19.045: Administering External Grants and Contracts
|Status:||Approved on July 18, 2012||Signatures and dates
on archival copy
|Initiated by:||Shane Gilkey|
Assistant Vice President for Research and Sponsored Programs
|Endorsed by:||Pam Benoit|
Executive Vice President and Provost
|Approved by:||Roderick J. McDavis|
- I. Overview
This policy provides for the programmatic and fiscal administration of external grants and contracts (including subcontracts). This policy does not apply to student financial aid programs or gifts and donations.
Ohio University will administer external grants, contracts, and subcontracts in accordance with applicable federal, state, and other sponsor regulations.
- II. Acceptance of Award Document
Award documents can range in form from checks to grant letters, contracts, subcontracts, or cooperative agreements. In all cases, the original documents must be presented to the Office of Research and Sponsored Programs (ORSP) for processing. ORSP has been authorized to negotiate the terms and conditions of all award documents as they pertain to sponsor and university policies; see Policy 19.051. Investigators must refrain from the negotiation of terms in any award. In all cases, if a signature is required, the signature must be that of the VP for Research or his or her official designee. In no case is a Dean or a Principal Investigator considered an institutional official, even if the document is preprinted indicating so.
- III. Restricted Account Activation
The minimum documentation that is required for the establishment of a restricted account in the University's financial management system is the following:
- Fully executed, original award document
- Invoicing instructions
- Transmittal Form
- Statement of work
- Specified period of performance
- Full proposal
The above documents will be collected by ORSP. Once received, an account will be established with the assistance of the Grants, Contract, and Plant Accounting office, VP for Finance and Administration.
In cases where award documentation is delayed, but is imminent, a pre-award spending account may be authorized. Pre-award accounts may also be established for bridge funding purposes, acquisition of a piece of equipment with a large lead time, renovations to a research space, or a collaboration with a large research group that has already commenced its work. In any of these cases, a Pre-Award Authorization Form must be completed and signed by the chair, dean, and Assistant Vice President for Research and Sponsored Programs. A non-grant account must guarantee the funds incurred should the anticipated status of the award change.
- IV. Expenditure of Restricted Grant and Contract Funds
Spending on the restricted account is to be done in accordance with the sponsor-approved budget and the principal investigator's respective department, school, center, or institute's procedures. The Grants, Contract, and Plant Accounting office monitors the account for compliance with applicable regulations.
Compensation for university personnel from grants or contracts must be made in conjunction with sponsor guidelines and established university employment and payroll procedures. Faculty may be eligible to receive compensation for summer effort or extra compensation from external funds in accordance with sponsor regulations, appointment type, and faculty policies. Assistance with issues related to any of the above can be found in Policy 19.050.
Investigators with funded facilities and administrative cost bearing proposals may be eligible for a research incentive account, subject to the guidelines established in Policy 19.053.
- V. Modifications to Awards
Examples of modifications include, but are not limited to, budget revisions, extensions of time, change of scope, and change of investigator. All modifications to an externally funded award must be approved by ORSP and the sponsor. ORSP will initiate all formal requests for modification with the sponsor. Written approval from the sponsor must be received by ORSP before the requested change can be implemented.
Federal awards under expanded authorities allow Ohio University to rebudget proposed funds without prior approval from the sponsor. Questions regarding expanded authority and its application to awards should be directed to ORSP.
- VI. Subcontracting and Consulting
Subcontracting is the formal mechanism by which Ohio University passes or receives some level of responsibility and corresponding funding to or from another institution or entity to complete work agreed upon by both parties, as proposed in a grant application. In addition to the implementation of subcontracts described below, the inclusion of a subcontractor in a proposal is subject to Policy 19.050.
- A. Subcontracting to Ohio University
Subcontracts made to Ohio University are treated as externally funded awards and are subject to the above sections II through V.
- B. Subcontracting by Ohio University
All services purchased through a subcontractor are subject to Policy 55.007. Funded grant proposals with an identified subcontractor are exempt from the bidding process because the use of the specified subcontractor is a condition of the grant. Guidelines for a waiver from competitive bidding are available from the Purchasing and Contracting Office, VP Finance and Administration (see https://www.ohio.edu/finance/purchasing/waiver.cfm).
ORSP is responsible for the creation and execution of a subcontract. The minimum documentation requirements for a subcontract are:
- Institutional official signatures from both parties
- Subcontractor points of contact information
- Subcontractor budget
- Subcontractor statement of work
Once the subcontract is fully executed, a blanket purchase order is prepared by ORSP, established by Purchasing and Contracting, VP for Finance and Administration, and sent directly to subcontractor. The principal investigator is responsible for approving invoices from the subcontractor and forwarding them to the Grants and Contracts Accounting office for payment.
- C. Consulting
The use of consultants in externally sponsored research and other activity requires the use of a service provider agreement. Investigators shall contact ORSP managers to arrange for the creation and execution of such a document.
- VII. Reporting and Overdue Reports
Externally funded research or programs may require any or all of the following reporting documents, annually or at period end (responsible party indicated in parentheses):
- Financial (VP Finance and Administration, Grants, Contract, and Plant Accounting)
- Technical (Principal Investigator)
- Patent (VP Research, ORSP)
- Equipment (VP Finance and Administration, Grants, Contract, and Plant Accounting)
Principal investigators must submit final technical reports to ORSP within 90 days of the project end date. Any technical reports identified as delinquent by a sponsor may result in ineligibility for new research challenge funds until the report is received by ORSP. When the final report is not submitted within 90 days of the project end date, all PI or Center Research Incentive funds, up to the total direct costs of the grant, will be frozen until the report is accepted by the agency. The PI will be precluded from receiving any new grants until the report is accepted by the agency.
- VIII. Equipment
Equipment purchased using grant funds is subject to Policy 19.055. Title to such equipment vests with Ohio University unless otherwise indicated in the conditions of the grant award. All equipment is tagged specially and inventoried by Grants, Contract, and Plant Accounting, VP for Finance and Administration.
Proposed revisions of this policy should be reviewed by:
- Vice President for Research
- Associate Deans for Research
- Council for Research, Scholarship and Creative Activity
- Faculty Senate
- Administrative Senate
- Director of Student Financial Aid and Scholarships
- Payroll Manager
- Chief Human Resource Officer
- Forms, References, and History
- A. Forms
The following forms are specific to this policy:
- The Proposal Transmittal Form is available from the Office of Research and Sponsored Programs, or online from http://www.ohiou.edu/orsp/orsp_transmittal.htm.
- The Pre-Award Authorization Form is available from the Office of Research and Sponsored Programs, or online from http://www.ohiou.edu/orsp/budget/preaward_form.htm.
- The Request for Waiver from Competitive Bidding is available online at https://www.ohio.edu/finance/procuretopay/forms.cfm.
- B. References
The following items are relevant to this policy:
- Policy 19.050, "Submission of Proposals for External Support of Research or Other Activities."
- Policy 19.051, "Guidelines for Sponsored Research."
- Policy 19.053, "Cost Recovery and Distribution of Research Incentive Funds."
- Policy 19.055, "U.S. Government Excess Equipment."
- Policy 55.007, "Purchasing - Competitive Bidding."
- C. History
Draft versions of this policy that were circulated for review, their cover memos, their forms, and Reviewers' comments on them are available on the password-protected Review site, at https://www.ohio.edu/policy2/19-045/.
Prior versions of this policy were approved on:
- February 1, 1995
- April 3, 1981
- December 15, 1979
- April 1, 1979