Purpose
This guideline establishes standard procedures for the preparation, submission, administration, and completion of all grants and contracts at Capital College.
Introduction
These guidelines are based on general University guidelines and policies as articulated by the Vice President for Research, the Office of Sponsored Programs, the federal Office of Management and Budget, the various Institutional Review Boards, and the Board of Trustees, all of which can be accessed here and other University websites.
Policies
All Capital College faculty must follow the policies noted below as well as those referred to in Penn State’s research publications as revised, which are available here.
- RA01- Determining the Allowability, Allocability, and Reasonableness of Costs on Sponsored Projects
- RA02- Acceptability and Evaluating of Services, Equipment or Property Donated to Federally Sponsored Projects
- RA04- Making Revisions to Budgets and Program Plans on Federally Sponsored Projects
- RA03- Preparing Budgets (Cost Estimates) For Sponsored Projects
- RA05- Significant Financial Interest Disclosure for Sponsored Project'sInvestigators
- RA06- Cost Recovery for Sponsored Projects
- RA10- Handling Inquiries/Investigations Into Questions in Ethics in Research and in Other Scholarly Activities
- AD 47- General Standards of Professional Ethics
- HR 76- Faculty Rights and Responsibilities
- HR 80- Faculty Consulting PracticeHR 91 - Conflicts of Interest
- RAG02- University Equipment Matching Funds Program
- RAG03- Assistantships / Traineeships Matching Funds Program
- RAG05- Fixed Price Agreements - Residual Balance
- RAG06- Applying Fringe Benefit and Facilities and Administration (F&A) Rates to Sponsored Projects and Other Miscellaneous Funds
Assignment of Grant Supervision Responsibilities
The Chancellor has given the Senior Associate Dean for Academic Affairs and the Associate Dean for Research and Graduate Studies the responsibility for supervising all grants at Capital College. The Office of the Associate Dean for Research and Graduate Studies works directly with the University’s Office of Sponsored Programs and The Graduate School to further the research goals of the University.
Persons Subject to This Guideline
This guideline applies to all faculty, staff, and students of the Capital College and all grants, contracts, services, or any other externally supported activities related to the College’s research and educational outreach activities including any projects developed jointly through the Office of Development. All faculty must also adhere to the policies governing the use of Human Subjects, which are available at here and other University sites.
Projects Subject to this Guideline
All external grants, contracts, or gifts with conditions or deliverables are covered by this guideline as well as all other applicable University policies.
Responsibility for Administering This Guideline
The primary responsibility for ensuring compliance with all grants, contracts, sponsored programs, and other externally supported activities rests with the Principal Investigator and the Budget Administrator/School Director. The Senior Associate Dean and the Associate Dean for Research and Graduate Studies will supervise all externally sponsored activities and report regularly to the Chancellor on the status of the College’s research enterprise.
Critical Stages of the Grant Process
All grants are subject to several critical review periods. The timetables for these stages will depend on the requirements of the sponsor and the deadlines outlined in the Request for Proposal [RFP] or grant announcement. The stages outlined below will vary depending on the type of grant or project, the requirements of the sponsor, and other criteria established by the Office of Research and Graduate Studies to facilitate the research enterprise of the University.
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Pre-Submission Stage – Consultation with potential faculty and staff participants, the School Directors, and the Office of the Associate Dean for Research and Graduate Studies leading to a draft proposal for review and approval for submission by the Office of Research and Graduate Studies. During this stage, and as far in advance as practical, the budget is prepared in consultation with the grants management team in the Office of Research and Graduate Studies and must be approved by the Budget Administrator/School Director. Proposed budgets must list specific personnel, when known. All course releases, extra compensation plans, and/or related salary issues should be resolved with the Budget Administrator/School Director and Associate Dean for Research and Graduate Studies as early in the proposal process as possible.
- Award Stage – Once the University and the College receive the notice of award, the Office of Research and Graduate Studies will consult with the PI as the contracting process occurs through the Office of Sponsored Programs at University Park. At the time the budgets are established (usually after the contract is in place), salary distribution forms for all personnel (including faculty) will be prepared at this time and approved by the Budget Administrator/School Director.
- Pre-Completion Stage – Principal Investigator meets with Office of Research and Graduate Studies [Grants Administrator and Associate Dean as required] and the Financial Officer to begin preparation for the closeout of the grant, determine the final budget details, and arrange for reports to sponsors.
- Completion Stage – All documents and deliverables forwarded to sponsor, and all financial reports completed.
Expectations and Procedures
This guideline cannot specify every exigency arising from a preparation or administration of grant or contract. The procedures and expectations outlined below establish the minimum requirements for meeting the objectives of these guidelines.
Pre-Submission
- All grants and contracts must identify all personnel involved at every stage of the grant and the percent of effort contributed by each individual.
- All salary requirements must be specified before any proposal is submitted. Such salary requirements as extra compensation, salary savings, provisions for course release, and all other items related to compensation must be included with the original proposal. All aspects of the budget must be approved by the Budget Administrator/School Director and the Associate Dean for Research and Graduate Studies.
- Since “matches” are real monies and must be tracked and accounted for, match budgets must be established prior to submission and as the budget is developed. The match budget must be specifically identified for all grants and contracts. That budget must contain information on the source of funds, all fringes benefits/expenses, and allotment. This requirement, which is mandated by federal and state laws, must be approved in writing by the Budget Administrator and by the Associate Dean for Research and Graduate Studies before any proposal is submitted.
- The Associate Dean for Research and Graduate Studies must review and approve all agreements before submission of any proposal.
Post-Award
- If the sponsor delays the grant award, if any personnel are to be hired on grant funds, the Budget Administrator must certify that funds are available to support the position[s], identify the source of the funds, obtain approval from the Chancellor’s office if the funds are not available in the academic or research unit. This also applies to fringe benefit costs.
- The Budget Administrator/School Director is ultimately responsible to ensure that salary and time commitments for all personnel are properly allocated. Salary distribution forms must be approved by the Budget Administrator/School Director after reviewing the salary distribution, the budget sources to be billed for the salary, the specific dates including fiscal years for grants extending beyond a single year, and any other issues related to salary. An Excel spreadsheet or similar mechanism should be used to track the salary distribution in detail for the entire grant period. Any extra salary compensation must be approved by the Chancellor in advance.
- The PI and a representative from the research and/or finance office should meet soon after an agreement is signed to review the budget and ensure that the BARA form is processed properly.
- All faculty and staff must follow the Penn State policies and guidelines regarding exclusions and restrictions imposed by the sponsor. The College will not support unallowed charges for nay project. Such expenses will be billed to the respective academic units or individuals in accordance with applicable University practices.
- The practice of issuing advance fund numbers will be monitored carefully by the Associate Dean for Research and Graduate Studies. The Associate Dean for Research and Graduate Studies in cooperation with the appropriate College offices will determine the procedures to be followed whenever there are delays with the award, problems with the grant agreement or contract, and other difficulties related to the distribution of compensation. The Associate Dean, Financial Officer, and the School Director should agree on how to distribute the funds and/or pay salary obligations. Any central budget charges must be approved the by the Senior Associate Dean and reported to the Financial Officer or delegate. No grant should remain in “advance” status after official award notification is made. The individual budget unit rather than the College will be liable for any expenses incurred but not covered when the contract is in place.
- The PI and the School Director must identify who and how invoices will be prepared, the invoice frequency, and the detail required for payment. Whenever possible, Capital College will use the standard invoice wording in Penn State contracts to ensure that Research Accounting at University Park will handle the invoicing. The College prefers that, whenever possible, Research Accounting should invoice clients or agencies.
- No PI or administrator is authorized to sign agreements on behalf of Penn State.
- The office of the Associate Dean for Research and Graduate Studies will review agreements whenever sponsors suggest or require changes to the original agreement or amendments adding any new restrictions or deliverable requirements.
Given the responsibilities of the principal investigators, budget executives, and academic administrators for fostering the research enterprise at Capital College, the overall administrative goals are to comply with all applicable procedures and policies regardless of whether they are covered in this document. A strict adherence to common and reasonable practices will ensure that the College will exhibit exemplary behavior and remain accountable to all its sponsors and constituents.
Reviewed: The Office of Sponsored Programs
Approved: Academic Leadership Council
Revisions: Academic Council March 25, 2009