A. Programmatic
Requirements and Institutional Control:
1.
All externally-supported grant and contract activity at the University must
be directly related to the University's Mission, Vision, and Five-Year
Strategic Plan.
2. The continuity of support for the University’s ongoing functions
must not be endangered by the acquisition of research grants and contracts.
3. All faculty effort supported by
external grants and contracts must be consistent with faculty roles as
defined in the Faculty Policies and Procedures Manual, and an
appropriate balance between grant/contract activity and instruction must be
preserved.
4. Externally-supported grant and contract activity once approved and
funded is
considered considered to be a part of the faculty
member’s assignment for the duration
of the grant/contract period. As such, the activity
is supervised and evaluated in
accordance with the policies set forth in the Faculty
Policies and Procedures Manual.
5.
Grants and contracts must be awarded for specified periods of time.
6. In accepting funds from outside agencies, Longwood University assumes
programmatic and financial responsibility for grant- and
contract-supported activity
conducted by faculty members. At the same time, the
University ensures the
investigator’s freedom to investigate and report results,
as guaranteed by the
Statement
on
Academic Freedom in the Faculty Policies and Procedures Manual.
B.
Pre-Award:
1.
Any faculty member intending to apply for a grant or contract should meet
with the department chair and dean to discuss the proposed project.
Upon approval to proceed with the application, the faculty member should
notify the Grant's Office (Lancaster 213C) of the intent to seek support.
This will serve to eliminate any duplication of effort in the event an
other individual has already applied to the same grantor. This intent
requires the name of the project, the name(s) of potential funders, and the
anticipated grant or contract award amount.
2.
Once the application for the grant or contract has been completed, the
faculty member attaches a Sign Off Sheet for Grant Grant/Contract Proposal
Approval available for download at grantssignoffsheet.htm.
This must be approved by the Department Chair, the School Dean, the Vice
President for
Information Technology (only if the proposal
requires technology equipment or services), the Grant's Administrator, the
Human Resources Office, the
Vice President for
Administration and Finance, the Vice President of the affected area, and the
Vice President for University
Advancement or Director of Corporate and Foundation Relations (only
if seeking support from a private foundation, business, industry, or
individual).
3.
Grant and contract proposals requiring matching cash contributions from the
University must indicate the proposed funding source of the match.
This includes Banner budget codes and prior approval by the Vice President
for
Administration and Finance. A copy of the proposal must be
sent to the Grant Office (Lancaster 213C).
C.
Rates:
1. Indirect Costs
Recovery Rates: The cognizant agency for federal grants and contracts
is the U.S. Department of Health and Human Services. The current federal rate
is forty five (45) percent. The rate for private and state
grants is fifteen (15) percent of total expenditures.
2.
Fringe Benefit Costs:
a. Salaried
(full-time), Administrative and Professional (A/P) (full-time) and
Classified rate = fifty (50) percent of total salaries.
b. Wage (part-time), Administrative and Professional (A/P)
(part-time) and general rate = seven point six five (7.65) percent of
wages.
c. Federal and College Work study rate = zero.
d.
Graduate Assistant wage = seven point six five (7.65) percent of wages.
D.
Receipt of a Grant/Contract:
1. Grant/Contract Project Directors must forward a copy of their approved
grant proposal, award notification, itemized budget, and any
additional information to the Grant Office at the time of
the grant award or notification. The Grant Office is responsible for
maintaining a complete grant/contract file for audit.
2. The Grants Office will set up the account in Banner. The
responsible person for this account will be the Project Director.
The Grant Office will enter and monitor the budget on Banner.
3. Project Directors will have online access to Banner to monitor
their budgets. Project Directors will be responsible for ensuring that
expenditures are appropriate for their grant or contract and that funds
are available in their grant/contract budget.
E.
Reporting and Receipting of Funds:
1. The Grant Office will be responsible for all financial
reporting to the grantor. The Grant Office, using a spread sheet
listing each grant/contract and their budgets and expenses, will supervise
reporting.
2. The Grant Office will submit any reimbursement requests required by the
grantor and will deposit those reimbursements into the proper
account. Any funds received by the Project Director will be
sent directly to the Grant Office within twenty-four (24) hours of
receipt of funds for deposit into the proper account.
3. If an internal budget covers more that one fiscal year, any
continuing balance will be carried
forward from one fiscal year to the next.
4.
Unexpended funds at the close of a grant or contract will be disposed of according
to the provisions of the grant or contract. If no provisions are
made, the Project Director will contact the grantor to determine
the proper disposition.
F.
Audit of Grants and Contracts: The
Auditor of Public Accounts will audit all grants and
contracts annually. The
Internal Auditor upon request may audit grants and contracts. The
Grant Office will maintain a complete file of financial documents for a period
of five (5) years. Project Directors must keep adequate documentation of
activity related to their grant or contract for at least five (5) years
and are responsible for adhering to all terms of the grant or
contract.
G. Indirect Costs:
1. The Commonwealth of Virginia requires
that thirty (30) percent of indirect costs received will be transferred
to Education and General revenues in support of grant and contract
administration costs. The
remaining seventy (70) percent of indirect costs may be retained
by the institution to fund the conduct and enhancement of research and related
requirements.
2. Upon receipt of indirect costs from the grantor, the revenue will
be distributed so that thirty (30) percent will go to E&G/other
revenue and seventy (70) percent to a restricted cost pool. The
thirty (30) percent E&G/other revenue is available to fund E&G operations
and matching requirements of other grants and contracts. The seventy (70)
percent indirect cost pool is equally divided between two (2) restricted cost
pools. One is available for grant seed money and cost of grants
and contract administration. The second is available for
each the academic department generating the indirect cost. Use
of these funds must be approved by the Vice
President for Administration and Finance and/or the department chair.
These funds do not revert at the end of each year.
H.
Procurement of Goods, Supplies, and Services: All Commonwealth of
Virginia and University policies for procurement must be adhered to for
all grants and contracts procurement regardless of funding source. An
exception only occurs when the grant or contract specifies in the
original contract a specific source of materials or services required by
the project.
I. Sub-agreements/Subcontracts and Consultants:
1. When
preparing proposals for external funding that include a transfer of a
portion of the research or substantive effort of the prime award to
another institution or organization, or in seeking professional
advice or services from external sources, a determination must be
made during the proposal development stage as to the appropriate
mechanism for this transfer of effort, or outside consultation. The two
(2) mechanisms commonly used are the issuance of a sub-agreement
or a consultant agreement.
2.
A sub-agreement is a document written under the authority of, and consistent
with the terms and conditions of, a prime award (a grant, contract or
cooperative agreement) that transfers a portion of the research or
substantive effort of the prime award to another institution or
organization.
3. A consultant is an individual hired to give professional advice or
service for a fee but not as an employee of the hiring party. The term
"consultant" also includes a firm that provides paid
professional advice or service. Recipients of federal funds are
expected to have policies governing their use of consultants and
to apply these policies consistently regardless of the source of
support, and are expected to justify the use of consultants instead
of salaried employees.
4. According to OMB A-21, employees may not consult for their own
institution unless that consultation is cross-disciplinary.
J.
OMB Circular A-21:
1. OMB Circular
A-21, Cost Principles for Educational Institutions, establishes
baselines for costing activities. These baselines now incorporate four
(4) of the Cost Accounting Standards (CAS). These standards address consistency
in costing and reporting of costs. Adherence to the standards is mandatory
even for institutions that do not have to submit formal disclosure statement
on such practices to their cognizant auditors. Institutionally
approved baselines will be provided to faculty by the Grant Office.
2. Section J.8 of OMB Circular A-21 specifies the regulations with
regard to intra-university consulting (normally unallowable) and to salary
remuneration (no additional salary beyond the academic year base
salary) for participation in research activities during that academic
year. The regulations explicitly prohibit salary augmentation from
research, education, or scholarly endeavor funds during a period covered
by the term of the faculty appointment (i.e., you cannot charge a
higher rate on research, education, or scholarly endeavor grants
than you normally receive from your institutional base salary).
Similarly, they prohibit reimbursement to faculty members for
internal consulting during such a period. The only exception to
the consulting statement is in clearly defined situations where
the consulting is across college or departmental lines and/or a
separate activity for which one is not regularly compensated. Of
course, individuals may earn salary during the summer months (utilizing the
same base rate calculation process). This calculation process consists
of the base rate divided by the number of months of the term of
the original base salary to arrive at a monthly salary. To
alleviate difficulties, the institution requires consistency in costing.
K. Conflict
of Interest:
1. Conflicts of
interest occur when an officer or employee or member of his or her immediate
family has a personal interest in, or benefits or suffers from, his or her participation
in a contract or transaction considered by the University.
2. No office or employee of any governmental agency shall have a
personal interest in a contract with the government agency of which he/she
is an officer or employee, other than his or her own contract of
employment.
L. Certification
of Time/Effort Reporting: OMB Circular A-21, Cost Principles for
Educational Institutions requires that faculty certify the effort
devoted to sponsored projects. The certification effort by a faculty
member is a legal certification and must in all cases be defensible on audit.
At least annually a statement should be signed by the employee,
principal investigator, or responsible official(s), using suitable means of
verification that the work was performed.
M. Cost Sharing and/or University Contribution:
1. Cost sharing is
the portion of the total project costs of any sponsored agreement that
is not provided by the sponsor. Cost sharing should be engaged in only
when
a. mandated
by the sponsor;
b. needed to accurately reflect the level of effort required to
conduct the project; or
c. necessary due to the competitive nature of the award.
2. All cost sharing
must be documented and identified in the University's accounting system. If
the sponsor as a condition of the award accepts cost sharing, accurate
accounting records must be maintained to verify that these funds have
been provided. Cost sharing, whether voluntary or mandatory, must in
all cases be justifiable on audit. To qualify as cost sharing, costs
must be all of the following:
a.
verifiable through effort reports or other appropriate documentation;
b. necessary and directly related to the project objectives;
c. not included as contributions for any other federally assisted
project or program in either the current or a prior period; and
d. provided for in the approved project budget.
Further information
on cost sharing and institution contributions may be found in OMB Circular
A-21, Cost Principles for Educational Institutions, and OMB Circular
A-110, Grants and Agreements with Institutions of Higher Education,
Hospitals, Nonprofits.
