Sponsored Programs Policy

Rationale
The development of financial resources from government (other than Utah State Legislature appropriated funds) and private or corporate foundation sources provides significant benefits to the institution and furthers the institutional mission by facilitating research, workshops, projects and activities that enrich the scholarly and creative endeavors of faculty, staff, and students and enhance the programs and services provided by the institution.  As members of the institutional community identify and prepare sources and opportunities, and begin preparing written Proposals for funding, it is necessary that these efforts be coordinated, collaborative potentials explored, potential institutional obligations identified and addressed, and appropriate oversight administered.

Terms
1.    Sponsored Program – contracts, agreements, or gifts to support research, scholarly or creative activities; programs of service; or projects involving funds, materials, other forms of compensation, or exchanges of in-kind items or efforts from government and private or corporate foundation sources external to the institution (not to include state appropriations, donations from individuals, or donations from corporate entities that are not corporate foundations).  Typical funding mechanisms include, but are not limited to, awards, contracts, cooperative agreements, or congressional appropriations, from federal, state, or local government entities, or from private or corporate foundations.
2.        Office of Sponsored Programs – the office of the institution designated to provide facilitation and oversight of the Sponsored Program Proposal development and submission process.
3.        Budget – the financial plan or cost assessment for the Sponsored Program Proposal, contract, or award reflecting all costs associated with implementation of the project in compliance with sponsor guidelines, government regulations, and institutional policies.
4.        Direct Costs – all costs that can be directly attributed to the conduct of the Sponsored Program and that are specified in the Budget. This does not include Indirect Costs or other operating overhead.
5.        Indirect Costs – costs incurred by an institution in supporting projects funded by monies or resources from outside sponsors and/or agencies. These costs include, but are not limited to: general and departmental support and use of College services such as libraries, laboratories, classroom facilities, computer centers, and utilities.  They also include services provided through the offices designated to develop and administer Sponsored Programs, essential administrative services including accounting, personnel, payroll, accounts payable, accounts receivable, specialized insurance coverage, compliance and regulatory monitoring, independent audits, and legal services that are related to the administration of Sponsored Programs.
6.        Externally Funded Activity – any activity, program or project of the institution that is funded from sources external to the institution and funded through awards or agreements (e.g., grants, contracts, cooperative agreements, congressional appropriations, etc.).
7.        Post Award Compliance – facilitation to ensure that the terms and conditions of an award, as dictated by the funding sponsor and other regulatory requirements are met.  Post award compliance is primarily the responsibility of the Principle Investigator or project director, with assistance from the offices of institutional compliance, Sponsored Programs, financial accounting, and auditing.
8.        Notification of Intent – written notification indicating an individual’s or unit’s intention to seek external sponsorship.
9.        Principle Investigator (PI) – Individuals – faculty, staff, student or administrator (also referred to as the Project Director) who has primary responsibility for technical compliance, completion of programmatic work, and spending of a sponsor’s funds.
10.     Proposal – a written description of a request for a Sponsored Program establishing the need, objectives, projected outcomes, methodology(ies), qualifications of investigator(s), Budget plan, and/or some combination of these.

Policy
1.        All Sponsored Program Proposals from the institution shall be coordinated and submitted under the direction of the Office of Sponsored Programs and with the approval of the officer(s) designated by the President to administer Sponsored Program contracts for the institution.

Procedures

I.  Pre-Award Activities
    A.  Administration:

            1.    The Office of Sponsored Programs is responsible for the oversight, support, coordination, and submission of all Sponsored Program Proposals to advance the programs, activities, and services of the institution

                    in accordance with the institutional Strategic Plan.

            2.    Each dean or division administrator is encouraged to hire or appoint an officer to be responsible for the support, coordination, and submission of Sponsored Program Proposals within their respective areas of

                    administration. Such officers will coordinate their efforts with the Sponsored Programs Office.

    B.  Sponsored Programs Development Committee

            3.    A Sponsored Programs Development Committee will be established to recommend procedures for Sponsored Programs administration and to represent the Sponsored Program Proposal-writing interests and

                    efforts of their respective areas of administration.

            4.    Members of the Sponsored Programs Development Committee will be appointees of the faculty senate, Institutional Advancement, and deans or division administrators representative of the major areas of the

                    college concerned with solicitation of external support for research, creative and scholarly activities, programs and services.

            5.    The individual designated to develop and administer the Office of Sponsored Programs will serve as chair of the committee.

    C.  Sponsored Programs Development Committee Responsibilities

            6.    Serve in an advisory role to develop and promote Sponsored Program initiatives.

            7.    Disseminate Sponsored Program information to appropriate individuals within their respective areas of assignment.

            8.    Assist in the formation of effective teams of researchers and/or writers to develop Sponsored Programs.
            9.        Provide recommendations in matters of institutional Sponsored Program development.
    D.  Notification of Intent to Develop Sponsored Program Proposal
            10.     A Notification of Intent to develop a Sponsored Program Proposal should be submitted to the Office of Sponsored Programs before initiation of proposal preparation to avoid disallowed multiple requests from

                    the same funding source.  This form must be signed by a department chair and dean or division administrator to indicate preliminary approval.

            11.     If two or more units have submitted a Notification of Intent to submit Proposals for the same Sponsored Program prospect with a limited call for Proposals, the following protocol will be used:

            11.1      Collaboration among campus units is usually the first and foremost objective.

            11.2      If necessary, the following criteria may be used to determine the Proposal to by submitted by the institution:

                                   -    the greatest potential for campus impact;

                        -     the best alignment with institutional mission and strategic plan(s);

                        -     the unit that first submitted their Notification of Intent;

                        -    the best alignment with the giving interests of the organization to be solicited; or

                        -    in the case of private or corporate foundations, personal connection with officers of the organization being solicited.

            11.3     In the case of a disagreement on which unit will take the Proposal lead or be allowed to submit a Proposal, the Director of Sponsored Programs will negotiate progressively as needed with the involved parties,

                        respective departmental chairs or directors, deans, or division administrators to negotiate a resolution. If necessary, the President’s Council may be requested to make a final decision.

    F.  Sponsored Program Proposal Writing:

            12.    The Office of Sponsored Programs will provide assistance with Proposal writing, editing, review and recommendations for improvements, review and assistance with Budget preparation, and/or preparation of

                    time-line charts, other charts and graphs, preparation of forms, etc.

            13.     Faculty and staff of the institution who participate in Sponsored Program Proposal-writing activities may be eligible for reassigned time or compensatory stipends with approval of their respective dean or

                    division administrator and in alignment with other related institutional work policies.

    G.  Proposal Review and Approval:

            14.     All Proposals for externally funded projects that will be conducted under the auspices of the institution must undergo administrative review prior to submission by the following:

                        -    The Office of Sponsored Programs;

                        -    Department chair and or unit division director of the Project Investigator/Director and the dean or senior administrative officer of the Project Investigator/Director;

                        -    Vice President(s) and the Director of Budgets for submissions requesting more than $50,000, or which involve more than $10,000 in matching funds or institutional commitments, or Proposals which involve

                               more than one administrative division of the College.

            15.     Proposals for projects involving use of humans or animals as subjects of research must be submitted for special institutional review and approval. Generally, grant sponsors expect that this review process will

                    be completed and institutional approval obtained prior to submission of a Proposal.

            16.     Proposals for Sponsored Programs will attempt to recapture the maximum amount of Indirect Costs allowable within the Sponsored Program and/or according to negotiated agreements with sponsoring entities.

            17.     All Sponsored Program Proposals must be signed by the institution’s designated authorizing official in a timely manner such that the proposal may be submitted prior to the sponsor’s deadline.

            18.     A summary of all Sponsored Program Proposals in process and submissions will be presented monthly to the President’s Council, the institutional Board of Trustees, and various other interested or responsible

                    parties on campus. A summary of Sponsored Program Proposals exceeding $500,000 will be submitted to the Utah State Board of Regents in accordance with Regents policy.

II.  Post Award Activities:

    A.  Acceptance:

            19.     The Vice President of Academic Affairs (or officer designated) shall review and accept all contracts for institutional Sponsored Programs and will assure that such are in the best interest of the institution, and

                    that they comply with institutional and Utah State Board of Regents policies.

            20.     The institution is obligated to conform and comply with all relevant federal and state statutes and regulations and all directives issued by the Board of Regents, Board of Trustees and Office of the President in

                    the administration of Sponsored Programs and externally funded activities.  In order to meet these obligations, only specific individuals, authorized by the President and/or by institutional policy to act on behalf

                    of the institution, may accept awards from federal, state, or local government entities, or from private or corporate foundations or agencies. 

            21.     Prior to acceptance of external funding or awards which are in excess of $500,000, approval by the Utah State Board of Regents must be received. (See State Board of Regents Policy).

    B.  Administration:

            22.     The offices of Institutional Compliance and Policy Administration, financial accounting, and auditing are responsible for institutional post-award compliance with Sponsored Program contracts.

            23.     The institution is the contracting agency subject to audit and review by sponsors and agencies and is therefore, responsible for the proper expenditure of funds and submission of timely and accurate financial

                    reports.

            24.     All Sponsored Program expenditures must be in compliance with federal, state, and local government laws, rules, and regulations as well as Utah State Board of Regents and institutional policies and

                    procedures.  When there is a variance between any sponsor or agency and institutional guidelines or laws, the most restrictive guideline or law shall govern.

            25.     All external funds awarded to entities of the institution or by subcontract to non-institutional entitles will undergo administrative review upon award and throughout the funding cycle as follows:

                    25.1  The department chair(s), dean(s) or unit division director(s) will be responsible to assure that expenditures of external funds are aligned with the funded activities, that reports are submitted in a timely

                    manner, and that awardees meet the terms, conditions, objectives and/or expectations set forth in the written Proposal and/or contract of the awarding organization.

                    25.2  The office designated to ensure institutional compliance will be responsible to facilitate compliance with contractual obligations of awards by conducting initial Sponsored Program orientations with Project

                    Director(s), providing ongoing consultation as needed, and by reviewing Sponsored Program activities, records, and reports to assure compliance with relevant laws, policies and standards.

            26.     Changes in the project’s Budget shall be reviewed by the Office of Sponsored Programs and may also require prior approval of the funding source and/or approval of the Vice President of Academic Affairs (or

                    officer designated).