Sponsored Programs and Research Integrity
Date of Current Revision: May 2016
Primary Responsible Officer: Director of Sponsored Programs
Sponsored Programs and Research Integrity
Gifts, Sponsored Programs and University Business Transactions
Money coming into the university from sources other than appropriations, or tuition/fees usually necessitates supplementary oversight and management. External funds may have restrictions on use, carry compliance requirements beyond standard UCM practice or engender tax consequences that may impact UCM’s tax-exempt status (gifts, unrelated business income tax, etc.).
Generally, this external funding will fall into one of three categories: gifts, sponsored programs, or business transactions. Accurate classification and processing of external funds assures the university's ability to comply with any terms specified by the sponsor/donor, meet reporting requirements, properly recover costs – both direct and indirect – and facilitate acceptable levels of accountability and stewardship for these funds. Individuals or departments misrepresenting or not reporting external funding to avoid university requirements constitutes fraud and may incur personal penalties or university sanctions. Acceptance and management of gifts is provided by the University of Central Missouri Foundation. Business transactions are managed by the Division of Administration and Finance. Sponsored programs are managed through the Office of Sponsored Programs & Research Integrity (OSP&RI). If there is any question regarding the proper classification of external funding, particularly in cases where the nature of the potential funding relationship is not immediately clear, consultation with the offices listed above is required.
Funding for sponsored programs is provided to the university with the understanding that the sponsor will receive value (academic, proprietary, etc.) from UCM commensurate with the magnitude of the award and that the award may be withdrawn if that value is not received. The value to be provided by UCM to the sponsor is normally specified as a part of a grant, contract, cooperative agreement, and/or other legally binding means of transfer. Sponsored programs may include: designation of key personnel; involvement of any compliance activities (Human Subjects etc.); reporting requirements; return of unexpended funds; and/or cost share or non-reimbursed commitment of any university resources (e.g., space, personnel, equipment, etc.).
The University of Central Missouri is the official recipient of sponsored program funding. While principal investigators/project directors (PIs/PDs) may be the authors of proposals requesting funding, UCM is the legally accountable entity for the award and as such, accepts responsibility for oversight, compliance management and appropriate conduct of sponsored programs. It is therefore required that, through the Office of Sponsored Programs & Research Integrity, the university maintains a centralized, coordinated approach to the development and management of policies and regulations for sponsored programs at UCM. The Office of Sponsored Programs & Research Integrity is responsible for developing procedures in accordance with these policies and regulations.
Authorized Organizational Representative - Signature Authority
A University of Central Missouri Authorized Organizational Representative (AOR) must approve all components of proposals (including budget) prior to submission and sign all sponsored program awarddocumentation. AOR responsibilities include approving proposals for submission, entering into agreements, and accepting awards for externally sponsored programs on behalf of the university. Persons authorized to make this approval are designated by the university president.
Faculty and staff who are interested in pursuing external funding should contact the Office of Sponsored Programs & Research Integrity as soon as they begin formulating their ideas for a proposal. University personnel not specifically authorized by the university president do not have the authority to submit proposals or to enter into agreements with funders of sponsored programs.
Principal Investigator/Project Director Eligibility
In order to serve as a Principal Investigator/Project Director (PI/PD) on a UCM sponsored program, the PI/PD must have a contractual relationship with UCM and be approved by the Office of Sponsored Programs & Research Integrity.
Management of Sponsored Programs
All sponsored program funds must be spent in accordance with university policy, applicable federal and state laws and regulations, and funder terms and conditions. While the university provides oversight for the overall administration of all sponsored programs, PIs/PDs are held individually responsible for the proper management of the project and for meeting the objectives of the project. PIs/PDs are responsible for completing and routing all Accounts Payable, Human Resources, and other administrative forms through the Office of Sponsored Programs & Research Integrity. PI/PDs are responsible for completion of the scope of work, management of the project, and ensuring all requirements for the program are met. Payment of grant expenses should always be made out of the account provided for the specified project. In no instance should grant expenses be paid from a department/college general fund.
Cost of Acquiring and Conducting Sponsored Programs
The cost of acquiring and conducting sponsored programs at UCM includes:
1) Direct costs (e.g. faculty or staff time, materials, supplies, travel directly covered by the award),
2) cost sharing or matching
3) Facilities and administration costs incurred in the general day-to-day operations needed to support the project (e.g. space and utilities, information systems, accounting, payroll services, human resources, general counsel, etc.).
Facilities and Administration Cost Recovery
Facilities and Administration (F&A) cost recovery (also known as Indirect Cost Recovery) provides UCM with a method to recuperate some of the costs of hosting a sponsored program. The F&A rate UCM is allowed to use is established every four years by the university’s cognizant agency, U.S. Department of Health & Human Services, in conjunction with the UCM Office of Accounting Services and the UCM Controller. Proposals for all sponsored programs must include recovery of F&A at the established UCM rate. Exceptions require consultation with the Office of Sponsored Programs & Research Integrity at least 10 working days prior to the proposal submission deadline. OSP&RI will ensure all allowable costs have been identified, included in the proposal budget, and used to calculate F&A recovery.
OSP&RI will follow published policy statements from funders who specifically limit F&A cost recovery. OSP&RI will secure written approval of the Provost if institutional benefits of the project clearly outweigh the reduction in sponsor funding and cost to the university.
Distribution of F&A Cost Recovery
The university has elected to invest its F&A cost recovery in the support and stimulation of sponsored programs with priority given to activities that invest in building UCM’s sponsored program capacity.
Cost Sharing or Matching
Cost sharing or matching represents the use of institutional funds to supplement project costs not borne by the sponsoring agency. Cost sharing constitutes additional financial obligations for the university, thus, UCM makes cost sharing commitments only when required by the funder and then only to the extent necessary to meet those requirements. All cost sharing must be reviewed by the appropriate parties and approved prior to proposal submission. Determining the acceptability of cost share and what sources can be used as cost share is the responsibility of the Office of Sponsored Programs & Research Integrity.
Cost Sharing Expenditures
All types of cost sharing expenditures are reportable and must be documented and identifiable. All cash cost share will be transferred from current university accounts into specific sponsored program account in order to facilitate the reporting and tracking of all project expenditures. All cash cost share, including personnel salary and benefits, must be transferred as it is committed to the project. PI/PDs are responsible for completing or acquiring all necessary documentation to appropriately budget cost share items for a proposal which includes in-kind cost share. PI/PDs are also responsible for obtaining any necessary documentation of in-kind cost share from third parties.
Collaborative UCM Sponsored Programs
In cases where a sponsored program involves multiple UCM departments, colleges, or programs, one individual will be designated as the primary PI/PD by the collaborative units and will be responsible for the management of the project.
Edited for web links, formatting and plain language. Approved December 2015.
Revised by Director of OSP and Vice Provost for Academic Programs & Services May 2016.
Previously annotated as VII.17 Sponsored Programs. Renamed Sponsored Programs for alphabetical listing, grammar and spell check, and transitioned into policy library April 2017