the award restrictions will be followed. Foreign travel under a Federal award (or an award with Federal funds as its ultimate source) must adhere to the U.S. Flag Carrier Airline restrictions. Reports Almost all contracts/grants require technical or progress reports, which are the responsibility of the Principal Investigator. The award document or award guidelines will usually provide guidance as to the report type, format and submission date. The reports can be submitted to the funding agency by the Office of Sponsored Programs or the Principal Investigator can submit them directly to the agency. If OSP will submit the report, the Principal Investigator must provide the required number of copies (this information is in the award document or the funding agency guidelines). If the Principal Investigator submits the reports directly to the agency, a copy of the transmittal letter and report cover page should be sent to the Contract Administrator to facilitate entry of the report submission in the OSP database. Timely submission of reports is an important matter. Many Federal agencies will withhold future awards to the delinquent Principal Investigator and, in some instances; the agency may withhold all future awards to the University until they receive the report. Most awards require reports other than the technical reports. They may include annual reports of new technology/inventions and annual property reports. Although the Contract Administrator will submit these reports, he/she will require information from the Principal Investigator prior to the submission. Fiscal reports are the responsibility of Contracts and Grants Accounting, but the Principal Investigator should have knowledge of the content of the reports and be prepared to provide input to the assigned Accountant. Personnel It is the Principal Investigator's responsibility to ensure that his/her project is supported by a sufficient number of professionally competent personnel to complete the task within the agreed time frame and authorized funding amount. If a new position is required to fulfill the award obligations, contact the Office of Human Resources/Staff Employment for assistance. The University has a prescribed procedure and forms for developing and advertising new positions. Individuals working on sponsored projects are paid from the project account in proportion to the effort expended in support of the project. The Bi-Weekly Labor and Leave Report should be submitted by each individual charged to a 5-account or cost sharing 2-70xxx account. This document has several purposes and must be sent to different offices depending on the intended purpose. Instructions for use of the BLLR and routing of the copies are at this link. Additional information about the payroll system and the payroll forms are available at the Payroll web site. Subcontracts A proposed research project often requires subcontracted services of a non-University individual, a company or another university. In this case, after award, the University will issue a subcontract to the individual or company. A subcontract is ALWAYS between the University and the subcontractor. The University authorizes the subcontractor to begin working. A Principal Investigator should never circumvent the established subcontracting process. It is the PI's responsibility to monitor the technical conduct of the subcontractor and ensure that all reports or deliverable items are produced in a professional, timely manner. This is particularly important because completion of the project is usually dependent on input from the subcontractor. The University's procedure for issuing subcontracts, consultant subcontracts, and letter subcontracts can be found at in Subcontract Information. If a researcher requires the services of another University employee in another department and the individual is fully committed and cannot perform the task as part of his/her normal duties, the Principal Investigator can issue an Intra University Consulting using the required form and following the prescribed payment procedures. The employee/consultant's home labor area must be different from that of the Principal Investigator (or it would not be a "cross-departmental" situation), the employee/consultant must be paid at a rate no greater than his/her normal UAH hourly rate equivalent, and the funding agency must approve the action. Instructions and forms can be found at this link. Account overruns or disallowed costs It is important that a Principal Investigator closely monitor his/her monthly account statements to ensure that the account expenditures do not exceed the authorized funding amount. The overrun is the responsibility of the Principal Investigator and the University unit fiscally responsible for the account. In accordance with the University's policy on "Overruns on Sponsored Research Contracts and Grants", an overrun account will be frozen by Contracts and Grants Accounting until the overrun is resolved or by submission of a Risk Memo. (The risk memo will allow the account to remain active but the overrun must still be resolved.) Some costs are not allowed by particular funding agencies and, if improperly charged to the account, will be disallowed at a later date. This is why it is important to understand your individual contract/grant restrictions and to understand the UAH "Cost Policy". In many cases, disallowed costs can be avoided by obtaining the proper approval prior to incurring the expense. A disallowed cost becomes the responsibility of the Principal Investigator and the fiscally responsible department. Close-out At the end of the contract period of performance, the Office of Sponsored Programs begins a close-out procedure. This procedure documents that all required reports and forms have been properly submitted and that the funding agency has released the University from any further responsibility relative to deliverables. All subcontracts issued under the contract/grant must be closed out in the same manner prior to close-out of the main award. All payments must be received, all accounts balanced and all required fiscal reports must be submitted to the funding agency. All files related to the contract/grant are stored for a period of seven years. Audit Any sponsored contract or grant is subject to audit by several entities. Funding agencies can request approval to audit during the course of an award or following the end of an award. They can also audit proposals—a pre-award audit—to ascertain if the University's proposal costing is accurate and realistic relative to the technical effort proposed. The University is obligated to perform an annual "A-133 Audit" (single source audit) every year using a professional accounting firm. During this audit, the auditors will select a representative sample of contract/grant related transactions and check the transaction procedure relative to the funding agency's and University's policies and procedures regarding the transaction. The University's internal auditor also can perform audits on procedures relating to contract administration. If a Principal Investigator is approached directly by an outside auditor relative to sponsored project activity, he/she should immediately notify the Office of Sponsored Programs. This manual is based on general principles. Many pre-award and post-award issues are peculiar to the individual award situation and have not been addressed here. It is important to discuss these questions and concerns with the Contract Administrator and Contracts & Grants Accountant as soon as they arise—ideally, before any action is taken. This will ensure the avoidance of problems or a timely resolution if they do occur.