WHAT CAN SPONSORED
PROGRAMS DO FOR YOU?
John D. Hulvey
Director, Sponsored Programs
Administration and Accounting
October 19, 2015
Review of First Course
“Grant Writing”




Developing a project plan/outline
Finding a funding opportunity
Drafting and polishing a proposal
Considerations of things to do after a submission
Office of Sponsored Programs
MISSION STATEMENT
• To enhance and facilitate the ability of faculty, staff,
and students to develop and achieve their goals in
research, educational programming, and service
delivery through successful competition for external
funding.
This mission will be accomplished while maintaining
responsible stewardship of extramural sponsored
projects as directed by the values of our office and
the applicable federal, state, and agency regulations
and policies.
SPONSORED PROGRAMS
PERFORMS 4 BASIC FUNCTIONS:
 Distribute information concerning potential funding
opportunities
 Review agency guidelines and assist with the overall
proposal submittal process (including budget
development)
 Negotiate sponsor agreements, relationships, and
award terms and conditions
 Interpret and apply the regulatory, contractual, and
administrative requirements.
What is a Sponsored Program?
An award from an external source
(Sponsor) to the University.
 Must provide accountability for its
disbursement
 Is NOT a gift - legal stipulations for use
 Is NOT permanent

Why have an Office of
Sponsored Programs?

Award is “to the Institution” so the
Institution is responsible for compliance
 Verify
sponsor’s requirements are met
 Verify accuracy and allowability of budget
 Ensure contractual requirements are
acceptable
 Obtain final university approval
 Submit final proposal package to sponsor
Improve a submission: Plan

Contact OSP early so we can add value
 Review
sponsor’s terms and conditions
 Alert you of red flags/special considerations
 Develop budgets

Collaborators, on or off-campus
 Substantial
lead time is required to obtain
collaborators’ approved materials
Budget Development
(NOT an afterthought)
“Financial Representation of the Project”
 Consider “needs” for the project in terms
of narrative, not cost (dollars)

 Senior

Who, how much time, when


Personnel Requirements
Example: 1 summer month, 1 course release
Beware of “over commitment”
 Student

Support
Undergraduate, Graduate, PostDoc

Example: $10/hr x 12 summer weeks x 20 hours/wk x 2
Budget Development (continued):
 Equipment Needs (items with cost >$5,000)
 Supply Needs (items with cost <$5,000)
 Contractual: Collaborator/Consultant Needs
 “Collaboration Checklist” on OSP website
 Subawards require budget, budget justification, statement of
work, letter of commitment (at minimum)
 Travel Requirements
 Location, duration, number of travelers
 Facilities and Administration (F&A) (overhead, IDC)
 Required unless disallowed by the sponsor

OSP will translate your budget narrative into an
Excel budget template for review and refinement
“Allowable” and “Reasonable”

The tests of ALLOWABILITY of costs are:

ALLOWABLE – not on the prohibited list in 2 CFR 200; Subpart E
(200.420- 200.475)
Caveat – There MAY be some exceptions to these excluded costs
depending on unique situations. This is why it is important to work with
Sponsored Programs to develop your budget





REASONABLE – the “Prudent Person” test.
ALLOCABLE – able to be assigned to a specific task with high degree of
certainty to a project
CONSISTENT – treated the same in like circumstances
Indirect Costs “Facility and Administration” – A ‘real cost’ to the
institution for accepting the sponsored program, but not one that can be
allocated to the project (lights, heat, cost of hiring, cost of paying vendors)
BEWARE UNALLOWABLE
COSTS
Here are some (some may be an Indirect Costs)
Salaries of administrative and clerical staff (in
most cases)
 Office supplies
 Cell Phones
 Memberships
 Entertainment & alcohol

“Contemplating any business act, an employee should ask himself whether he would be
willing to see it immediately described by an informed and critical reporter on the front
page of his local paper, there to be read by his spouse, children, and friends.”
--- Warren Buffet
What is the Uniformed
Guidance (UG)?
-
-
Federal Regulations that combined 8 Office of
Management and Budget (OMB) Circulars including the
ones most applicable to Higher Ed institutions (A-21- Cost
Principles; A-110 - Administration and Internal Controls;
and A-133 - Audit)
Codified at 2 CFR 200 (Code of Federal Regulations)
What did the UG Change?
Documenting Bidding for items of < $3000
 Defined “Subrecipient” and “Contractor”
 Requires ‘Risk Assessment’ of Subs
 Specifies monitoring requirements over
Subs.
 All Fed Agencies will have FCOI Policies

Financial Conflict of
Interest (FCOI) :
for all “Key Personnel” and
external collaborators (subrecipients)
 MUST submit a Financial Conflicts of
Interest Disclosure Form(s) PRIOR to
application
 If selected for funding, each individual must
then take FCOI training prior to award
release
 Requirement
Other Compliance Considerations:




Human Subject Research requiring Institutional
Review Board (IRB) review (side by side
comparison to funded proposal)
Animal Research requiring Institutional Animal Care
and Use Committee (IACUC) review
Responsible Conduct of Research (RCR) training for
students
Requirements specific to an award
Final Submission:



By University policy, ALL proposals for external
funding much be submitted through the Office of
Sponsored Programs (no matter how large or small)
OSP is already established in most electronic
portals and systems (Grants.gov, FastLane, etc)
Completed proposals should be presented to
OSP 5 working days before the submission
deadline
At Award/Regulatory Compliance:


Individuals cannot sign agreements, only the
university’s delegated authorized representatives
OSP will coordinate the review, negotiation, and
signing of ALL agreements
 Includes
Non-Disclosure, Teaming Agreements, and
Materials Transfer Agreements

Common “Problem” wording includes:
 Indemnity
(Hold Harmless) and Liability Clauses
 Governing Law Clauses
 Arbitration/Mediation
Regulatory Hierarchy:

What rules apply to my award?
Award Terms and Conditions- Sponsor
University Policies
State Regulations
Federal Regulations
NO terms can violate Federal Law
Regulatory Hierarchy:
Award Terms and Conditions- Sponsor

These describe grantees’
requirements:






duration of project
Rebudgeting requirements
Cost type restrictions
invoicing instructions
Reporting & deliverable requirements
Closeout
Regulatory Hierarchy:
University Policies

Sponsors’ T&Cs are compared
against University policy to reveal
any conflicts such as:





Hiring & pay practices
Anti-discrimination policies
Educational mission of University
Insurance Coverage & limits
Vendor payment requirements
Regulatory Hierarchy:
State Regulations

Sponsors’ T&Cs are compared
against state law to reveal any
conflicts such as:
“Fly America”/ “Open Skies”
 “Buy America”
 Indemnification & liability
 Disputes Settlement/Binding Arbitration

Regulatory Hierarchy:
Federal Regulations

Sponsors’ T&Cs are compared
against federal law to reveal any
conflicts.
Remember:
NO terms can violate Federal Law
Types of Awards:
 Grant – most flexible, “to carry out a public purpose of
support” to achieve aim(s), diligence is required, can
adapt scope and budget
 Contract – more restrictive, a procurement with
deliverables and stringent T&C’s, must produce results
 Cooperative
Agreement - sponsor has substantial
involvement in project activities
These distinctions determine the applicability of Federal
Regulations for award administration:


Federal Acquisition Regulation (FAR), (codified in Title 48 of the Code of
Federal Regulations) FAR governs Contracts
UG for Grants and Cooperative Agreements
Other Related topics:

Rebudgeting
 Somewhat
expected (follow the budget!)
 Sponsor defined regulations, contact OSP

Change in Key Personnel
 Always

ask permission through OSP
No Cost Extensions
 May
need to request as much as 60 days prior to the
project end date (almost always 30 days prior)
 Also must be done through OSP
Other Related topics II:

Close-out
 Becoming
very TIGHTLY MONITORED
 WORK MUST STOP at the end of project period
 “Close-out period” is for clean up only



Allocate Payroll costs
Complete vendor payments
Complete final invoicing; financial and technical reports
University generally has 60 or 90 days; PI should only take
30 to 45 of those

Reporting (Timely reporting also closely monitored)
 Technical,
Financial, Inventory/equipment, Patents
Other Related topics III:

Match (“Cost Sharing”)
 STRONGLY
discouraged by the University unless
required by the sponsor.
 It is a contractual obligation to provide
 Must consist of Allowable and Allocable costs.
 Maybe “In Cash” or “In Kind”
 MUST be Monitored, Tracked, and Certified


Best to do this as the project progresses; can be extremely
difficult to obtain documentation at close-out
Failure to contribute or document match will
likely cause a reduction in awarded funds.
SPONSORED PROGRAMS
4 BASIC FUNCTIONS (Review):
 Distribute information concerning potential funding
opportunities
 Review agency guidelines and assist with the overall
proposal submittal process (including budget development)
 Negotiate sponsor agreements, relationships, and award
terms and conditions
 Interpret and apply the regulatory, contractual, and
administrative requirements applicable to sponsored projects
STAYING IN TOUCH WITH
SPONSORED PROGRAMS





Location: JMAC Building 6 (Medical Arts West),
Suite 26, MSC 5728 (1031 Harrison Street)
Phone: (540) 568-6872
FAX: (540) 578-6240
E-mail: jmu_grants@jmu.edu
http://www.jmu.edu/sponsoredprograms/index.shtml
 See “About Sponsored Programs” and scroll
down for a staff listing
Thank you for your attention!
 Questions??