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3.10.5 Control of Sponsored Research/External Funds PDF Print E-mail
Thursday, 03 September 2009 13:08

3.10.5 Control of Sponsored Research/External Funds

The institution maintains financial control over externally funded or sponsored research and programs.

Responsible Unit: Division of Business and Finance

Compliance Judgment

Compliance

Narrative
North Carolina Agricultural and Technical State University (A&T) maintains contractual, research compliance, and financial control over externally funded sponsored research through the Research Administration Department in the Division of Research and Economic Development (DORED) and the Office of Contracts & Grants in the Division of Business & Finance. [1] [2] [3]

Research administration consists of three offices:

The Office of Research Services (ORS) supports faculty as they prepare proposals for sponsored programs. The office aims to increase competitiveness for funding by assisting in identifying appropriate funding opportunities, writing proposals, preparing budgets, and providing training for faculty and grant administrators. Research services also facilitate development of interdisciplinary research programs. [3]

The Office of Sponsored Programs (OSP) is required to evaluate all proposals, awards, agreements, or contracts prior to submission in order to certify that commitments made can be honored, and verify the accuracy of the information supplied. Each application is evaluated for compliance with university policies, agency guidelines, and where applicable, federal regulations (i.e., animal use, human subjects, conflict of interest). OSP works in concert with departmental offices and central administration to prepare and submit the application. Under a specific delegation of authority from the vice chancellor for research and economic development (VCRED), OSP has signatory authority to enter into legal commitments for the university for all proposals, grants, cooperative agreements, and contracts associated with research and training activities. [4]

The Office of Research Compliance (ORC) provides service as a liaison for researchers, study participants, federal agencies, and the research committees to ensure efficient processes related to the ethical conduct of research at A&T. [5]

ORC coordinates the administrative business of four research review committees:

Researchers can contact the Compliance Office for assistance in the application process, interpretation of committee guidelines, and locating information to assist with protocol development. Study participants may contact the Compliance Office regarding their rights while participating in research studies. Researchers themselves should be contacted for information regarding their particular research study. Adverse events, unanticipated problems, and research misconduct reporting may be facilitated through the Compliance Office and according to all applicable university policies.

The Office of Contracts and Grants (OCG) within the university Comptroller's Office is responsible for the administration of financial accounting for all sponsored agreements awarded to A&T, the development of financial policies and procedures, the preparation and/or review of all financial reports concerning contracts and grants. This responsibility includes the following:

· Providing support for the administration and financial management of contracts and grants.

· Administering cash flow related to contracts and grants.

· Submitting all required financial reports.

· Maintaining an auditable effort reporting system.

Guidance for the administration of contracts and grants is provided from several sources. The primary sources are:

· Federal circulars, OMB A-21 and A110 [10] [11]

· Individual regulations from the various awarding agencies

· Periodic policy guidance from the State of North Carolina

· Budget manual, Office of State Budget and Management [12]

· North Carolina A&T State University Policies and Procedures [2] [13]

· University of North Carolina General Administration policies [14]

Overview of Responsibilities

Guidelines: All proposals must be internally reviewed and signed by the vice chancellor for research prior to submission to the sponsor. Principal investigators (PIs) do not have the authority to negotiate for and/or commit to the performance of a proposal on behalf of the university. [1]

No proposal should be submitted to the Office of Sponsored Programs without prior review and approval by the PIs chair and dean.

Individual departments or units may have their own procedures that must be followed prior to submission to OSP. [12] [13]

Principal Investigators/Project Directors (PI/PD): Sponsored projects administration is a joint effort between the PI/PD and the university. The PI/PD is held accountable for the proper fiscal management and conduct of the project. The university is held legally and financially responsible and accountable to the sponsor for the performance of the activity funded and the proper use of funds, but without the full cooperation and oversight of the PI/PD, A & T would be unable to fulfill its stewardship role.

The PI/PD is responsible to the university and to the sponsor for assuring that the scope of work for which the award was made is completed, that A&T policies and procedures are adhered to and that funds are expended in accordance with the awarded budget and sponsor terms and conditions.

While the PI/PD may delegate some responsibility for day-to-day management of finances or other tasks to departmental and school business staff, the PI/PD remains accountable for compliance with university policy and sponsor requirements.

Department Chairs: The department chair is responsible for establishing and maintaining high standards of ethical conduct and fiscal responsibility in the unit and for fostering a culture of compliance with regulations and policies pertaining to sponsored research. The department chair reviews and approves the proposal being submitted to verify that the principal investigator can effectively manage the program, given other academic and administrative commitments, as well as to confirm that proposals and programs are in accord with department/school objectives.

The department chair assesses the adequacy of the budget and how it will impact departmental finances, and reviews any additional space or cost-sharing requirements given the scale of the program. In signing a proposal, the department chair also accepts financial responsibility for the department for any eventual overruns and/or cost disallowances.

The department chair also approves certain expenses or actions related to the program such as stipend payments, tuition, new hires, and cost-sharing commitments. Where possible, the department chair provides departmental assistance in preparing and submitting appropriate documentation for financial and other administrative transactions.

If research involves investigators from more than one department/unit, one department is selected to administer the award (admin department), but each department/unit must still provide approval for the use of space, personnel, and/or equipment to be used on a particular project.

Deans of Colleges & Schools: The dean's office reviews the proposal to verify that the faculty member is eligible to be a principal investigator and can effectively manage and properly conduct the proposed program. The dean's office also reviews budgets, gives official approval to any cost-sharing commitments or provisions for additional resources, and confirms that proposals and programs are in accord with department/school objectives.

The dean's office will accept financial responsibility for any eventual overruns and/or cost disallowances, and will often provide local administrative support for the program once funded.

In the event that signature authority has been delegated to another person for purposes of approving the Internal Processing Form, a copy of this delegation is kept on file in the department. However, the respective dean of the school or college has ultimate responsibility for the department/center/institute named on the application.

Pre-Award: The vice chancellor for research and economic development, through the Office of Research Services (ORS) and the Office of Sponsored Projects (OSP), is responsible for the operations of pre-award administration. The OSP directs the pre-award administration and ensures compliance with the proposal policies of the university which are posted on the DORED Web site (http://www.ncat.edu/~divofres/). The budget manager in the ORS ensures budgetary and financial compliance with the policies of the university and those of the sponsoring agency in the proposal preparation stage and in the initial creation of the budget for the awarded project.

Post-Award: The vice chancellor for business & finance, through the Office of Contracts and Grants (OCG), is responsible for the operations of post-award administration. OCG reviews expenditure transactions for compliance with applicable laws, regulations, university policies, and specific agreement conditions, and provides all data and information needed during federal and other financial audits of sponsored projects.

Indirect Cost Rate: A&T has negotiated an indirect cost rate agreement with the Department of Health and Human Services that is based on 40% campus or 26% off-campus of the Modified Total Direct Costs (MTDC) for research. As stated in the Colleges and Universities Rate Agreement, MTDC consists of all salaries and wages, fringe benefits, materials, supplies, services, travel and sub grants and subcontracts up to the first $25,000 of each sub grant or subcontract, regardless of the period covered by the sub grant or subcontract. MTDC excludes equipment, capital expenditures, tuition remission, rental costs of off-site facilities, scholarships, and fellowships as well as the portion of each sub grant and subcontract in excess of $25,000. [15]

Indirect Cost Rates
(effective thru 6/30/10)

Type

On-Campus

Off-Campus*

Research

40%

26%

Instruction

41%

26%

Other Sponsored Activity

34%

26%


 

* use when more than 50% of the project is performed off-campus

PI Training: The Offices of Contracts & Grants (OCG) and Office of Research Services (ORS) offer PI training classes each semester. The training classes are continuously updated to ensure the appropriate coverage of pertinent rules and regulations, the implementation of university policies and procedures and full participation by staff and faculty who are required to know the material for the performance of their respective duties.

RAMSeS@NCAT: A&T uses a new electronic research administration system called RAMSeS@NCAT that is administered by the Division of Research and Economic Development (DORED) and used by ORS and OCG. RAMSeS is a Web-based system that is accessible through the Internet and will result in time and effort efficiencies. [1] [2] [16]

RAMSeS is a "cradle-to-grave" research proposal and award management system that provides a full range of functionalities, from pre-award (creation and electronic routing of new proposals, including electronic departmental approval and principal investigator certification) through post-award (account setup and award management), and also serves as a data repository with a comprehensive reporting functionality.

Effective July 1, 2008, proposals are now submitted to the OSP through RAMSeS, which allows the office to retain an electronic copy of all documents associated with proposals and awards. This also allows the principal investigator (PI) to post drafts of the proposal and budget for review by ORS. [3]

There is a link for RAMSeS on DORED's homepage. Any A&T employee may log into the system using the e-mail handle and password. [1]

DORED offers training sessions for principal investigators and approval training sessions for chairs and deans. Individual and small group sessions are available.

Inasmuch as RAMSeS provides a full range of functionalities and may be readily adapted to meet the needs of other institutions, UNC General Administration (UNC-GA) is requiring that it be implemented across UNC's seventeen-school system. [17] Having RAMSeS in place will benefit the UNC System by not only providing standardization across all campuses, but also by greatly streamlining and improving GA's data collection and reporting efforts.

A&T is the second UNC school to implement this system, but all UNC System schools must be active by September 2009.

IRBIS@NCAT: IRBIS@NCAT is the new electronic system used by the Institutional Review Board in the Division of Research & Economic Development (DORED) for administering protocols for research involving human subjects. This system interfaces with RAMSeS@NCAT and is administered by the Office of Research Compliance. [5] [18]

DORED also maintains and updates polices for research misconduct, conflict of interest and export compliance. [19] Certifications for these areas are included in RAMSeS@NCAT as a part of the proposal preparation process. Any potential violations of these policies are investigated jointly by the DORED and the Division of Business & Finance before referral to the provost and Office of Academic Affairs.

Supporting Documents

[1] DORED Website

[2] Business & Finance Website

[3] Office of Research Services Website

[4] Office of Sponsored Programs (OSP)

[5] Office of Research Compliance (ORC) Website

[6] Institutional Animal Care and Use Committee (IACUC) Website

[7] Biosafety Committee (IBC) Website

[8] Radiation Safety Committee (RSC) Website

[9] Institutional Review Board (IRB) Website

[10] Federal Circular OMB -A-21

[11] Federal Circular OMB A-110

[12] NC Office of State Budget Policy Manual

[13] NC A&T Spending Guidelines

[14]    UNC-GA, Sponsored Programs Website

[15] Indirect Cost Rate Agreement

[16] DORED Policies and Procedures

[17] RAMSeS

[18] DORED Forms

[19] Policy, Ethical Standards in Research, Misconduct

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Last Updated ( Tuesday, 16 February 2010 14:11 )
 

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