GRANTS MANAGEMENT

MANUAL STANDARD OPERATING

PROCEDURES

Published October 26, 2019

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Table of Contents Grants Management Overview and Standard Operating Procedures- 2 Pre-Award- 3

A. Introduction- 3 B. Policies and Procedures- 3

Dissemination of Funding Opportunities and Information- 4 Finding Funding – Sponsor Announcements- 7 Proposal Development, Review, and Approval- 9 Submission Process and PI Checklist – 9 Proposal Submission- 12

A. Negotiation and Acceptance- 12 Post-Award Management- 13 Post-Award Process- 15

1. Receiving the Contract/Award- 15 2. Grants/Contracts Award Notices- 15 3. Negotiation and Acceptance-16 4. Communications/Dissemination- 16 5. Project Account Setup- 16 6. Continuing Grants and Contracts-17 7. Responsibility and Compliance- 17 8. Time and Effort Reports and Certifications- 17

Time and Effort Reporting Policies- 19

1. Legal Basis- 21 2. Definitions- 21 3. General Rules- 22 4. Required Personnel, Frequency and Process- 22 5. Report for Establishing Payroll Distribution- 23 6. Time & Effort Reports- 24 7. Certification Schedule- 25 8. Instructions for Preparing and Processing of Time & Effort Forms-26

Files Management and Archiving- 35 Reporting- 36 Grants Management - General Roles and Responsibilities- 38 Equipment- 39 Cost transfers-40 Program Income- 42 Project Closeout and Property Management and Disposal- 43 Appendix- 46

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Bethune-Cookman University GRANTS MANAGEMENT MANUAL STANDARD OPERATING PROCEDURES Grants Management Overview and Standard Operating Procedures The Bethune-Cookman University, Office of Sponsored Programs and Research provides specific assistance to faculty and staff with the management and administration of grants for the University.

• Assists with processes and compliance issues related to funding agency or organization regulations and standards, and monitors adherence to college administrative, fiscal and accounting policies, procedures, and fiscal reporting related to grant proposals and funding.

• Provides advisory services and assistance in the planning and development

stages of grant budgets, spending plans, and accounts. Prepares budget estimates and justifications; and provides advice and technical assistance to grants’ program staff.

• Meets regularly with Principal Investigators (PIs) to review and reconcile budget(s) and account(s).

• In collaboration with the grant program principal investigator, prepares

special programs/grant project funding reports, financial reports and summaries.

• Works with PI’s and the Business Affairs Office to ensure that cost codes

are acquired in a timely manner and grant fund drawdowns occur on a regular basis.

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• Assists in the preparation of grant proposals, to include guidance and assistance in budget preparation and interpretation of funding agency or organization regulations and requirements.

• Develops and maintains specialized databases and record management

system for recording and tracking grant proposals, awards, and related statistical information; creates and distributes standard and special reports, summaries and analyses as required.

• Maintains current knowledge of grant funding policies, regulations, and

procedures, disseminates and presents information to staff; advises on the implementation of changes and on the impact of changes on funded operations.

• Monitors grant programs accounting, audits, and fiscal reporting. Performs

internal control reviews, and assists with the development of internal control plans and internal accountability procedures.

Pre-Award

A. Introduction Pre-award services are the activities and processes that legally and ethically enable an institution to obtain externally funded research and sponsored programs. The exact nature of those services varies, depending upon the size of the unit, its culture, and mission. Pre-award services generally include:

1. Dissemination of funding opportunities and information 2. Assisting with the proposal development 3. Reviewing and approving proposals to be submitted by the

institution 4. Managing the proposal submission process 5. Negotiating, accepting, and activating an award

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B. Policies and Procedures The Office of Sponsored Programs and Research, will issue the necessary guidelines, norms and procedures, or will amend the existing ones to implement what is established in this Policy. Each sponsored project represents a contract between the grantor (government agency, foundation, or corporation) and the university. For this reason, all faculty and staff members seeking external support from a government agency or office must obtain administrative approval through this office. Please contact us early enough to ensure that we have sufficient time to obtain the necessary approvals to submit your application by the sponsor due date. Dissemination of Funding Opportunities and Information The first step toward external funding success is the identification of sources of funding opportunities and search for sponsor information. The Office of Sponsored Programs and Research must disseminate this type of information. This information is deemed precious particularly to those new to grant seeking processes, or established investigators seeking new funding opportunities. The information available to the university community through the latter offices/services, as well as the one presented herein, must be periodically updated to assure that the university keeps abreast about common and new sources of funding, and new developments affecting the grant-seeking process. Investigate Existing or Prior Awards. It is also important for those seeking support for a sponsored project/program to verity if a similar or closely related one is or has already been funded or completed. Representative databases are:

• the NIH RePORTER - provides a database of biomedical research funded by the National Institutes of Health (NIH),

• NSF FastLane - provides information, including abstracts, for awards made since 1989,

• federal Department of Education awards can be found in the Award Databases for U.S. Department of Education Grants and Contracts, and

• USDA Current Research Information System (CRIS) - provides information on over 95% of all publicly supported agricultural and

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forestry research, and some US Geological Survey research.Research.gov

- Online easier access and services to National Science Foundation (NSF). Researchers, Principal Investigators (PIs), Co-PIs, and sponsored programs offices can use their university-issued user ID and password to access FastLane services through Research.gov. To promote and foster competitiveness and excellence in grantsmanship skills, the Office of Sponsored Programs and Research will present funding-related workshops on locating funding, funding database use, proposal development, research compliance, as well as other funding topics, upon request. Finding Funding – Funding Opportunity Databases. Historically, BCU has established and values its relationship with a broad range of federal, non- federal, private and public sponsors. To find and explore the universe of sponsors available to university faculty, staff and students, a series of professional organizations (i.e., SRA International, NCURA), as well as sponsors themselves, provide links to a number of resources for locating funding opportunities, including web-based resources. In addition, individuals may subscribe to periodically receive via email personalized funding opportunity announcements free of charge or for a fee (i.e. Grants.gov Email Notices). Examples of valuable Funding Opportunity Databases are:

• Grants.gov - is the main source to find and apply to all federal government grants funding sources. Today, Grants.gov is a central storehouse for information on over 1,000 grant programs and provides access to approximately $400 billion in annual awards. Individuals may subscribe for free to Grants.gov Email Notices to receive grant notices for specific or all federal grants

• Catalog of Federal Domestic Assistance (CFDA) – CFDA, compiled and maintained by the General Services Administration (GSA), is "a government-wide compendium of all 1,412 Federal programs, projects, services, and activities...”. It also includes a helpful section on writing grant applications.

• GrantsNet - A database of DHHS funding opportunities in biomedical research and science education. Includes information on research funding programs for graduate and medical students,

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postdoctoral fellows, and junior faculty, as well as programs in science, math, engineering, and technology for undergraduate faculty and students. Registration is free and provides access to a searchable, continuously updated funding resource.

• Community of Science (COS) – This commercial source, despite its name, COS includes information about sponsors in all disciplines. COS provides information on Federal, non- federal, and international opportunities. Expertise, a database of professional researcher profiles in North America.

• SPIN - Sponsored Programs Information Network – An InfoEd’s company service that provides detailed and timely information about thousands of Federal, non- federal and international funding opportunities. A user-friendly database, searches can be initiated through general keywords (Quick search) or specific criteria categories (Advanced search). A subsystem of SPIN, SMARTS / GENIUS notifies the registered participant of new funding opportunities via e-mail.

• GrantsWeb 2000 - From the Society of Research Administrators International (SRAI), provides links to a broad range of federal, non- federal, private and foundation sponsors.

• proposalCENTRAL - A web-based grant management solution for government, non-profit, and private grant-making organizations to simplify their operations by receiving and reviewing grant applications online. Participating organizations include members of the Foundation Commons.

• Foundation Center's Grantmakers - An excellent source of information about philanthropy worldwide, contains information on private foundations, corporate grantmakers, grantmaking public charities, and community foundations. This website includes links to more than 2,000 grantmaker websites.

• ScanGrants - Designed by Samaritan Health Services as a public service listing of grants and other funding types and sources to enhance individual and community health.

• SchoolGrants - created to share grant information on PK–12 education and educators. Provides a listing of a variety of opportunities available to public and private nonprofit elementary and secondary schools and districts across the United States.

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Finding Funding – Faculty and Student Fellowships. BCU encourages, and in certain academic and research programs requires, faculty and student application to external sources for fellowships. A list of fellowship awards available includes (please check specific websites for the most current information):

• American Cancer Society • American Heart Association • Bill and Melinda Gates Foundation • Burroughs Wellcome Fund • Cancer Research Institute • Charles A. King Trust/Medical Foundation • Damon Runyon Cancer Research Foundation • David and Lucille Packard Fellowships • Ford Foundation • Fulbright Scholar Program • Helen Hay Whitney Foundation • Human Frontier Science Program • Huntington's Disease Society of America • Irvington Institute for Immunological Research • Jane Coffin Childs Memorial Fund for Medical Research • Juvenile Diabetes Research Foundation • Leukemia Research Foundation • Leukemia and Lymphoma Society • Life Sciences Research Foundation • National Institutes of Health National Research Service Award • National Research Council -- Research Associateships Program • NIH Research Training Opportunities Home Page • US Congress –House of Representatives Internships

Finding Funding – Sponsor Announcements On a continuous basis, sponsors release program announcements in the form of Request for Proposals (RFP), Request for Application, (RFA), Funding Opportunity Announcement (FOA), Notice of Funding Announcement (NOFA), among others. These announcements are an important source of information, since they represent high-priority areas and funding allocations have been appropriately identified for those interested in applying. University community may access these

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announcements directly from the sponsor website or through the links provided herein or the unit webpages. Examples are:

• The NIH REQUEST FOR PROPOSAL (RFP) DIRECTORY has been established to provide Internet users with quick and easy access to RFP solicitations available at the NIH. The RFPs AVAILABLE by Institute sub directory, directly links to all currently active electronic RFPs issued by the appropriate issuing Institutes or Centers (ICs) of the NIH. All RFPs listed in this directory have been previously advertised in the FedBizOpps and the NIH Guide for Grants and Contracts.

• The Federal Business Opportunities (FEDBIZ.OPPS.GOV) website provides a more general source of information for all federal opportunities available to vendor/buyers, grant applicants, and entrepreneurs.

• NSF’S RECENTLY ANNOUNCED ACTIVE FUNDING OPPORTUNITIES.

• RURAL DEVELOPMENT - NOTICES OF FUNDING ANNOUNCEMENTS (NOFA) - Rural Development announces the availability of money for many of its programs in the Federal Register, through a Notice of Funds Availability (NOFA). Each NOFA lists the application deadlines, eligibility requirements and places where you can get more help in applying for program dollars.

In this case, the USDA’s Rural Development Grants Assistance is provided in many ways, including direct or guaranteed loans, grants, technical assistance, research and educational materials. Visit the following sites for information and/or assistance. Sample of specific topics are: Business and Cooperative Grant Assistance (rural enterprise/business development, renewable energy, biofuels); Housing and Community Facilities Grant Assistance (rural water and waste, preservation, community facilities); and, Utilities Grants (wastewater, solid waste, telemedicine and distance learning, high energy cost, well systems).

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Proposal Development, Review, and Approval Once university faculty, staff or student identifies the most appropriate sponsor and grant mechanism, the proposal development and preparation process begins. Proposals are typically very technical documentations that must adequately respond to all sponsor requirements. Failure to do so may lead to administrative withdrawal of submitted grants and awards by the sponsor. The Office of Sponsored Programs and Research, provide guidance in this process. Furthermore, a series of sponsors have developed excellent web-based resources to assist in the proposal preparation and submission processes. The web links to some of these sponsor sources are listed below:

Sponsor Weblinks for Applications Information NIH NIH Applications and Forms

NIH - Grants Process, Application Basics and Application

NSF NSF - Grant Proposal Guides NSF - How to prepare Your Proposal

NASA NASA - Guidebook for Proposers Responding to a NASA Research Announcement

Department of Education (DE)

DE - Grants Information

Submission Process and PI Checklist

• IDENTIFY: (PI) Locate an appropriate funding opportunity for your project.

• NOTIFY: (PI) Email your Department Chair and appropriate Official at

least two (2) weeks prior to the sponsor’s proposal submission deadline, regarding your “Intent to Submit a Proposal” for external funds or proposed grants.

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• Inform this office at the earliest opportunity that you intend to apply for funding. If given sufficient notice, this office can assist you in planning and developing your application as well as with technical matters.

• Provide the following pre-application information (“Intent to Submit a

Proposal” form) and materials to the Office of Sponsored Programs and Research at least ten business days before the sponsor deadline.

• SUBMIT ROUTING FORM: BCU’s internal “Intent to Submit a Proposal

Approval Form” (Appendix 1) must be completed in its entirety and routed appropriately. Signatures are required from the Project Director, the department’s Chair, Dean and Provost. This document ensures that the BCU administration has been made aware of, and endorses, the formal request for the grant. A copy of this document is then submitted to the Office of Sponsored Programs and Research for the University’s record.

• Pre-Application Information and Materials (To be provided at Least Ten

Business Days before Sponsor Deadline) Name of the sponsoring agency and specific funding opportunity, Project title, Proposed project/program period (we can assist you in determining these dates), Abstract (may be in draft form), Budget narrative/justification (with costs itemized and any cost sharing

specified), If cost sharing is involved, provide the account number(s) from which the BCU funds will be drawn, Contact information for project leader/administrator at each participating Institution (other than BCU), if any, Contact information for each individual, non-BCU contributor (consultant)

if any, A list of your current and pending support, if requested by the sponsor Any other financial information to be included in the application Any language that is to be included in the application and addresses whether

BCU will support/sustain the project beyond the award termination date.

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The information/materials listed above are requested ten business days prior to the external due date to ensure time for due diligence by this office and others involved in the internal approval process. In some cases, a project leader may not be able to prepare the materials as early as requested. In these cases, we will work with you (within reason) to secure institutional approvals in a shortened timeframe, but do not guarantee that the application will be approved for submission. This office is available to help develop applications and to review application narratives upon request. Regarding the latter, although every reasonable effort will be made to review your proposal as quickly as possible, given the workload of this office, the turnaround time may be as long as a week. For this reason, to ensure that you have time to finalize your application, we recommend that, whenever possible, you provide narratives to us at least two weeks before the sponsor deadline.

1. BUDGET SUPPORT: PI will work with the Sponsored Research Pre-Award Coordinator in the development of the budget to ensure that funding requests are compliant with both institutional and federal guidelines (Appendix 2). 2. OBTAIN Institutional Review Board (IRB) APPROVAL: Contact Institutional Effectiveness Specialist for any necessary IRB approvals or if you have questions as to whether your project will need IRB approval. (Please note that review by the Solicitor’s Office may still be required in some instances.) 3. FORMAL SUBMISSION: Submit completed, approved project (including narrative, budget, and Appendices) by the required deadline. If the proposal requires electronic submission (via Grants.gov, E-Grants, Fast lane, etc.), allow time prior to the due date to complete the process of online submission and confirmation. You must also allow time for the PI/PD to be set up on a grantor’s electronic reporting site such as Fast lane.

The final proposal materials should be submitted to this office in complete form at least three business days before the sponsor's deadline. Time is required

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for document compilation and proper review and to account for possible complications associated with any electronic submission system. Although we strive to be as helpful as possible, we cannot guarantee the successful submission of your applications if you do not provide all of the required materials in final form within this timeframe. In some cases, a letter of intent or other document must be submitted in advance of the complete application. If that document contains any financial information—even if it is just a total request amount, this information must be routed through this office prior to being released.

The simple rule is that anything with a dollar sign should be routed. This practice protects the integrity of the university by ensuring that the financial information released to sponsors is consistent with BCU's central records, which are subject to audit. We will do our best to ensure that the information you provide to us is reviewed in a timely manner.

Proposal Submission

• The Office of Sponsored Programs and Research, routes the final

proposal to the Authorized Organizational Representative (AOR) for submission to the sponsoring agency.

• PI/PD should be available to answer questions and resolve any

issues that may arise during the process.

A. Negotiation and Acceptance

• The PI/PD must be involved in any negotiation concerning the scope of the project and any changes in the budget. The role of the Office of Sponsored Programs and Research is to assure that there are no implicit or explicit obligations in the performance of the project that cannot be accomplished given the amount of time and budget. Usually, the scope of a project is reduced as a result of budget decisions or cuts in funding.

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• The Terms and Conditions of the award need to be assessed. It includes areas such as: period of performance, cost principles, patents and copyright, terminations, financial reporting, payments schedules, among others that are often negotiated in an award.

• The development of sub award agreements and contracts require

the evaluation of a variety of issues such as: payments schedules, subrecipient monitoring, facilities and administrative cost rates (F&A), among others. Two possible scenarios are:

• Subcontractor or subrecipient - When the institution is a

subcontractor or a subrecipient, the federally negotiated F&A rate is applicable to the institution’s budget, unless specific rates are provided by the sponsor.

• Contractor - If the institution is the prime contractor for a budget

that includes subcontracts or subawards, the appropriate BCU rate is assigned to the portion of the budget. With respect to subcontracts and subawards the DHHS agreement specifies that the institution collects F&A cost only on the first $25,000 of each subcontract in the BCU unit budget.

• All Grants and Contracts must be formally accepted by BCU to

complete a legal agreement between the sponsor and BCU. The formal acceptance of the award is the signal for the activation of the project.

Post-Award Management

Introduction Post-award administration begins when an award is received and there are multiple requirements and tasks as part of the post-award administration, which should not replace or substitute the exact specifications of various statutes and regulations. The post-award phase includes everything that happens from the time the award has been initiated until the project has been completed and closed out. There is a full range of post-award functions required for the

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administration of sponsor project whether funded by grants, contracts, or cooperative agreements. The 2 CFR, Part 200, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospital, and Other Non-Profit Organizations, establishes the requirements for post-award administration. Subpart C sets forth the minimum standards that an organization must meet in order to be a recipient of federal assistance awards. Those requirements are in the areas of:

1. Financial and program management 2. Property standards 3. Procurement standards 4. Reports and records 5. Termination and enforcement

Regulations applicable to contracts are contained in the Federal Acquisition Regulation (FAR) (https://www.acquisition.gov/far/). Other important documents necessary for successful post-award administration at universities are 2 CFR Part 200 (former OMB Circulars A-21), Cost principles for Educational Institutions and A-133, Audits of States, Local Governments, and Non-Profit Organizations and its annual Compliance Supplement. Below are significant post-award administrative processes/tasks:

1. Award terms and conditions 2. Allowable cost 3. Prior approval 4. Effort certification 5. Equipment 6. Cost transfers 7. Program Income 8. Award reporting and closeout

The post-award function includes the following types of activities:

1. Monitoring expenses for allowability, allocability, reasonableness, and compliance with university policies.

2. Reporting and invoicing the sponsor on project expenses.

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3. Draw down of funds in the form of checks and wire transfers, and posting them to the corresponding accounts.

4. Monitoring spending against budget, noting certain trends such as overspending or underspending.

5. Completing the required programmatic and financial reports. 6. Closing out the award by ensuring all requirements have been

satisfied, including collection of interim and final progress reports, invention reporting, equipment reporting, and salary certifications, among others.

Cash Management and cost accounting/cost analysis functions have a great deal of interaction with and are dependent upon the pre-award and post-award functions. Post-Award Process

1. Receiving the Contract/Award

When a grantor issues an award (or declination), official notification will be made via phone, letter, and/or email. Recipients typically include the President, the Office of Sponsored Programs and Research and/or Project Director. If awarded, BCU will receive an official Grant Award Notification (GAN) which must be fully executed by the BCU President.

2. Grants/Contracts Award Notices NOTIFY: Once a proposal is awarded, the award documentation will be received/forwarded to the Sponsored Programs and Research, for corresponding processes. This document is a legally binding document between the awarding agency and BCU establishing funding level, period of support, terms and conditions, and contact information, among others. The University is legally responsible for proper conduct and execution of the project and assures compliance with federal laws and regulations, and grantor’s policies and procedures.

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3. Negotiation and Acceptance Each sponsored project award comes with a unique set of terms and conditions, which may range from entirely flexible to restrictive. The PI/PD, in coordination with the Office of Sponsored Programs and Research, is responsible for reviewing the award documents and, if need be, negotiating the terms and conditions attached to an award. The goals in negotiation are to protect the investigator's publication and intellectual property rights; to protect the institution against harmful or unmanageable stipulations; and to ensure any agreement is in keeping with state and federal regulations as well as BCU requirements.

4. Communications/Dissemination The Office of Sponsored Programs and Research will send a news brief to the BCU Office of Communications for immediate release and dissemination to the academic community. All fully executed award notifications will be kept on file in the Office of Sponsored Programs and Research. It is the responsibility of the Project Director to forward a copy of the contract, budget (signed by the President), and award notification letter to the Office of Sponsored Programs and Research.

5. Project Account Setup Once all requirements and terms and conditions are discussed, the Post-Award Coordinator will begin the process to request a unique cost code/ account for each contract under the auspices of the College.

The Grants Accountant will assign an appropriate job code for BCU grants and contracts. The Project Director will be notified of the appropriate cost or job code(s) and will be expected to meet with the Post-Award Coordinator for appropriate training sessions for efficient administration of the grant. The Post-Award Coordinator and the PI will discuss the terms and conditions (project objectives and goals, period of performance, required sponsor’s

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programmatic reports frequency and deadlines, invoicing/drawdowns, allowable/unallowable costs) stated in the Award Notice. The training will be a function of the Office of Sponsored Programs and Research and will be provided to BCU staff as well.

6. Continuing Grants and Contracts The President is BCU’s signatory authority and serves as the project binding agent for all continuing contracts and grants, including amendments, renegotiated budgets, and annual budget requests that are awarded to the College. All fully executed documentation, including amended contracts, awards, annual reports, final reports, and close‐out documents should be sent to the Office of Sponsored Programs and Research for archival.

7. Responsibility and Compliance Grant awards are made to BCU, not an individual Project Director; therefore, BCU assumes full legal responsibility for ensuring that all funds received through the award are used for the purposes and intent outlined in the conditions of the contractual agreement. Grants and contracts carry administrative responsibilities, involving strict accountability. Principal Investigator/Project Director (PI/PD) The PI/PD has administrative and reporting responsibilities when managing a grant. It is the PI’s/PD’s responsibility to be cognizant of all award requirements and contract details, as well as the policies and procedures of BCU. It is duty of the PI/PD to review and oversee the successful completion of the contractual and grant funded activities. The Project Director will be responsible for communicating all programmatic, curricular, and budgetary issues for auditing purposes. A Federal employee may not be the PI/PD on any non-Federal grant. The list of full responsibilities is attached.

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8. Time and Effort Reports and Certifications As a recipient of sponsored funds, B-CU must assure Federal and other sponsors that the assignment of effort and associated salary and fringe benefit costs to the projects they sponsor is reasonable in relationship to the work performed, and that commitments to sponsors have been met. Federal regulations provide a basic regulatory framework for Effort Reporting. 2CFR Part 200 (Uniform Guidance) requires that any individual, who performed work on a federally sponsored project, including federally funded sub awards received from other institutions, industry or State, must certify that the effort, paid or committed, is reasonable. B-CU’s effort reporting policies and procedures are the mean by which these effort reporting and effort certification responsibilities are fulfilled. This overarching set of policies and procedures applies to all individuals whose salaries are charged to sponsored projects (in whole or in part), whose effort has been committed as part of cost sharing/matching funding, and whose responsibilities involve certifying the effort of other individuals. Non-compliance would affect the University’s reputation, jeopardize future funding from the federal government and collaborations with other institutions, and can lead to financial penalties and/or expenditure disallowances. For instance, disallowance of costs charged for salary and wages, would also limit the recovery of Facilities and Administrative (F&A) costs (i.e. indirect costs). Each personnel’s Effort Report accounts for 100% of the effort required in achieving the employee's obligation or professional activities for the University (Total Professional Effort, TPE) and for which the employee is compensated by the University in their institutional base salary (IBS). The institutional definitions of TPE and IBS are contained in this document. The purposes of B-CU Effort Reporting Policies and Procedures are: (1) to comply with the federal 2 CFR 200 Office of Management and Budget (OMB) Uniform Guidance, Cost Principles for Educational Institutions, and all other applicable federal laws and regulations, for the certification of effort performed on a federally sponsored program; and, (2) to assure that effort certifications completed in connection with University sponsored projects are accurate,

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reasonably reflect the actual level of effort expended on a sponsored project, and comply with sponsor requirements, terms and conditions in areas, such as:

• Salary charged to those projects, the commitment indicated (including mandatory and voluntary committed cost sharing) in the proposal and subsequent award, and in the corresponding estimates of facilities and administrative (F&A) costs (indirect costs) charged to sponsors.

Each faculty member must be aware of his/her:

• Level of committed effort to sponsored projects, ability to meet those commitments in light of any other obligations, and need to communicate any significant changes in level of sponsored projects effort to the university immediately.

All individuals involved in the effort certification process are expected to abide strictly by the policies and procedures contained herein. Time and Effort Reporting Policies

Each personnel’s Effort Report must reasonably account for 100% of the effort required in fulfilling the employee's obligation to the University that is his/her Total Professional Effort (TPE). For faculty personnel, effort (institutional or sponsored) may be dedicated to:

• Academic instruction, • Conduct of research, • Creative activity, • Teaching improvement, • Training, and/or services.

For full- time employees, 100% TPE does not equate to any set number of hours, e.g., 40 or 50 hours per week; it equates to the totality of University-compensated effort. TPE excludes effort outside of duties for B-CU:

• External consulting, • Non-B-CU appointments, • Other non-institutional professional activities, • Or volunteer/unfunded activities such as community service.

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University personnel may receive additional compensations or remunerations that may involve time and effort, therefore the corresponding effort must be included in the individual’s Effort Report. The remunerations received under these terms must accordingly be documented as part of the individual’s IBS. In conformity with sponsor requirements and institutional authorization(s), university personnel may commit and/or charge a percentage of their TPE (minimum of 1%, but not to exceed 100%) in sponsored programs/projects agreements. Consideration for maximum effort should be reasonably estimated. For example, any person who has administrative duties, instructional requirements, or office duties may not be charged 100% to sponsored projects as they must have some measurable amount of effort to account for these activities. The corresponding percent effort commitments for key personnel should:

• be consistent with the description of the individuals’ roles on the project and be reasonable given the nature and complexity of the project,

• reconcile with the individuals’ other current and pending responsibilities, including instruction, administration, sponsored projects, or other activities, and

• Not be inflated beyond what is reasonably required to accomplish the proposed work, and be consistently reflected on the corresponding institutional authorization documentation of a proposal.

The PI/PD will ensure that faculty and/or staff paid in full or in part by a grant certifies the accuracy of this time (i.e. effort) according to the procedures established by BCU in compliance with federal regulations. Once the “Report for Establishing Payroll Distribution” form (Appendix 2) and the “Time and Effort Report” form (Appendix 3) have been submitted, a copy of the record is printed, signed, dated and submitted to the Office of Sponsored Programs and Research. It is expected that the BCU protocols will be followed to ensure accuracy of time and attendance.

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9. Legal Basis

Federal Office of Management and Budget (OMB) 2 C.F.R. Part 200 (Uniform Guidance).

10. Definitions

In the application of these rules and procedures, the following terms are defined as follows:

• Faculty - University employee with an academic appointment. • Professional Personnel - Employees that require specialized academic

preparation, and in some cases, a license or permit, to practice their profession.

• Non-Professional Personnel - Employees that do not require specialized academic preparation to carry out their job functions, acquiring the necessary training and experience through their service.

• Effort- Effort is expressed as a percentage of the total amount {100%) of professional effort expended on University activities for which an institutional base salary is paid.

• Institutional Base Salary - For Faculty Personnel dedicated to academic instruction, who also conduct research, creative activity, teaching improvement, training, and/or services, is defined to be their annual permanent salary as it appears in the employment contract of the employee or subsequent letters of notice of salary increase/decrease plus any supplemental compensation of one full year or more. This annual permanent salary constitutes the base pay for the individual's total professional effort (100%), independent if his/her time is devoted to teaching, research, administration, creative activity, service, clinical activities, other activities and/or a combination of these, and in conformity with the provisions contained in General Rules of Bethune-Cookman University.

• Cost Sharing - cost sharing occurs when a portion of the total costs of a sponsored project are borne by the University, not the sponsor. Cost sharing/matching requirements may be in the form of an actual cash expenditure of funds, or may be an "in-kind" match, which is the value of non-cash contributions to the project (for example, a faculty or personnel percent effort commitment to a sponsored project/program).

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11. General Rules

Compliant to OMB 2 C.F.R. Part 220 (Uniform Guidance), the University engages the After the Fact methodology for initially charging federally sponsored agreements based on factors of an individual's effort commitment to sponsored agreements and the forecast of the individual's total University workload in relation to the individual's defined institutional base salary.

Subsequent changes that are considered significant such as the addition or reduction of sponsored agreements to an individual's workload are made to reflect the best estimate of expected actual results. At the end of each monthly period, forms are generated depicting the initial effort expended for an individual having charged labor and/or cost shared on a sponsored project for the period.

The effort profile presented is based on the payroll charged related to the individual's institutional base salary for the period and should represent by account 100% of the individual's sponsored and non-sponsored activities.

Each report is reviewed, changed when appropriate to reflect a reasonable estimate of the actual effort expended in relation to the charges for the period, and signed by the appropriate official(s) having suitable means of verification.

Labor cost transfers should be made to ensure payroll charged is aligned with the effort certified. The following procedures are provided for accomplishing the charging, reporting and certification of effort for faculty, professional and non-professional employees.

12. Required Personnel, Frequency and Process

Faculty and professional personnel charged and/or cost shared to federally sponsored projects, including research, training or any other sponsored agreement.

• Initially, the individual's institutional base salary (IBS) is defined to be their annual permanent salary as it appears in the employment contract of the employee or subsequent letters of notice of salary increase/decrease plus any supplemental compensation of one full year or more.

• When there is a change in the IBS, supplemental pay, and/or account distribution, a Human Resources Personnel Action Form is required to be completed by the department initiating the change that includes the base salary, status of the individual (part/full time) and the account to charge

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where a subsequent change is made. This document is the vehicle recognized by the Payroll Department to pay an individual and charge final cost objectives.

13. Report for Establishing Payroll Distribution

This form is required to be completed within a reasonable time (no more than 60 days) from the beginning of the academic year, when an individual is newly appointed and/or when significant changes such as the addition or reduction of sponsored agreements to reflect a reasonable estimate of expected effort actual results.

It should be completed summarizing all commitments the covered individual has as well as the accounts and pay listed on the Personnel Action Forms.

This form is used to present the individual's new 100% account profile and total pay. It is also used to obtain all necessary approvals. When sent to the Human Resources Payroll Department, establishes the amount that will be charged to applicable projects prospectively based on estimates to reflect devoted effort.

Estimates are based on factors of an individual's effort commitment to sponsored agreements and the forecast of the individual's total University workload in relation to the individual's defined institutional base salary.

Compensation that is non- effort related may not be included in the institutional base salary for determining estimates chargeable to federally sponsored awards unless prior approval has been obtained from the sponsor.

According to Uniform Guidance Part 2 CFR 200, in cases where consultation is across departmental lines or involves a separate or remote operation, and the work performed by the consultant is in addition to his regular departmental load, any charges for such work representing extra compensation above the base salary are allowable provided that such consulting arrangements are approved by the sponsoring agency.

• Form “Report for Establishing Payroll Distribution” must be accompanied with the supporting documents (Notice of Award/Budget Justification) and submitted to the Office of Sponsored Programs and Research.

• The Grants Accountant will review the form to ensure the accounts and amounts to charge are appropriate. Additionally, a review of the NSF

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requirement for faculty not to exceed 2/9 of salary for nine months contracts, unless approved by the agency.

• If the intended form for the faculty and/or professional personnel is not in accordance to the grant award, Office of Sponsored Programs and Research and/or the Grants Accountant will return the completed form to the individual and their supervisor for correction before labor charges are initiated.

• Otherwise the Grants Accountant submits it to the Human Resources Department for entry into the Payroll system by the Payroll Office.

• The Payroll Office is responsible for input of the Personnel Action Form, which supports and is summarized on the “Report for Establishing Payroll Distribution” form, into the University's payroll system.

• The “Report for Establishing Payroll Distribution” form must represent 100% of an individual' s effort profile (sponsored and non-sponsored activities across the institution) based on labor charges related to the institutional base salary and/or commitments by funding source for the period reviewed. The distribution of time and effort dedicated to distinct projects and programs for sponsored and non-sponsored activities will be on a percentage basis and must sum to 100%.

14. Time & Effort Reports

At the end the semester for all employees during academic year and at the end of summer term for all employees, following the certification schedule.

The distribution of time and effort dedicated to distinct projects and programs for sponsored and non-sponsored activities will be on a percentage basis and must sum to 100%.

The Certification Reports will be made available to the Office of Sponsored Programs and Research by the departments for its review, update and certification.

The certifier (employee) should review the “Time and Effort Certification” form to ensure it represents the effort devoted for each activity for the period.

Forms updated requiring labor cost transfers to appropriately align payroll charges with the actual effort expended must be executed immediately.

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The “Time and Effort Certification” form should be completed and certified by the employee or an official designed for this task.

Applicable labor cost transfers must be executed within the first sixty (60) days after the forms are available according to the following schedule:

15. Certification Schedule

Period Covered Forms Availability Date Certification Deadline

Fall January, 15th March 15th

Spring July 15th September 15th

Summer August 30th October 30th

If the Certification deadline is a weekend day or a Holiday the deadline will be the next working day.

• Certification. The “Time and Effort Certification” form will be signed by the covered named individual or an official(s) having suitable means of verification that is personally familiar with the activities and work done by the covered named individual for the period reported, and that possess sufficient technical knowledge that they can identify the covered named individual's effort in each project or program.

• The directors of departments, offices and/or programs and deans, each one at their respective level of responsibility, will ensure that the personnel under their supervision submit timely reports; reports are properly completed and signed by officials having suitable means of verification; and will apply disciplinary measures, consistent with the situation, when there is a lack of compliance.

• The Office of Sponsored Programs and Research will maintain the originals of the “Time and Effort Certification” forms (Time and Effort Reports) for all faculty and professional personnel under their jurisdiction. The Office of Sponsored Programs and Research will ensure all “Time and Effort Certification” forms are completed accurately, submitted timely, and are in accordance with University Effort Reporting policies and procedures.

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Additionally, the Office of Sponsored Programs and Research will maintain control of all financial accounts of federal, state and private/foundation funds under their jurisdiction.

Non-professional personnel will use time sheets to record actual time on projects and submit monthly for payroll and charge to University activities. Timesheets are maintained at the Human Resources office.

16. INSTRUCTIONS FOR PREPARING AND PROCESSING OF TIME AND EFFORT FORMS: 1) “Report for Establishing Payroll Distribution” and 2) “Time and Effort Certification” forms.

i. “Report for Establishing Payroll Distribution”: The following procedures will be followed with respect to establishing estimates to initially charge sponsored and non-sponsored projects:

ii. Faculty and Professional Personnel with the assistance of Department Administrators and the Office of Sponsored Programs and Research will complete the form to charge payroll as needed to appropriate projects/accounts.

iii. An original shall be forwarded to each of the projects or programs to which the employee or official will be rendering services and to the Chairperson, Dean or other official of the appropriate department/college/division, to which the employee is ascribed.

iv. The spaces and columns will be completed as follows:

• Employee Name - indicate the name of the employee or official. • Social Security - fill in the social security number of the employee or

official, showing only the last four digits. • Department/Faculty - indicate the department/faculty of the employee. • Position - refers to the title or position that the employee or official holds. • Base Salary - Indicate the individual's Base Salary considered as their IBS. • Indicate if the employee is faculty, professional, non-professional or clerical. • Effective Date of Payroll Distribution - indicate the begin date of the

distribution.

v. In the section Sponsored Accounts, indicate and/or review the following:

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• Fund (Federal, State or Private), Function (Instruction, Research, etc.) & Department (CBE, CSEM, BIOL, etc.): i.e. 02-01-1200

• Account Number and Object Codes- account number (i.e. 29141) code of the applicable object (i.e. Summer Salary- 6170) from where a payment will be received.

• Project Title - title of the project or program on which the employee or official will work and be paid.

• Period of Performance of the Award- Beginning and end dates of the award.

• Level of Effort % - the commitment or estimated effort that is expected to resemble actual effort devoted.

• Amount to be charged to Account - according to the committed level of effort % and the period in which effort will be devoted and based on the institutional base salary. Non-IBS labor charges are not allowed to be charged to federally sponsored accounts.

vi. In the section Cost Sharing or Matching Funds, review the same columns previously defined above for the section Sponsored Accounts.

vii. In the section University Funds, review the following columns: • Fund (Institutional), Function (Instruction, Research, etc.) & Department

(CBE, CSEM, BIOL, etc.): i.e. 01-01-1200. • Account Number and Object Codes- account number (i.e. 12345) code of

the applicable object (i.e. Summer Salary- 6170) from where a payment will be received.

• Type of Activity Funded by B-CU -functional activity, that is, instruction, department research, administration, etc.

• Level of Effort % - the estimated effort that is expected to resemble actual effort devoted.

• Amount to be charged to Account - according to the committed level of effort % and the period in which effort will be devoted and based on the institutional base salary.

Incidental and/or compensation that is not considered base pay, should be included in the section "Payments Paid for other work not included in the Base Salary" with the proper approvals of the department/chair/dean.

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• Provide an explanation in the Comments section of the Form for compensation not considered base salary.

• Total Compensation - total the amount that will be charged to Sponsored and University Funds.

• Comments - indicate comments related to the information that is included in the form.

• Approval Section: In the spaces provided, the following personnel must sign the form: the employee or official that completed the form, the Home Department Approver if applicable, and the Project Director(s) of the home campus of the covered named individual. All signatures must be dated as well.

• Office of Sponsored Programs and Research, Grants Accounting and Human Resources use only– Will verify the information and sign and date the form.

Note: When required, to fill out the budget forms for the SF 424 R&R grantees will need to convert percent-of-effort to person months. Conversion of personnel percent effort commitment to sponsor defined “person months” (i.e. NIH) should be calculated considering the corresponding and applicable Academic Year and Summer Terms. For B-CU, the actual academic year and summer terms are as follows:

• Academic Year (AY) based on a 12-months period (AY12), • Summer Term (ST) based on a 3-months period (SM3).

Therefore, the conversion of percent effort to person months should be estimated as follows:

Person months = [AY or ST] x [fraction of effort]

Example 1:

AY9 x 25% effort = 9 x 0.25 = 2.25-person months In specific, a PI on an AY9 appointment with an IBS of $63,000 will have a monthly salary of $7,000 (one-ninth of the AY). 25% of AY effort would equate to 2.25-person months (9 x 0.25=2.25). The budget figure for that effort would be $15,750 ($7,000 multiplied by 2.25 AY person months). Example 2:

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SM3 x 100% effort = 3 x 1.00 = 3-person months In specific, a PI on an AY9 appointment with an IBS of $63,000 will have a monthly salary of $7,000 (one-ninth of the AY IBS), and a corresponding ST of 3 months (SM3). If the PI commits, charges a full summer term (3/9) or 100% of effort for the SM3, this would equate to 3 SM3 person months (3 x 1.0=3). The budget figure for that effort would be $21,000 ($7,000 multiplied by 3 SM3 person months). Example 3: AY12 x 25% effort = 12 x 0.25 = 3-person months In specific, a PI on an AY12 appointment with an IBS of $72,000 will have a monthly salary of $6,000 (one-ninth of the AY). 25% of AY effort would equate to 3.0-person months (12x0.25=3.0). The budget figure for that effort would be $18,000 ($6,000 multiplied by 3.0 AY person months). Committed cost sharing (mandatory or voluntary) effort must be accurately documented and reported in the personnel’s Effort Report. As per university Cost Sharing/Matching Funds Policy, in institutionally authorized sponsored projects agreements, individuals may commit part of their TPE. Faculty and personnel remunerations received from university matching/cost sharing funds based on a specific percentage of their TPE must be accurate and the corresponding percent effort included in the Effort Report. In addition, cost sharing/matching funds that commit university personnel’s TPE in a specific sponsored project cannot be used to satisfy a cost share commitment on any other sponsored project. Principal Investigators (PI), Project Directors (PD) or person’s having first-hand knowledge of employee effort on sponsored programs must reasonably certify that effort paid from their grant funds was reasonably expended. For determining “reasonableness”, 2CFR Part 220 (OMB Uniform Guidance) states: “In an academic setting, teaching, research, service and administration

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are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate… The payroll distribution system will … (ii) reasonably reflect the activity for which the employee is compensated by the institution…” It must be underscored that individual(s) who certify a falsified report may be subject to criminal charges. Any changes to an effort certification form must be accompanied by a corresponding change to the payroll system to correct the expense. Sponsors must be notified of changes to effort commitments at the time of the initial award, and during the course of the project, consistent with the individual sponsor’s notification requirements. The PI and their department should make corrections within 30 days after receipt of the Effort Report. The Institutional Base Salary (IBS) is used to propose and charge salary to sponsored projects.

• The IBS of the Faculty Personnel dedicated to academic instruction, who also conduct research, creative activity, teaching improvement, training, and/or services, is defined to be the annual remuneration that the University pays to said personnel for the individual’s TPE (100% effort).

According to federal regulations, compensations included as part of the IBS must conform to the criteria delineated. Institutional compensations that require or are based on the commitment of personnel’s time and effort (i.e. administrative, among others) must be included as part of an individual’s IBS, provided they meet the following criteria:

• The remuneration must be paid through the university. • The university must guarantee the remuneration for a period of 1 year or

more. • The remuneration must be documented in the individual’s human

resources personnel action forms. • The remuneration must involve personnel time and effort, and the

remuneration’s corresponding effort must be accounted for on the individual’s effort reports

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IBS excludes one-time payments, incentives or bonuses (not involving time and effort), additional compensations based on work overload or additional summer work (i.e. summer salaries when the academic year is less than 12 months), and any income that an individual is permitted to earn outside of duties for B-CU. In the case where the personnel IBS exceeds an agency’s salary cap, no more than the percent effort committed multiplied by the salary cap may be requested or charged to the sponsor, yet the individual must still devote the full committed effort as proposed and awarded. Sponsor imposed salary caps restrictions require additional consideration for the commitment and certification of effort for in cases where the IBS exceeds the salary cap. Effort report forms for individuals earning in excess of the capped amount must be completed in accordance with this policy and considerations. Sponsors, in particular the National Institutes of Health (NIH) may impose a cap on the reimbursement of salaries. By law, NIH may not reimburse salaries under NIH awards at an annual rate that exceeds the cap (Currently NIH Salary Cap http://grants.nih.gov/grants/policy/salcap_summary.htm). Nevertheless, investigators must still devote the full committed effort as proposed and awarded without regard to the salary reimbursement limitation. It can be foreseen that Salary Cap restrictions may force an automatic situation of Contributed Effort (where Total Effort is split between Contributed Effort and effort allowed to be charged to the sponsor under the salary cap). The salary cap restriction requires consideration for proposal submission (tracking of cost share and committed effort) and Effort Reports. Therefore, as shown in the example below for Professor Y, even though an individual commits 20% effort to an NIH project, the salary cap implies that the University may only charge the agency for 16% of his/hers IBS, and the remaining 4% remains committed in the form of cost sharing. Professor Y’s Effort Report should reflect the total committed effort of 20%.

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Salaries

(IBS and NIH

salary cap)

Percent effort

committed (%)

Funds estimated as per IBS and funds approved

as per NIH's cap

Actual percent of faculty’s IBS that can be

charged and will be supported

by NIH

Percent effort (%) to

be cost shared or contributed effort by

the university

$250,000 (IBS)

20%

$50,000

$199,700

(NIH salary cap)

20%

$39,940

~16%

~4%

The effort personnel expend during the summer period on professional activities (i.e. summer sponsored research) is considered as additional work beyond the individual’s TPE responsibilities during the academic year for which he/she receive their IBS. Specific guidelines for summer salary compensations must be strictly followed, these are: Summer Salary must be consistent with the current academic year’s rate of pay or IBS. That is if a faculty member has an annual IBS of $90,000. The monthly remuneration of such personnel is $90,000/9 = $10,000. Therefore, if a faculty member receives summer salary support for one-month (1/9) the total support or compensation should be $10,000.

• Personnel may not receive more than 3 months of summer salary support from sponsored projects without prior written approval (NSF max. 2).

• Personnel must be prepared to certify that the effort was expended on these projects during the summer in at least the same proportion as the summer salary charged to those projects.

Example of Professor Y- His IBS ($250,000) exceeds NIH’s Annual Salary Cap ($199,700) and commits 20% to an NIH project.

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• Personnel receiving full summer salary (3/9 maximum) from external sponsors during the summer period are ineligible for time off during that period for which they are being compensated.

In addition, payment of full summer salary by a sponsor means that the faculty member cannot engage in other activities, i.e., administrative or academic activities compensated by the University. If a faculty member has formal summer academic or administrative responsibilities, summer compensation and the corresponding effort must be adjusted proportionately. The effort de facto expended during the academic year, on sponsored project/programs that will only remunerate faculty during the summer period, is regarded or classified as uncommitted faculty effort, and hence effort need not be identified and reported if there is no reduction to other teaching or research and/or any other duties. This should be considered in the faculty personnel Effort Report.

• Due to the effort commitment to a sponsored project, if a sponsor has a salary cap, and if the faculty member commits to full effort during a summer month, even though the sponsor will not pay a full salary because of the cap limitation (see example above), the faculty member must still devote their full effort to the project during the month paid.

• Summer period effort reporting is required for all sponsored projects’ personnel with less than 12-month appointments and that also conducts additional professional activities, particularly summer research.

• PI/PDs, departments, and/or corresponding research administrators’ units must submit labor redistributions within 60 days from the date the original transaction, consistent with the university’s cost transfer policy for all expenditure categories.

• University units must adequately document in the personnel’s effort and human resources record each significant change of the PI’s role, responsibilities, or distribution of effort for all PIs that hold dual, salaried appointments with other campuses or institutionally-affiliated units (clinical appointments, appointments with the Veteran’s Administration). Such documentation can be in the form of a Memorandum of Understanding (MOU), or official letters.

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• Administrative and/or disciplinary actions in accordance with University disciplinary procedures may be imposed, due to failure to follow the provisions of this effort reporting policy, to the individuals, research administration units and departments responsible for the violation(s).

• Specifically, if effort reports are not completed and returned in a

timely manner, cost disallowances, such as salary costs associated with uncertified grant activity, may be removed and charged to a faculty, research administration unit, departmental, deans’ account.

• There may be the need to suspend submission of any new proposals on

behalf of a noncompliant PI, or inclusion of a noncompliant researcher in proposals, until effort reports are up to date and properly completed and certified.

• Certification of effort reports that are known to be materially inaccurate

may expose the individual who completed the reports to personal disciplinary action.

Submission/Routing

1. Once signed by the employee or official, an original will be sent to the director or supervisor of the project or program and to the Chairperson and Dean of the appropriate institution or Home Department Approver to which the employee is ascribed; the employee or official should retain a copy. 2. After the form has been signed by the director or supervisor of the project or program and by the corresponding Dean or Director, the Director of the Office of Sponsored Programs and Research’s and the Grants Accountant’s signature is also required. 3. The original will be sent to the Human Resources Office for input to the payroll system with copies sent to the Office of Business Affairs and the Office of Sponsored Programs and Research for filing. 4. “Time and Effort Certification” form (Appendix 4)- At the end of the semester during academic year or summer period, the following procedures will be followed with respect to certifying an individual's reasonable estimate of actual effort expended:

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• Faculty and Professional Personnel will complete and review the form for accuracy and certification. Employees will submit the form every semester and for the summer period according to the certification schedule.

• The original Time and Effort form shall be submitted to the Grants Accountant within the first sixty (60) days as described in the certification schedule.

• Amount Charged to Account -the level of effort % multiplied by the individual's proportional institutional base salary for the corresponding period. Note, incidental and/or compensation not related to effort should not be considered here.

• Total Effort and Base Salary - total the Effort Percentage which must sum 100% and the Amount Charge to each account, which must be proportional to the institutional base salary for the corresponding period.

• Comments - indicate comments related to payroll adjustments that must be made if the Effort % was changed from the pre-populated amount(s).

A cost transfer must be processed to align the effort profile with the labor costs charged.

Certification: The employee's signature is required and/or the Certifier (one who has suitable means of verification that the work was performed and the effort is reasonably accurate for the period) if the employee is not available.

Submission/Routing

• After the form has been signed by the employee or in his/her absence, by the director or supervisor of the project or program (the Certifier), the original will be sent to the Office of Sponsored Programs and Research; the copy will be retained by the director or supervisor of the project or program. • The Grants Accountant will execute applicable labor cost transfers and maintain the signed original Time and Effort form.

Files Management and Archiving The PI/PD will ensure that all files are prepared for storage and/or archiving at the end of the grant cycle. The Office of Sponsored Programs and Research will ensure that appropriate notifications are made as to storage and following of

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protocol for BCU. Records should be able to be readily, reasonably, retrievable upon request by the funding agency for a period of not less than five years.

Reporting Technical or narrative reports required by the funding agency are to be prepared by the PI/PD. All reports are to be reviewed by the Office of Sponsored Programs and Research prior to submission. Once reviewed and approved, the report will then be forwarded to the funding agency. The PI/PD must maintain all appropriate documentation for the narrative. The PI/PD will work with Office of Sponsored Programs and Research and with the Grants Accountant in the submission of all financial reports. PIs/PDs are responsible for obtaining and communicating all due dates for reporting including the final close‐out report to BCU Chair and Office of Sponsored Programs and Research, and BCU Grants Accountant. (Note: All grant drawdowns will be reported to the PI/PD in a timely manner by the Office of Sponsored Programs and Research Grants Accountant.) Post‐Award Checklist

• PI/PD submits award notification letter, budget (signed by President), and fully executed contract to the Office of Sponsored Programs and Research.

• PI/PD reviews the contract in its entirety and remains aware of all elements of the agreement.

• The Office of Sponsored Programs and Research will send a news brief to the BCU Office of Communications for immediate release and dissemination to the academic community.

• PI/PD must schedule a meeting with the Office of Sponsored Programs and Research Grants Specialist and Grants Accountant and obtain training regarding administration and management of the grant.

• PI/PD complies with BCU, state, and federal requirements under the award contract.

• Time and effort tracking for all grant‐funded personnel, if required. (Please contact the Office of Sponsored Programs and Research Grants Accountant for details).

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• PI/PD complies with BCU policies and procedure for payroll, purchasing, and processing invoices and travel documents.

• PI/PD monitors grant activity for financial accuracy and compliance under the contract (using BCU’s reporting formats).

• PI/PD supervises and manages team responsible for the award (Communicate)!

• Ensure the proper forms are completed timely and accurately as required by the contract. These forms include interim reporting to the grantor and the closeout reports.

• PI/PD properly documents and obtains authorization for any changes associated with the grant.

• PI/PD monitors and retains all documentation associated with the award, including budget details and correspondence.

• Before the closeout documents are submitted, PI/PD meets with the Office of Sponsored Programs and Research Grants Specialist and Grants Accountant to review all grant requirements have been met and documentation has been completed (in order to prepare any auditing review requirements).

Change of PI Form

Prior to initiating changes directly with any federal or state agency, grantees wishing to change the Principal Investigator or Project Director must contact the Office of Sponsored Programs and Research. OSPR will submit a formal memo to the President noting this need. The Office of Sponsored Programs and Research will then make the formal change request to the funding agency.

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Grants Management - General Roles and Responsibilities

Office of Sponsored Programs and Research Grants Specialist (Pre and Post Award)

and/or Grants Accountant

Principal Investigator/Project Director (PI/PD)

• Assists with processes and compliance issues related to funding

agency or organization regulations and standards, and monitors adherence to college administrative, fiscal and accounting policies, procedures, and fiscal reporting related to grant proposals and funding.

• Provides advisory services and assistance in the planning and development stages of grant budgets, spending plans, and accounts. Provides advice and technical assistance to grants’ program staff.

• Meets regularly with PI’s to review and reconcile budget(s) and account(s).

• In collaboration the grant program principal investigator, prepares special programs/grant project funding reports, financial reports and summaries.

• Works with PI’s to ensure that cost codes are acquired in a timely manner and monitors grant fund drawdowns occur on a regular basis.

• Assists in the preparation of grant proposals, to include guidance and assistance in budget preparation and interpretation of funding agency or organization regulations and requirements.

• Develops and maintains specialized databases and record management for recording and tracking grant proposals, awards, and related statistical information; creates and distributes standard and special reports, students, summaries and analyses as required.

• Maintains current knowledge of grant funding policies, regulations, and procedures, disseminates and presents information to staff; advises on the implementation of changes and on the impact of changes on funded operations.

• Monitors grant programs accounting, audits, and fiscal reporting. Performs internal control reviews, and assists with the development of internal control plans and internal accountability procedures.

• Proposal development and/or request assistance as needed.

• Complete and submit “Grant Proposal Checklist and Approval Form” which includes obtaining appropriate signatures for prior approval.

• Schedule of report due dates. • Annual and interim reports. This includes

collaborating with Office of Sponsored Programs and Research on reporting.

• Meet with Office of Sponsored Programs and Research Grants Specialist at onset of the project and at scheduled intervals.

• Budget management. • Contract knowledge; assure contract is

followed. • Time and effort tracking and

documentation. • Allocating and spending funds in

compliance with purposes and scope of the project, including, allowable and non-allowable expenses.

• Provide all appropriate documentation as required by BCU and the funding agency.

• Documenting and obtaining authorization for any changes to any aspect of the grant.

• Supervise and manage grant team. • Comply with BCU and funding agency

requirements. • Serve as institutional representative

regarding the funded project. • Monitor accounts for accuracy and

allowability of expenditures. • Understand how funds are expended i.e.

requisition process, approvals, etc. and submit correctly.

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Equipment

(a) Definition- Equipment means tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-Federal entity for financial statement purposes, or $5,000.

(b) The following rules of allowability must apply to equipment and other capital expenditures:

(1) Capital expenditures for general purpose equipment, buildings, and land are unallowable as direct charges, except with the prior written approval of the Federal awarding agency or pass-through entity.

(2) Capital expenditures for special purpose equipment are allowable as direct costs, provided that items with a unit cost of $5,000 or more have the prior written approval of the Federal awarding agency or pass-through entity.

(3) Capital expenditures for improvements to land, buildings, or equipment which materially increase their value or useful life are unallowable as a direct cost except with the prior written approval of the Federal awarding agency, or pass-through entity.

(4) When approved as a direct charge, capital expenditures will be charged in the period in which the expenditure is incurred, or as otherwise determined appropriate and negotiated with the Federal awarding agency.

(5) The unamortized portion of any equipment written off as a result of a change in capitalization levels may be recovered by continuing to claim the otherwise allowable depreciation on the equipment, or by amortizing the amount to be written off over a period of years negotiated with the Federal cognizant agency for indirect cost.

(6) Cost of equipment disposal. If the non-Federal entity is instructed by the Federal awarding agency to otherwise dispose of or transfer the equipment the costs of such disposal or transfer are allowable.

(7) Equipment and other capital expenditures are unallowable as indirect costs. (2 CFR 200.436)

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Cost transfers Definition

A cost transfer is an expense that is transferred from one account to another after the expense was initially recorded in the financial accounting system. Basis for Cost-Transfer Policy Project sponsors expect the grantee institution to establish and maintain adequate financial management practices and policies so that costs are appropriately charged at the time incurred and significant adjustments are not generally required. The federal government has established policies concerning the assignment of costs to federally sponsored agreements, including the general government policies outlined in the Uniform Guidance as well as federal and nonfederal agency-specific policy requirements. Uniform Guidance Requirements To comply with the cost allowability and allocability requirements outlined in the Uniform Guidance (200.400 - Subpart E - Cost Principles), the institution must be able to explain and justify all charges transferred onto federal awards, whether the costs are transferred from some other federal account, a non-federal account, or a University account. Any necessary cost transfers should be completed in a timely manner and with a complete explanation, as these are, per the principles outlined in the Uniform Guidance (200.400 - Subpart E - Cost Principles), critical factors in supporting allowability and allocability. Institutional Cost-Transfer Policy and Guidelines Each department is responsible for ensuring compliance with the following policies and procedures. Any penalties, disallowances, or losses of funding caused by non-compliance with this policy will be assessed against the department in violation of the policy. It is expected that the Principal Investigator (PI) or authorized delegate will review the fiscal status of the PI's sponsored project accounts regularly- a monthly review is recommended -- and promptly correct expense transactions that are incorrectly recorded.

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The University recognizes that transfers of costs from one sponsored project account to another are occasionally necessary to correct bookkeeping or clerical errors in the original charges. The University also recognizes that closely related work may be supported by more than one funding source and that in such cases a transfer of costs from one funding source to another may be proper. However, frequent, delayed, or unexplained cost transfers, particularly when they involve projects with cost overruns or unexpended fund balances, raise serious questions about the propriety of the transfers themselves as well as the overall reliability of the University's accounting system and internal controls. When the need for a cost transfer to a sponsored project account arises, explanation for the cost transfer must be clearly stated and must be sufficient for an independent reviewer (i.e., an auditor) to understand the transfer and conclude that it is appropriate. According to federal regulations, an explanation which merely states that the transfer was made 'to correct an error' or 'to transfer to correct project' is not sufficient. When transferring expenses to a sponsored project account, cost transfers should be accomplished within 90 days of the original entry's effective date. If a particular sponsor's cost-transfers policy is more restrictive than 90 days, the more restrictive policy will apply. No time limit exists for removing expenditures from a sponsored project account. If inappropriate expenditures are discovered on sponsored project accounts, they must be moved to a non-sponsored departmental account without regard to time limits. Cost transfers that are made only for the intention of spending down sponsored project funds or as a matter of convenience are not allowed. Expenses transferred to a sponsored project account are very prone to audit and must be clearly supportable. Transferring costs because of a deficit or other reasons of convenience is not appropriate. Any shared costs should be pro-rated among the applicable accounts at the time the costs are incurred to the maximum extent possible. Charging costs to one sponsored project with the intention of repaying that sponsored project when an award is received is also not appropriate.

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Program Income General

Per Uniform Guidance 2 CFR Part 200.307, Non-Federal entities are encouraged to earn income to defray program costs where appropriate.

• Cost of generating program income- If authorized by Federal regulations or the Federal award, costs incidental to the generation of program income may be deducted from gross income to determine program income, provided these costs have not been charged to the Federal award.

• Governmental revenues- Taxes, special assessments, levies, fines, and other such revenues raised by a non-Federal entity are not program income unless the revenues are specifically identified in the Federal award or Federal awarding agency regulations as program income

• Property- Proceeds from the sale of real property, equipment, or supplies are not program income; such proceeds will be handled in accordance with the requirements of the Property Standards 200.311, 200.313, and 200.314, or as specifically identified in Federal statutes, regulations, or the terms and conditions of the Federal award. Deduction. Ordinarily program income must be deducted from total allowable costs to determine the net allowable costs. Program income must be used for current costs unless the Federal awarding agency authorizes otherwise. Program income that the non-Federal entity did not anticipate at the time of the Federal award must be used to reduce the Federal award and non-Federal entity contributions rather than to increase the funds committed to the project.

• Cost sharing or matching- With prior approval of the Federal awarding agency, program income may be used to meet the cost sharing or matching requirement of the Federal award. The amount of the Federal award remains the same.

• Income after the period of performance- There are no Federal requirements governing the disposition of income earned after the end of the period of performance for the Federal award, unless the Federal awarding agency regulations or the terms and conditions of the Federal award provide otherwise. The Federal awarding agency may negotiate agreements with recipients regarding appropriate uses of income earned after the period of performance as part of the grant closeout process.

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Project Closeout and Property Management and Disposal Reporting Requirements At the conclusion of a sponsored project, the terms of the award generally require written reports, including a final technical or progress report and a report of expenditures, which must be submitted to the sponsor within a specified period of time. These reports are generally viewed as the University's fundamental obligation to the sponsor, and are generally required whether the sponsor is a private organization or a public agency. Federal awards, according to Uniform Guidance, are subject to the following requirements: •Technical- Unless otherwise indicated, final performance reports are due 90-120 calendar days after the expiration or termination of the award, depending on the sponsor guidelines. When required, performance reports shall generally contain, for each award, brief information to address the following requirements. A comparison of actual accomplishments in relation to the goals and objectives established for the period, the findings of the investigator, or both. Whenever appropriate and when the output of programs or projects can be readily quantified, such quantitative data should be related to cost data for computation of unit costs. Reasons established goals were not met, if appropriate. Other pertinent information, including, when appropriate, analysis and explanation of cost overruns or high unit costs. The PI is responsible for preparing and submitting this report. A dated copy of the report or letter of transmittal should be sent to the Division of Sponsored Programs, serving as audit verification that the report was filed. • Financial- Most sponsors generally require a final accounting to document how the funding was spent. Federal awards require a standard Financial Status Report (Form SF425), which is prepared by the Grant Accounting Office, sent to the PI for approval, then submitted to the federal awarding agency. • Inventions- Most federal funding agencies require some sort of reporting to indicate whether inventions have resulted from the sponsored project. Federal agencies require the grantee (University) to submit a Final Invention Report or Statement and Certification, whether an invention has resulted from work under the funded project or not. The Final Invention Report or Statement/Certification

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must list all inventions that were conceived of or first actually reduced to practice during the course of work under the funded project, between the original effective date of support through the date of expiration or termination of the project, whether previously reported or not. If there were no inventions, the statement should simply indicate None. Depending on the sponsor involved the report may be prepared and signed by the principal investigator or by the Office of Sponsored Programs and Research. • Property- federal agencies always require the University to account for any real or personal property acquired with federal funds. A report is prepared using agency-specific forms, identifying the equipment purchased, acquisition cost, make, model number, serial number, inventory number, and condition. If the terms of the award do not automatically give title to the University, a letter is sent to the agency requesting transfer of title to the University.

9. Federal Closeout Procedure- Uniform Guidance requires federally funded projects to complete the following closeout steps:

Recipients shall submit, within 90 calendar days after the date of completion of the award, all financial, performance, and other reports as required by the terms and conditions of the award. The Federal awarding agency may approve extensions when requested by the recipient. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions. The Federal awarding agency shall make prompt payments to a recipient for allowable reimbursable costs under the award being closed out. The recipient shall promptly refund any balances of unobligated cash that the Federal awarding agency has advanced or paid and that is not authorized to be retained by the recipient for use in other projects. When authorized by the terms and conditions of the award, the Federal awarding agency shall make a settlement for any upward or downward adjustments to the Federal share of costs after closeout reports are received.

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The recipient shall account for any real and personal property acquired with Federal funds or received from the Federal Government in accordance Subpart D - Post Federal Award Requirements Insurance Coverage; Real Property; Federally Owned and Exempt Property; Equipment; Supplies and Other Expendable Property; Intangible Property; and Property Trust Relationship. In the event a final audit has not been performed prior to the closeout of an award, the Federal awarding agency shall retain the right to recover an appropriate amount after fully considering the recommendations on disallowed costs resulting from the final audit. • Procedures for Equipment Disposal, Transfer Unless otherwise stated in the award terms and conditions, the title to equipment acquired under a sponsored agreement belongs to the University. The University is obligated to track and account for all equipment acquired with federal funds.

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Appendix

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Appendix 1 Office of Sponsored Programs & Research, 640 Dr. Mary McLeod Bethune Blvd. Daytona Beach, FL 32114 Office: 386-481-2547 BETHUNE-COOKMAN UNIVERSITY Intent to Submit to Proposal Date: _________________ Project Working Title: _______________________________________________

___________________________ Co-PI (s): _______________________________________________

_____________________________________ Please list any other internal or external collaborators: _______________________________________________

__ _____________________________________________________________________________________________ Potential Sponsor: ______________________________________________________________________________ Due Date to Sponsor: ________

Submission Method: ____________ Limited Submission: _________________

Please provide the link to the Request for Proposal here or attach the RFP:

_________________________________

Estimated Total Funding: ______________________ Estimated Project Duration: _________________________

Required Match: ____________ Match Type: ___________________

Match Amount or Percentage:

__________

Does the PI/PD or a Co-PI need release time to complete the project?

_____________________________________

How much release time is required? _______________________________________________________________

Will the grant compensate the University for release time?

_________ Will the project generate income?

______

Does this proposal require a reduction of the Indirect Cost Rate?

_________________________________________

If yes, what is the proposed Indirect Cost Rate? ______________________________________________________

Indirect Cost Rate reduction justification: ___________________________________________________________

_____________________________________________________________________________________________ Does the project involve new course(s) or program(s)?

______ Does the project require additional space?

______

Does the research involve human subjects? _____

animals? _____ biohazards? ____ hazardous chemicals? _____

The signature of the Dean is an acknowledgment of notification that faculty have an intent to submit a proposal. A completed and signed Proposal Submission form is required at least 10 business days prior to submission of the proposal. _____________________________________________________________________________________________ PI/PD Date _____________________________________________________________________________________________ Dean Date _____________________________________________________________________________________________ OSPR Director Date Provost Date For use by Office of Sponsored Research Only Log In/Receipt Date: ______________ Assigned Pre-Award

Coordinator: __________

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Appendix 2

Allowable and Unallowable Costs Direct Costing on Sponsored Projects

I. Purpose To describe the practices used to determine whether or not a cost item may be directly charged to a sponsored project. It refers to guidance provided in 2 CFR200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance, or UG). Specifically, Subpart E – Cost Principles – of the UG (Sections 400 – 475) sets forth general criteria for determining allowable direct costs on Federal awards. It is critical for Grant Management and Principal Investigators (PIs) to review the terms and conditions of individual programs as they may differ based on sponsor or funding type. Based on this review, PIs and GMs should prepare detailed budgets identifying, to the best of their knowledge, the direct costs that will be associated with a sponsored research project. During the life of the project, adequate documentation is required to support all direct costs charged to sponsored funds. II. Definitions Direct Costs: Direct costs are those costs that can be identified specifically with a particular sponsored project, or that can be directly assigned to such activity relatively easily with a high degree of accuracy. Typical direct costs include personnel compensation, fringe benefits, materials, travel, and equipment. Allowability: Direct costs must meet the following criteria to be considered allowable: are necessary and reasonable for the project; conform to limitations/exclusions listed in the Uniform Guidance; are consistent with related policies and procedures, and are consistently treated across projects; are in accordance with generally accepted

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accounting principles (GAAP); are not used to meet a cost sharing requirement on another project; and are adequately documented. Questions regarding allowability should be escalated to your Office of Sponsored Programs liaison. Allocability: A direct cost is allocable to a sponsored project if it is incurred specifically for the sponsored project; or it benefits both the sponsored project and other work of the institution and can be distributed in proportions that can be approximated using reasonable methods. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost should be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefited projects on any reasonable documented basis. However, this allocation cannot be used to eliminate cost overruns. Reasonableness: A direct cost is reasonable if it passes the prudent person test: the nature and amount of the costs do not exceed what a prudent person would have determined when incurring the costs in the same circumstances. Consistency: Direct costs must be treated consistently with respect to institutional policies that apply to sponsored and non-sponsored activity, and to treatment as a direct or an indirect cost when incurred for the same purpose in like circumstances across sponsored and non-sponsored activity. Unallowable Costs: The Uniform Guidance addresses selected costs in Sections 200.420 – 200.475, providing principles to determine allowability. Several specific cost items are identified as unequivocally unallowable on a sponsored project, either as a direct or an indirect cost, including for example alcohol as entertainment, bad debt, personal

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use of automobiles, and losses that could have been covered by insurance. Other cost items can only be charged with the prior written approval from the sponsor, including for example entertainment, buildings and land, and student activities. Individual sponsor and project requirements may identify additional unallowable costs; GMs and PIs must review sponsor policies and award documents for specific guidance. III. Select Direct Cost Items Personnel/Salary/Compensation: Salary Basis: Charges for work performed on federal awards by faculty members during the academic year are allowable at the Institutional Base Salary (IBS) rate. IBS is defined as the annual compensation paid by Bethune-Cookman University for an individual's appointment, whether that individual's time is spent on research, instruction, administration, or other activities. The UG identifies allowable activities as those contributing and directly related to work under an agreement, such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, developing and maintaining protocols (human, animals, etc.), managing substances/chemicals, managing and securing project-specific data, coordinating research subjects, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences. Note: IBS excludes any income that an individual earns outside of duties performed for Bethune-Cookman University, such as providing consulting services. Computing: Computing devices, defined as machines used to acquire, store, analyze, process, and publish data and other information electronically, including accessories for printing, transmitting and receiving, or storing electronic information, may be treated as direct costs up to $5,000, if documentation can support they are essential and allocable, but not necessarily solely dedicated, to the performance of the Federal award. Devices whose primary function is communication (voice and email) are generally unallowable.

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Supplies: Consumable supplies may be treated as direct costs if the project can demonstrate that such supplies are used specifically for the purposes of the project and are consumed completely in the course of achieving the programmatic and scientific aims of the project. If used only for project purposes, items such as laboratory supplies and materials, lab notebooks, diskettes, transparencies, printer paper for research data and reports, report binders, and so forth are justified as consumable supplies. Note: if there is a residual inventory of unused supplies exceeding a total value of $5,000 at the end of the Federal award and the supplies are not needed for any other Federal award, Bethune-Cookman University must compensate the Federal Government for its share. IV. Documentation Adequate documentation for costs directly charged to sponsored projects means that the transaction has been assigned to the correct General Ledger account (G/L account) and includes all required and necessary receipts, forms and approvals to support the relationship to the sponsored project. The G/L account is a seventeen-digit code that classifies the transaction as salaries, fringes, supplies, travel, subrecipient payments, etc. Correctly identifying G/L accounts for individual transactions ensures a proper application of Bethune-Cookman’s F&A rate, activates the proper internal controls for purchases such as capital equipment, and allows for PIs to accurately assess the financial status of a project. If funds are not available on a sponsored project but an item is determined to be necessary to the scientific and programmatic aims of a sponsored project, the item should initially be charged to the Federal award using the appropriate G/L account for that expense type; the award is subsequently credited using the appropriate cost sharing G/L account. V. Review and Audit Research Costing Compliance monitors direct charges to ensure appropriate coding, required internal controls, and adequate justification. Inadequately justified charges are noted, and the department is required to remove these charges from federal codes.

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The Office of Sponsored Programs & Research includes direct charges in the scope of its interim and final compliance reviews. All direct costing concerns must be resolved before the final invoice/report is provided to the external sponsor. VI. Federal Regulations This document reflects the provisions of the UG, which became effective as of December 26, 2014, and all awards issued on or after this date must be managed in accordance with its provisions. It is important to verify the applicable regulations for an individual award, which may be found in the Award Notice issued by the funding agency. These guidelines pertain to federally sponsored projects and should be used as guidance for all sponsors unless specifically addressed in a non-federal sponsor’s policies and/or procedures. Any adjustments of charges will be as required under applicable Federal cost reimbursement principles. If a cost is removed from an award for any reason, whether or not related to this guidance, the cost will generally be charged to departmental funds.

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Appendix 3

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Appendix 4