Part I
Research
Administration
Start to Finish
(GC1000)
Part I
Research
Administration
Start to Finish
(GC1000)
Research Administration
Start to Finish Part I
Overview of the Proposal Submission Process
Proposal
Submission
Award Negotiation
and Approval
Award Receipt and
Account Set-Up
Overview (Module 1.00)
In this Module
Introduction
Goals of this Course
University of Colorado Structure
Summary of Office of Grants and Contracts
Introduction
Purpose of Course
• To receive comprehensive, interdisciplinary, mandatory
core orientation and education as described in the CU
Sponsored Research Audit (1999).
• To learn about existing and emerging issues and
regulations regarding the administration of sponsored
projects and programs.
• To receive information on how to work more efficiently
and effectively within the guidelines of sponsored
programs administration.
Maneuvering Through the Course
Links
Numerous links are
available directing you to
useful documents or web
sites. Underlined words in
dark blue generally indicate
that you can link to
additional information.
Modules
After you have completed
each section of a module,
close the browser window
(File Menu, Close) to return
to SkillSoft. You will be given
the option to either continue
viewing remaining sections
of the module or to close the
module and return to the
main menu.
Maneuvering Through
• Supplemental Materials - Throughout this tutorial many terms will
be used. To help you better understand what is being referred to, a
Definition List and a List of Acronyms have been provided for
reference.
• Assessments - At the end of each module, an assessment must be
completed before moving onto the next module. Each assessment
will cover materials in the proceeding module. Broad concepts
covered in earlier modules of the tutorial may need to be applied in
later assessments.
For example:
– UCD administrative units and faculty who have received funding from a sponsor are
responsible for following and complying with certain policies and procedures.
Responsibility for compliance occurs before a sponsored award is made (Pre-Award)
and after a sponsored award is received and accepted by UCD (Post-Award).
– Any penalties, disallowance or losses of funding caused by non-compliance with UCD
policy will be assessed against the faculty and administrative unit in violation of the
policy.
Goals of this Course
1. To provide a framework of knowledge on
sponsored research.
2. To step through the process of applying, receiving,
and administering sponsored funding.
3. To provide information on the roles and
responsibilities of faculty, administrators, the Office
of Grants and Contracts (OGC), and UCD|AMC
when applying for and receiving sponsored
funding.
University of Colorado Structure
• The University of Colorado Denver | Anschutz (UCD|AMC) is one
campus of a three-campus University of Colorado system
governed by the Regents of the University of Colorado.
• A State of Colorado educational institution.
• UCD|AMC works closely with many affiliated hospitals:
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University of Colorado Hospital (UCH)
Children's Hospital Colorado
National Jewish Health
Veterans Affairs Medical Center
Denver Health Medical Center
• These affiliated hospitals are separate legal entities from UCD|AMC
• Often have requirements and approval processes independent of
UCD|AMC.
UCD Mission
• The mission statement of UCD|AMC reflects its main
purpose:
– Education of health professionals.
– Delivery of both health care and community service.
– Advancement of knowledge through research in the
health sciences.
Read more about the Mission, Vision and Values of UCD|AMC.
UCD Support Systems
In support of this mission, UCD|AMC has numerous support systems in place to
support faculty (and staff) with their research endeavors. For research related
activities, the support systems can be broken down into two categories:
Administrative Support Systems
Technical Support Systems
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• Institutional Animal Care & Use
Committee (IACUC)
• Human Subjects - Colorado Multiple
Institutional Review Board
(COMIRB)
• Technology Transfer (TTO)
• Environmental Health and Safety
(EHS)
Grants and Contracts (OGC)
Payroll & Benefits Services (PBS)
Human Resources
Procurement Services Center (PSC)
Risk Management (URM)
Financial Compliance & Accounting
Office of Grants and Contracts
•
OGC is responsible for sponsored funding coming into UCD|AMC. OGC
works with faculty and departments to help foster continued growth of the
research effort at UCD|AMC.
•
The mission of OGC is to provide service to faculty and administrators,
for the purpose of obtaining and administering extramural funds in
compliance with UCD|AMC and sponsor guidelines.
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OGC is the coordinating office for externally funded activities at
UCD|AMC.
•
OGC serves UCD|AMC faculty and staff by supporting:
– The Review and execution of proposals.
– Negotiation and execution of mutually binding agreements.
– Accounting and administration of UCD|AMC's externally funded projects and
programs.
OGC Website
Resources and Information:
• Important updates
• Funding information
• Tools
• Proposal, grant and contract forms
• Contracts, sub-recipient agreements
• Policies and procedures
• Accounting & award administration
Visit the OGC Website: www.ucdenver.edu/ogc
OGC Office Structure
PreAward: Provides assistance in developing and reviewing proposals and negotiating acceptable
grant award terms.
Contracts: Provides assistance in developing and reviewing contract and sub-recipient
agreements and negotiating acceptable award terms.
PostAward: Deals primarily with financial administration of sponsored activity once awarded.
Accounting: Provides standard invoicing, cash management, acting as liaison for audits of
sponsored activity, and maintenance of various systems required by the federal government.
ERA: Configures and Implements the InfoEd eRA Grants Submission System
Summary
This module covered a number of topics that concern
the use of this tutorial and the structure of UCD|AMC.
• We covered the purpose of this tutorial.
• The goals for the course to ensure we are all starting with the
same understanding of UCD|AMC.
• The main support systems for carrying out the research mission
at UCDHSC with special emphasis on G&C's role.
Proposal submission process (Module 2.00)
In this Module
Proposals
Funding Opportunities
Principal Investigator(s)
Grants, Contracts, and Gifts
Before Getting the Award
Proposals
• Understanding that there are processes that must
be followed prior to submitting a proposal to a
sponsor will facilitate proposal writing success.
• A proposal is a grant application request for funding
submitted by a faculty member to an outside
sponsor or contract proposal that may directly lead
to an award.
• A proposal can also be a set of documents
containing a descriptive narrative of an idea and
a budget to be submitted to a sponsor for support.
Proposals
• A sponsor is an external funding agency that enters into an
agreement with UCD|AMC institution to support research,
instruction, public service or other sponsored activities.
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Private Businesses
Corporations
Foundations
Other Universities
• Other not-for-profit
organizations
• Federal, State and local
governments.
• Some sponsors require that proposals are submitted on preprinted
forms while others have no specific format.
• Faculty and administrators should take time early in the process to
develop fully a well thought out proposal. A well thought out proposal
can save considerable time later when there are numerous time
constraints on the completion of work.
Proposals
All formal proposals require an institutional authorized signature
to show the institution's acceptance of the proposal.
• An authorized signature is the signature of an institutional official
who is designated to give assurances, make commitments, and
execute documents on behalf of UCD|AMC as may be required by
sponsors and/or UCD|AMC for the provision of financial assistance
to UCD|AMC.
• The signature of an authorized institutional official certifies that
commitments made on proposals, applications and agreements can
be honored; and ensures that all extramural support conform to
Federal regulations, sponsor guidelines, and applicable institutional
policies.
•
Click here for information on OGC signature authority.
Funding Opportunities
Identification of external funding sources is the first step in the process of
obtaining funding from a sponsor.
Faculty members are urged to contact
– Their Dean's Office
– OGC funding opportunities web page
– The Office of Research and Development (ORDE) for information about
potential sources of funding.
Keep At It!
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Do not give up in the pursuit of external funding if a proposal is not funded.
Many proposals are not funded the first time the proposal is submitted.
Consider resubmitting a proposal after careful evaluation of reviewers’
comments.
Just because one sponsor did not fund the proposal does not mean the
proposal will never be funded.
Be sure to also look to other sponsors for potential funding opportunities.
Principal Investigators
A Principal Investigator (PI) on a proposal is typically a faculty member who
has been qualified and accepted by a sponsor to lead the proposed work.
The PI is responsible for technical compliance, completion of programmatic
work, and fiscal stewardship of sponsor funded projects (see Fiscal Policy 4-13,
Roles and Responsibilities for Grant and Contract Administration).
To Be a PI…
• Faculty must have certain ranks to be eligible as a PI as determined by the
faculty's School. Click here for PI eligibility. Exceptions to school
requirements will require written approval by the applicable Department
Chairman and Dean of the School.
• The sponsor may also limit who can apply for funding.
Roles and Responsibilities
• Throughout this tutorial the responsibilities of the PI, administrative staff,
and OGC will be described.
Grants, Contracts and Gifts
What’s the difference?
Grant applications
• Typically result in a grant award that is directed at satisfying
specific sponsor requirements
• Grant awards tend to be less restrictive, with the primary benefit
of the work going to the awardee.
• The majority of awards made to UCD|AMC are grants.
Grants, Contracts and Gifts
Grants involve one or more of the following characteristics:
• An award that is directed at satisfying specific sponsor requirements. A proposal or
award letter may contain terms specifying the scope of work or line of inquiry, performance
targets, timeframe, level of personnel, etc.
• A line item budget detailing expenditures by activity, function, and time period that must
be adhered to as a condition of funding.
• Deviations from the approved budget may require written sponsor approval.
• The award involves issues requiring institution review including the use of human
subjects or laboratory animals, assignment of patents or copyrights, ownership of data or
equipment, allocation of institution space, or research involving recombinant DNA,
radioactive or biohazard materials.
• A specific period of performance prescribed to the sponsor.
• Provisions for audits by or on behalf of the sponsor.
• The sponsor requires a detailed financial report and/or technical report at intervals
during the period of performance or upon completion of the grant.
Grants come in many forms. Two examples of grants received at UCD|AMC are:
• Federal Grants
• Federally Sponsored Cooperative Agreements
Clarification on Grants, Contracts and Gifts
Contract proposals
• Typically result in a contract award with established deliverables.
• Contract awards are designed to acquire services from UCD|AMC
that many times will primarily benefit the sponsor.
Subrecipient agreement (also termed a subaward or subcontract)
differs from a contract.
• A subrecipient agreement is designed to procure services from
another entity.
• The subrecipient in this case is the legal entity that a subcontract is
made to and which is accountable to the UCD|AMC for the use of
the funds provided. Subrecipient agreements will be covered in
greater detail later in this tutorial.
Clarification on Grants, Contracts and Gifts
For the documentation leading to an award and the award
itself to be considered a contract, it normally must contain
all of the following elements:
• The parties to the agreement must be clearly identified.
• Detailed financial and legal requirements must be included with
a specific Statement of Work (SOW).
• A specific set of deliverables and/or reports to the sponsor are
defined.
• Legally binding contract clauses are included (period of the
contract, termination terms, etc.).
• Authorized signatures by all parties to the contract are required.
Clarification on Grants, Contracts and Gifts
Contracts come in many forms. Examples of
contracts received by UCD|AMC include:
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Federal Contracts
Federally Sponsored Agreements
Interagency Agreements
Clinical Trial Agreements
Clarification on Grants, Contracts and Gifts
Distinctions
Gifts are cash or non-cash items bestowed
voluntarily to the UCD|AMC without any expectation
of a tangible good or service being provided in
return.
• There is no expectation of economic benefit on the
part of the donor.
• Gifts are charitable contributions for use by
UCD|AMC exclusively to fulfill its tax-exempt
purpose(s).
Why Make a Distinction?
The distinction between a grant, a contract and
a gift will often determine who in OGC will
assist faculty and administrators prior to having
a final award and may alter what approvals will
be required by OGC.
Throughout this tutorial, the different requirements will be
outlined to help you better understand what to expect when
working with OGC.
Before Receiving an Award
Awards are the funds provided from a sponsor, in
writing, for support of a sponsored project or
program at UCD|AMC.
This term is used for the original award, and
subsequent supplements or modifications; it can
mean monies or equipment and could also be
referred to as an agreement.
Before Receiving an Award
The PI normally will:
• Be required by the sponsor to develop and submit a
grant application or contract proposal.*
• Be required to review and acknowledge acceptance
of a grant application or contract proposal.
• Be provided with written documentation that a gift is
being given by a donor.
*When the term "proposal" is mentioned, it is referring to both grant
applications and contract proposals.
Before Receiving an Award
• To apply for a grant or contract award, a grant
application or a contract proposal is submitted by a PI
through OGC to an outside sponsor and may directly
lead to an award.
• Contracts that arrive in draft form never having required
a formal proposal to be submitted are still considered a
contract proposal.
• Gifts are to be made in writing and may vary in the
documentation used, from a letter to a formal agreement.
To handle a gift award, contact the CU Foundation the office
responsible for accepting gifts at UCD|AMC.
Overview of the Proposal Submission
Process (Module 3.00)
In this Module
Development of Proposals
Budget Development
Budgets and Federal Sponsors
Compliance
Direct Costs versus F&A Costs
Development of Proposals
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For the purpose of this tutorial, a Grant Application (or Application Package) is a
completed application for funding (scientific presentation, budget, and any necessary
administrative paperwork) plus all necessary internal approval forms
(i.e., Grants & Contracts Routing Form, COMIRB, IACUC, etc.).
Before You Get Started:
– Obtain the funding announcement.
– Review the criteria and restrictions related to applying – particularly
watch eligibility and be aware when limited submission applies (e.g. only
one application per campus or institution).
– Research historical funding activities of the sponsor.
– Analyze and then plan a development timeline
Development of Proposals
Obtaining Grant Application Instructions and Forms at UCD|AMC
• OGC interprets and disseminates the major sponsor policies and forms.
• The major sponsors include:
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Department of Health and Human Services,
National Institutes of Health
Health Resources and Services Administration.
Visit OGC’s website for sponsor forms or resources.
• The PI or the PI’s administrative unit should contact the potential sponsor
for appropriate application instructions and forms.
Grant Application Preparation
• The PI must prepare the grant application (including the preparation of the
budget and technical portions) according to the sponsor’s instructions and
UCD|AMC’s policies and procedures.
Completing the application
(before arrival in OGC)
Before the application arrives in OGC:
• Follow the sponsor directions!
– Simple things like the font size, page limitations, and form completion matter.
UCD|AMC and other institutions have had grant applications rejected by the
National Institutes of Health (NIH) because the font was too small.
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Written content must be readable, understandable and well organized.
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Check grammar and spelling.
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OGC provides pre-submission assistance and review of applications to
ensure that all institutional issues have been addressed and that all
potential financial and administrative sponsor rules and regulations have
been observed. There are a number of checklists that can be used to
ensure that everything is being compiled as necessary for OGC
eventual review and approval. Review the various checklists.
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Training grants can be very complex - Contact OGC for assistance!
Signing the Grant Application
The PI cannot sign grant applications on UCD|AMC's
behalf.
• A PI is not an authorized institutional official of UCD|AMC
and therefore is not authorized to legally bind UCD|AMC to
any legal obligations.
• Authorized Institutional Official(s) are individual(s) authorized
by the Board of Regents of the University of Colorado to sign
grant applications, contract proposals and/or subrecipient
agreements on behalf of UCD|AMC.
• A PI can only bind his or her own self.
Approvals for Proposals
The PI must Obtain all institutional, affiliated hospital,
regulatory and safety approvals for all proposal
arrangements.
• Approvals may need to be obtained from the affiliated hospital
where work (such as patient care) will be performed. These are
separate from the approvals required by UCD|AMC.
i.e. University of Colorado Hospital (UCH) is a separate entity with an
independent approval process for patient care activities.
Contract Proposals
• Contracts are usually issued by the sponsor to the PI
requiring approval by UCD|AMC.
• Occasionally, the sponsor requests UCD|AMC to develop a
contract for a project. Requests to develop a contract should
be directed to the OGC Contract Specialist(s) for input and
assistance.
• All contract proposals are subject to review and negotiation as
necessary to ensure compliance with UCD|AMC, State and
Federal rules and regulations governing sponsored projects.
• Contract proposals often have more restrictive and
problematic terms and conditions, which make it more likely
that it will take more time to negotiate and approve than a
typical grant application. Expect inherent delays.
Contract Proposals
The PI cannot sign contract proposals on UCD|AMC’s behalf.
• The PI is not an authorized institutional official of UCD|AMC and has
no authority to legally bind UCD|AMC to any legal obligations.
• Authorized Institutional Official(s) are individual(s) authorized by the
Board of Regents of the University of Colorado to sign grant
applications, contract proposals and/or subrecipient agreements on
behalf of UCD|AMC.
• A PI can only bind his or her own self.
All institutional, affiliated hospital, regulatory and safety approvals
need to be obtained by the PI for all proposal arrangements.
• These approvals may need to be obtained from the affiliated hospital
where patient care will be performed, separate from approvals
required by UCD|AMC. (i.e. University of Colorado Hospital (UCH) is
a separate entity with an independent approval process for patient
care activities.)
Budget Development
Technically
A grant application or
contract proposal must
be put together by the
PI.
Administratively
A proposal must be put
together by the PI or
administrative unit.
(Drafting the scope of
the work and the
expected outcome of
the project)
(Budget development,
budget justification and
a description of how the
project will be carried
out)
Budget Development
• The budget is the numerical way of representing the
work to be completed in the proposed project, whether
a grant application or a contract proposal.
• A budget is an itemized summary of anticipated
expenditure activity for a given period and activity with
an identified (proposed) means for financing.
• In some cases a budget is the dollar amount awarded by
a sponsor that the institution has a legal claim to collect.
• The budget must be realistic and reasonable. It should
not be higher or lower than what it would reasonably cost
to perform the work.
• UCD|AMC is a non-profit organization, not expecting
profits.
Budget Development
Standards
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No set guidelines that would be applicable to all budgets in all situations.
Generally, budget structures differ among federal, state, local government,
non-profit and private sponsoring agencies. There are also differences in
budget formats on research agreements, clinical trial agreements,
contractual service arrangements and budgets for training.
Budgets are typically broken into categories:
– Include detail by type of expenditure such as personnel, travel, equipment, etc.
– Despite the differences among agreements, the major budget categories will be
similar in grant applications and contract proposals regardless of the type of
sponsor or the type of award mechanism.
– Budget categories are standardized to ensure that financial reporting is
reasonable.
– The greatest amount of variance in budget development will most likely be found
in the amount of information required by the sponsor and UCD|AMC, and what
budget items can be requested for each category of the budget.
Budget Development
Standards
• The best source for information on how much detail to include
in the proposal budget will be the guidelines supplied by
the sponsor.
• The minimum budget requirements of UCD|AMC must also be
followed, even if it means providing a more detailed budget for
OGC's internal use (e.g. NIH modular grant applications).
• The sponsoring agency will determine the specific
requirements of budget development. It is here that a primary
distinction between federally funded and non-federally funded
budgets will be made.
Budgets and Federal Sponsors
• Proposal budgets to federal sponsors must adhere to the
federal cost principles found in Office of Management and
Budget (OMB) Circular A-21.
– This includes proposals being submitted to federal sponsors through
another institution or agency
Read about the Cost Principles
“Cost Principles for Educational Institutions”
OMB Circular A-21
OMB Circular A-21, “Cost Principals for Educational
Institutions”, establishes principals for determining
costs applicable to grants, contracts and other
agreements with educational institutions.
The principals are designed to ensure that the
federal government bears its fair share of total
costs. The significant principles of A-21 include:
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Cost Accounting Standards
Allocable Costs
Direct Costs vs. Facilities and Administrative (F&A) Costs
Allowable and unallowable costs
Cost Principals
The four tests of allowability:
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Reasonableness (including necessity)
Allocability
Consistency
Conformance with the terms and
conditions of the award
Cost Accounting Standards
Allowable Costs
• Budgets should only include the estimated
costs that would be acceptable to be
charged to the sponsored agreement.
• For more information on allowable costs see
UCD|AMC Fiscal Policy, Direct Charges to
Federally Sponsored Projects, 4-7.
Cost Accounting Standards
Reasonableness (including necessity)
• A cost that is necessary to and supports the
specific performance of the sponsored project.
• A cost is reasonable if a prudent person would
purchase a given item for the same purchase
price.
• Failure to adequately document a cost could
result in the disallowance of a legitimate charge.
Cost Accounting Standards
Allocability
• Budgets should include only the estimated costs
that can be assigned to the project, in
reasonable and realistic proportion to the benefit
provided.
• At the time of commitment or expense, it should
be relatively easy to assign the costs with a high
degree of accuracy, in reasonable and realistic
proportion to the benefit provided.
Cost Accounting Standards
Consistency
• When setting up a budget, ensure that budgeted costs will be
charged consistently for the same purpose in like circumstances,
either as direct costs or F&A costs.
• Plan the budget knowing that if there are costs incurred that benefit
more than one sponsored project, the costs can be allocated to each
project or program in proportion to the benefits received, using a
reasonable basis for reflecting the use or level of service.
• Plan the budget knowing that costs may not be shifted to other
sponsored projects due to cost overruns, avoidance of restrictions
imposed by law, or for convenience.
Cost Accounting Standards
Compliance
•
Requirements start with budget preparation and determining what costs are
considered direct costs as opposed to F&A.
•
When preparing proposal budgets, it is the PI’s and department’s
responsibility to ensure compliance with Fiscal Policy 4-7, “Direct Charges
to Federally Sponsored Projects”.
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OGC assists in this process by:
– Ensuring that proposals are managed by consistent treatment of allowable costs.
– Responsible for preparing, publishing, and maintaining a manual of
administrative and costing information necessary for the proper preparation of a
proposal for extramural funding, and as a result may be able to help when PIs
and departments have questions or concerns.
Direct Costs versus F&A Costs
Budgets are to be broken into two broad categories:
• Direct Costs
• Facilities and Administrative (F&A) costs
– Also referred to as “indirect costs” or “overhead”
Direct Costs
Costs that can be identified
specifically with a particular
sponsored project relatively
easily and with a high degree
of accuracy.
Direct Costs include many
budget items.
Examples:
 Personnel costs
• PI, Co-PI, technical staff, and
collaborators relative to the level
of effort expended on the project
 Laboratory supplies
 Long-distance telephone tollcharges
 Animal and animal care costs
 Scientific Equipment
 Travel costs
 Specialized shop costs
F&A Costs
The costs incurred by
UCD|AMC for common or
joint objectives and
therefore cannot be identified
readily and specifically with a
particular sponsored project.
Examples:
 Administrative/Clerical Personnel Costs
 Routine departmental administrative and
accounting costs
 Membership dues/fees for technical and/or
professional organizations
 Office supplies
 Ordinary and routine postage
 Costs associated with preparing
proposals, including typing, copying and
mailing costs
 Telephone hook-up fees and local service
charges
 Computer hook-up fees
 Utilities
 Public Safety
 Building and equipment use and
maintenance
Federal Sponsors
Administrative and Clerical Expenses normally
treated as F&A:
• Office supplies
• Postage
• Local telephone costs
• Memberships
• Salaries of administrative and clerical staff
However, direct charging of these costs may be appropriate where a
major project or activity explicitly budgets for administrative or clerical
services and individuals involved can be specifically identified with the
project or activity.
• .
Federal Sponsors
Caution
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When direct charges for administrative and clerical salaries/supplies are
made, care must be exercised to assure that costs incurred for the same
purpose in like circumstances are consistently treated as direct costs.
•
In general, those costs related to the general operation of an
administrative unit, division, or lab should not be charged as a direct
cost to a federally sponsored project.
•
PI must complete a “Proposal Checklist for Direct Charging of F&A Costs”
form Fiscal Policy 4-7, Exhibit B-2 when a project is anticipated to require
Federal funding as direct costs.
•
Fiscal Policy 4-7, Direct Charges to Federally Sponsored Projects provides
more information and guidance on the treatment of costs as either direct
costs or F&A costs and when it may be appropriate to directly charge
federally sponsored programs for Administrative and Clerical Expenses.
Questions about UCD|AMC direct charging of administrative unit
salaries/supplies should be referred to the OGC PostAward section.
Proposal Submission Process (Module 4.00)
In this Module
Budget Preparation
Contract Budgets
Direct Cost Categories
Facilities & Administrative Costs
Cost Sharing
Budget Preparation
General rules that should be applicable to
any good proposal budget preparation.
Proposals that will result in:
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Federally Sponsored Agreements
Contracts where the Federal Government is the prime sponsor
Cost reimbursement agreements
Agreements requiring detailed budgets
Budget Preparation
Prior to developing the budget for a proposal:
• Review the sponsor guidelines.
• Identify planned purchases by category in the
proposal budget.
• Describe the purchases in the budget
justification as appropriate.
• Included purchases in the final agreement if the
proposal is awarded.
Future Year & Multi-Year Budgets
• For budgets proposed to begin in the future, it is
appropriate to calculate a 3% increase to the current
salary to compensate for cost-of-living increases.
Additional increases of 3% per employment year are also
appropriate for the same reason. Currently, NIH only permits
a 3% factor for inflation.
• Any increase(s) should be detailed in the budget
justification with a statement such as:
“Each category has been increased by ___% per year to
account for anticipated inflationary cost increases.”
Other Types of Budgets
Clinical Trial Agreements
• Another type of proposal budgeting arises with
proposals where no specified budget is required and/or
no financial reporting of expenditure activities are
mandated by the sponsor.
• These types of proposals are normally non-federally
sponsored. (Agreements funded by private sponsors
and Fixed-Price Agreements)
Note: The Budget Development Standards section previously
covered in this tutorial is also applicable to the budgeting practices
for contract proposals that are non-federally sponsored.
Contract Budgets
Remember to consider the following:
• There are no set guidelines that would be applicable to all budgets
in all situations. Generally, budget structures differ among federal,
state, local government, non-profit, and private sponsoring
agencies.
• There are also differences in budget formats on research
agreements, clinical trial agreements, contractual service
arrangements, and budgets for training.
• Despite the differences, the major budget categories to work
toward will be the same when considering proposals regardless of
the type of sponsor or the type of award mechanism.
(continued)
Contract Budgets
Remember to Consider the following (continued):
• The greatest amount of variance in budget development will most
likely be found in the amount of information required by the sponsor
and UCD|AMC for each category of the budget.
• The best source for information on how much detail to include in the
proposal budget will be the guidelines supplied by the sponsor. The
minimum budget requirements of UCD|AMC must also be followed,
even if it means providing a more detailed budget for OGC's internal
use (e.g. NIH modular grant applications).
The same direct cost budget categories covered in the Proposal
Budgeting section earlier (section 3.07) should be used when
developing a budget for proposals that are normally non-federally
sponsored and typically result in contracts such as Clinical Trial
Agreements, agreements funded by private sponsors and Fixed-Price
Agreements.
Contract Budgets
Additional considerations to think about:
• Funding Level - Review budgets offered by sponsors to ensure that
the funding level is appropriate for the work that will be performed.
All activities and resources used or purchased in order to perform a
protocol or statement of work should be covered by the funding
provided in the agreement.
• Patient Care - Agreements where patient care is conducted at one or
more UCD|AMC affiliated hospitals must include the appropriate rate
per activity charged at the given affiliated hospital (e.g. University of
Colorado Hospital reviews and approve clinical budgets via the
Hospital Research Review Committee (HRRC).
Check with the hospital conducting any patient care to obtain correct
budget information related to planned activities.
Clinical Trial Budgets
Clinical Trials are expected to be funded on a cash-basis, which means
the project is expected to be in a positive cash position throughout the term of
the award. See Fiscal Policy 4-1, Clinical Trials.
• Pay close attention to the payment schedule in a clinical trial. Make sure that
payment will be received in a timely manner to allow the project to maintain a
positive cash balance and function smoothly.
• Billing Requirements - Generally, on clinical trials the PI is responsible for
getting required information to sponsors in order to receive payment.
• Incentive payments to individuals from sponsors are not allowed in
accordance with UCD|AMC policy.
F&A will be assessed on all contracts. Consult OGC Webpages for the
appropriate F&A rate.
Most sponsored clinical trials are assessed by the off-campus F&A cost rate
(26%) because a majority of the activity is generally conducted off-campus,
(i.e., at one of the hospitals affiliated with the UCD|AMC).
See Fiscal Policy 4-1, Clinical Trials for more information.
Payments
All payments are to be made payable to the University
of Colorado Denver and sent to the OGC Lock Box.
• The lock box address is:
University of Colorado Denver
Department 238 # [proposal number – PI's initials]
Denver CO 80291-0238
Note: Additional information will be provided on alternative
types of proposal budgeting later in this tutorial.
Direct Cost Categories
Primary direct cost budget
categories.
• Begin preparing the budget
using standard budget
categories (unless instructed
otherwise).



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



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Personnel
Consultants
Equipment
Supplies
Travel
Patient Care
Alterations and Renovations
Other Expenses
Subrecipients
(Consortium/Contractual)
Personnel Category
Includes both salary and the applicable fringe
benefit budgeting rates.
Personnel include faculty, staff and students employed by UCD|AMC,
such as the PI, research personnel, and technical personnel.
• Each person identified as "personnel" in the budget must be a
UCD|AMC employee paid through UCD|AMC payroll.
• Non-UCD|AMC paid employees must be identified in the budget as
subrecipients or consultants.
Consultant Costs
Individuals who will add
expertise and skill to the
project.
Consultants are commonly
listed in the budget as being
paid on a daily rate plus
travel costs. Some sponsors
limit the daily rate that may be
paid to a consultant.
Equipment Category
An article of non-expendable, tangible equipment:
• Useful life of more than one year
• An acquisition cost of $5,000 or more.
This includes equipment
• Purchased or acquired via transfer
• Donation
• Equipment being constructed where component
parts may be less than $5,000 each, but the total
cost will be $5,000 or more.
Supplies Category
Otherwise known as consumables
• Supplies for sponsored projects
are to be purchased out of the
direct costs for the project.
• Supplies related to the general
operation of the administrative unit
are to be covered as a part of
Facility and Administrative Cost
Recovery Revenue.
(e.g., paper, pens, printer cartridges,
excluding supply items stored and used in
a laboratory setting)
Travel Direct Cost Category
Travel includes only travel
activities by UCD|AMC
personnel necessary to
conduct and benefit a
project.
Patient Care Costs
Costs of routine and
secondary services carried
out with persons who are
participating in a research
project.
Alterations and Renovations
Most agencies specifically define allowable costs for space
alterations and renovations.
• In some cases, it may be necessary to determine whether or not
space will be available at UCD|AMC to accommodate the
requested change.
• Contact Institutional Planning for assistance developing
appropriate budget amounts
Other Expenses Category
Items not included in any other category should be
listed as other expenses. Check the sponsoring
agency's guidelines for any specific items to include
here. Listing by major categories is allowable.
Common expenses in this section include, but are
not limited to:
• Equipment maintenance
• Equipment rental
• Subject reimbursement
• Trainee costs
Subrecipients Category
Subrecipient The legal entity that has
agreed to work in collaboration with
UCD|AMC if the proposal is awarded.
 Also known as Consortium or Contractual
costs.
 Work to be performed will usually be
developed into a formal subrecipient
agreement for substantive portion of
work performed.
 Third party entity – NOT an individual
 Agreement developed upon receipt of an
approved award.
 Accountable to the UCD|AMC for the use
of the funds provided.
Facilities and Administrative (F&A) Costs
For sponsored project costing purposes, costs that are incurred for common
or joint objectives (research, instruction, public service, or patient care) of the
institution and, therefore, cannot be identified readily and specifically with a
particular sponsored project, an instructional activity, or any other UCD|AMC
activity, such as clerical and administrative personnel.
•
Also referred to as indirect costs, overhead costs, or administrative costs.
•
Most sponsoring agencies allow reimbursement of F&A costs as a
percentage of certain direct costs of the project (this is known as the MTDC
the Modified Total Direct Costs).
•
UCD|AMC has established a federally negotiated F&A cost rate agreement
which sets out the percentage rates to be applied to all proposal budgets
unless another mandatory sponsor policy applies.
F&A Cost Rate Determination
The cost rate for a project is determined by:
• The location of the project
– On or off campus location
• The type of activity being proposed.
F&A Cost Rate Determination
Some sponsoring agencies specify the F&A percentage rate to be
used. If the percentage rate is not specified by an agency, follow
UCD|AMC policy.
– All federally-funded projects are subject to the UCD|AMC's Negotiated
Rate Agreement unless otherwise specified by the federal sponsor.
– For non-profit, charitable associations, foundations and societies that do
not have an established policy, the UCD|AMC project must initially be
proposed at an F&A cost rate of no less than 10% of the Total Direct
Cost (TDC).
All other F&A cost rates are to be applied to a Modified Total Direct
Cost (MTDC) base unless indicated otherwise.
For more information on how to determine what F&A rate to use and
how to calculate F&A see the F&A Costs Guide.
Cost Sharing
The portion of a sponsored project or program that is
not supported financially by the sponsor.
• When the PI, department, and UCD|AMC agree to
provide any type of cost share to a sponsor, UCD|AMC
is then committed to provide those stated services or
assets in the performance of the program or project if
awarded.
• Any commitments made in the budget, budget
justification, proposal narrative and award documents
are all binding on the institution at the time of the
award and thus require approval and institutional
endorsement.
Cost Sharing
• Usually provided through the contributed effort of PI’s or their staff
and paid from the unrestricted fund, auxiliary and self-funded
activity fund and/or gift programs.
• The effectiveness and expected benefits of each cost sharing
agreement should be weighed considering the administrative and
financial requirements and responsibilities inherent for the PI, the
administrative unit, and UCD|AMC.
• Cost sharing is not normally appropriate on programs or projects
supported by “for-profit” entities.
Types of Cost Share
Three types of cost sharing:
• Mandatory
Required as a condition of the award.
• Obligatory
A “committed” cost share is offered in the proposal by UCD|AMC,
but is not a requirement to obtain the award once offered cost
share becomes a requirement of the award.
• Voluntary
Provided in excess of mandatory or obligatory cost sharing
requirements.
Payment of Cost Share
Cost sharing between sponsored projects is not
normally allowable.
For example: federal funds cannot be used for cost share on another project.
Covering Cost Share Obligations
• Cost sharing may be funded by unrestricted general fund
programs, auxiliary and self-funded activity fund programs, or gift
fund programs.
• Cost share can only identify or commit funds one time.
i.e. Dollars committed to cost sharing on one project cannot be committed again
on another project.
• Budgets that commit quantifiable cost sharing outside of the PI’s
administrative unit personnel must include authorization from the
appropriate department chair/designee and dean/designee. If third
party cost sharing is proposed, an authorized official of the
organization must approve the commitment in writing.
• It is the responsibility of the PI and the originating department to
ensure that all cost sharing is identified and documented appropriately
in the proposal.
• OGC reports cost share obligations to the sponsor if an award is
made to UCD|AMC, as required.
Examples of Cost Share
• Faculty, staff or students salaries and related fringe
benefits for those working on the project
• Laboratory supplies used on the project
• Travel benefiting the project
Unallowable Cost Share
Examples of Unallowable Cost Share:
– Expenditures which are normally charged as F&A, such as
administrative salaries or office supplies
– Unallowable direct costs such as alcoholic beverages,
entertainment, or any costs disallowed by the sponsor
– Equipment unless required by the sponsor
– Service Center expenses
The same cost principles for direct costs covered earlier in the tutorial
apply to the charging of cost share. The expenditure must be
appropriate as a direct expense. Requirements for cost sharing are
found in OMB Circular A-110, including the allowable methods for
documenting such cost sharing.
F&A Used as Cost Sharing
• With the appropriate approvals, waivers or reductions
of the facilities and administrative (indirect) cost rate
may be used as cost sharing.
• These waivers or reductions must have prior approval
of the awarding agency and must be formally requested
and processed through the UCD|AMC waiver approval
process if the rate is different than the normal rate.
See the following for additional information:
–
Fiscal Policy 4-4, Facilities & Administrative Costs and
Distribution of Recovery
–
Fiscal Policy 4-8, Cost Sharing
Budget Preparation - Conclusion
• While racing to get the proposal ready on time, remember
that good planning and good budgets save time later.
• There are no set rules that apply to all of the numerous
sponsoring agencies, but the general guidelines presented
above apply to any good budget preparation.
• The best method to ensure a properly-prepared budget is to
consult the sponsoring agency's guidelines prior to
beginning your budget preparation!
Proposal Submission Process (Module 5.00)
In this Module
Regulatory and Safety Issues
Proposal Review and Approval
What is Routing
Document Transfer to OGC
The Purpose of Routing
OGC Review and Approval
Routing Benefits the PI
Regulatory & Safety Issues
While preparing a proposal for submission to OGC, the
following regulatory and safety issues need to be
considered and addressed as required.
• Facilities Usage at UCD|AMC
• Completion of Conflict of Interest (COI) disclosure
through the Office of Regulatory Compliance
• Animal Subjects
• Human Subjects
• Radiation and Safety
• Biosafety
Facilities Usage at UCD
Is adequate space available to perform the proposed project?
• If no facilities are available for the project or program, the Planning
Office must be consulted for additional space or new space. For more
information see the Office of Institutional Planning.
• If facilities are available for the project, be prepared to identify the
primary location as “on” or “off” campus (see Fiscal Policy 4-4).
Familiarity with all fiscal policies is critical to ensure compliance.
List of University of Colorado Denver | Anschutz Policies and Guidelines
• Fiscal Policy 2-4, Use of Facilities and Equipment by Outside Parties
or for Private Gain, Fiscal Policy 3-11
• Use of Campus Facilities, Space and Services by External Entities,
and/or Fiscal Policy 3-12
• Real Estate Management-Space Acquisition and Use may become
applicable in certain circumstances.
Disclosure of Financial Interests
UCD is committed to:
 Maintaining the integrity and truthfulness of its research and scholarship through the
responsible and ethical conduct of its faculty, staff and students
 And has instituted policies and procedures for the disclosure of potential conflicts of
interest and for handling any perceived conflicts that are disclosed.
A financial conflict of interest is not inherently wrong as long as it is disclosed to
the institution and is managed, reduced, or eliminated.
The CU Administrative Policy Statement, Conflict of Interest Policy refers to situations in
which outside relationships or activities conflict (such as professional consulting for a fee)
or have the appearance of conflicting, with an employee's commitment to his/her
University duties or responsibilities.
Acceptable when:
• They comply with University policy
• Promote professional development of faculty and student employees, and enrich the
individual's contributions to the institution, to their profession and to the community
For Example, Consulting relationships may serve to create conduits for the exchange of
information and technologies that enhance the University environment and permit faculty to
test the soundness of their ideas. Separate policies may apply to faculty; for example, in the
School of Medicine, faculty are subject to separate guidelines and required to direct all
outside professional activities through University Physicians, Incorporated (UPI).”
Disclosure of Financial Interests
Any UCD|AMC faculty or staff engaging in employment
or financial activities outside of UCD|AMC should be
familiar with current UCD|AMC policy regarding conflict of
interest and the appropriate disclosure rules.
*Contact the Office of Regulatory Compliance for additional
information.)
OGC requires disclosure of financial interests for each
new proposal received. Faculty are to keep their chair and
dean or supervisors fully apprised of situations that are or
could be potentially perceived as being a conflict of interest.
Animal Subjects
If animals will be used for the project, the PI is responsible for
contacting the Animal Care and Use Committee (IACUC) office for
the necessary forms and approval procedures.
• During the proposal review “routing” process, OGC will ensure:
 Date of committee approval and protocol number is completed on the
routing form in order to approve the proposal.
 Approval to use animals is obtained prior to submission of all nongovernmental proposals.*
* Some federal sponsors like the Public Health Service (PHS) may accept approvals after
the grant application submission. Be sure to review sponsor guidelines as needed for more
information on what is or is not required.
You may also contact OGC should you need assistance.
Human Subjects
If human subjects are proposed in a research project, UC Denver must
review and approve the research protocol before human subject
research can be conducted. This includes continuing review and approval.
•
The PI must obtain approval for human subjects research protocols and is
responsible to work with the Institutional Review Board (IRB)
–
–
Colorado Multiple Institution Review Board (COMIRB)
Western Institutional Review Board (WIRB)
•
IRB approval must be obtained before a sponsored project involving
human subjects can be established in the UCD|AMC financial system. Lack
of an approved protocol will delay award setup.
•
Many sponsors accept proposals with a “pending” human subject protection
protocol. Federal agencies often utilize a “Just-in-Time” procedure which
postpones the requirement to submit an approved protocol until after the
peer review process and just prior to the funding.
Radiation and Safety
If using radioactive materials
 Approval is required from the
Committee on Ionizing Radiation
(CIR).
 The PI is responsible for
contacting this office to complete
the necessary forms and
procedures.
Biosafety
If the project involves the use of biohazards
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
Infectious agents
Infectious genetic material
Human gene therapy
Recombinant DNA or RNA
Select Agents
PI must complete the appropriate documentation &
submit it to the Biosafety Officer, Health and Safety
Division.
Subject to institutional review and approval by:
 Environmental Health and Safety Committee
 Infectious Agents Committee and/or
 Institutional Biosafety Committee.
Proposal Review and Approval
OGC is responsible for all research, instructional, or public
service activities that are related to the mission of the
UCD|AMC and sponsored by external agencies or entities.
All extramural requests for program funding and
sponsorship, including grant applications and contract
proposals must obtain institutional authorization prior to
being submitted to the sponsor.
• Route all documentation to OGC per campus guidelines
Gifts, bequests, and donations should be submitted to the CU
Foundation rather than OGC.
Proposal Routing – What to Route
Involves the process of completing and submitting
proposal applications for internal approvals:
• Approval of Application for Grant or Contract (Routing Form)
• Contract proposal (or any other form of request for
extramural funding)
• The required signatures for processing the routing forms:
 Principal Investigator
 Department Chair, Dean or Administrator
 Office of Grants and Contracts Official
Other signatures obtained only when applicable include Technology
Transfer, Resident Counsel (legal review), the Vice Chancellor, and/or the
Chancellor.
Proposal Routing – What to Route
The PI is responsible to obtain all appropriate or special signature
approvals in the routing process.
•
•
•
•
•
Facilities
Human subjects
Lab animals
Hazardous materials
Bio-safety agents
At time of submission to OGC, the proposal should be complete
administratively and scientifically for the final review and signature
unless arrangements have been made for OGC to complete a preview.
The PI may be required to sign other documents either by OGC or the
sponsor.
Any required approval by UCD|AMC or the institutional official are to
be signed by the OGC's authorized official for UCD|AMC.
Proposal Routing – What to Route
• Any document or documentation that
is submitted to a sponsor or that is
considered an attachment to a
proposal.
• All such documents should be
included in the package of
information routed to OGC.
• Route a copy of any special project
guidelines to assist OGC in the
review process.
Proposal Routing - Grant Review
Grant applications should be routed with sufficient lead-time. Consider
what needs to be achieved and the steps in the process to reach that goal.
• To complete the routing, allocate time to:
 Secure the department and Dean signatures
 Obtain OGC’s review and comment on the application
This includes allowing OGC time to identify any problems and for the PI or
designee to submit any corrections that need to be made to the routing or
application in order to obtain institutional endorsement.
 Obtain Institutional Endorsement
• A good rule of thumb for minimum lead-time on grant applications is to
have the application submitted to the Dean’s office 5-7 working days
prior to the sponsor’s application submission deadline.
Proposal Routing - Contract Review
Contract proposals typically take more time to review and approve
compared to grant applications.
• Often require the negotiation of contract language.
• A Contract Specialist will work with the PI or designee to negotiate the
terms and conditions of the contract with the sponsor as appropriate.
Contract proposals should be submitted with INCREASED lead time
 Follow the lead time recommendations for Grant Proposals
 Add an additional 2-3 days if your proposal include the need for contract
review
Expect the minimum lead-time on Contract applications to be 8-10 working
days prior to the sponsor’s application submission deadline.
Document Transfer to OGC
Begin the routing process as early as possible.
When to Route
Route new proposals and
continuing proposals that
deal with new monies:
When Not to Route
Actions that need OGC approval
but do not require routing:
 Funds that have not
already been awarded to
UCD|AMC
 Any new or additional
award monies require the
completion of an Approval
of Application for Grant or
Contract (Routing Form).
 Award notices for proposals that
have already been routed
 Executed agreements that have
already been routed
 Requests or authorizations for
additional time
 Requests for carry forward of
monies already awarded
What is the Purpose of Routing?
Routing provides internal approval to OGC of:
•
•
•
•
Institutional
Regulatory
Safety information
Written documentation of approval
PI’s should review the certifications contained in the routing materials
before signing the routing form and any other institutional or proposal
documentation.
What is the Purpose of Routing?
PI provides UCD|AMC with the assurance and certification:
• The routing and corresponding proposal is accurate and complete.
• If awarded, PI is aware that he/she is responsible for compliance with
award terms and conditions and University policies and procedures.
– Particularly for the technical conduct of the work, submission of technical
reports, regulatory compliance and financial management.
• Arrangements have been made for funding any cost sharing
requirements.
(continued)
What is the Purpose of Routing?
• Disclosures have been made of any items requiring special
consideration by the Dean, Chancellor’s Office, Planning Office or
Resident Architect.
• If a Research Program or Career Development Award, Disclosure of
Financial Interests to Sponsored Research has been completed.
• If there is a joint appointment with the Veterans Administration, a
Memorandum of Understanding has been executed between UCD|AMC
& VA
– Full disclosure has been made to the NIH or other sponsors as required;
and the PI’s time and effort will not be double billed for the same effort.
If Clinical Trial research, PI also certifies:
• Faculty and staff should have a proportionate amount of
their compensation charged to the clinical trial directly or
billed to the clinical trial through UPI for related faculty
services.
• Clinical trial data collection and analysis expenditures are
billed appropriately to the clinical trial and not to medical
insurance carriers.
• Patient care billed to a third party commercial or
governmental insurance plan is in accordance with the third
party commercial or governmental insurance plan
requirements.
(continued)
If Clinical Trial research, PI also certifies:
•
Associated income must be deposited into the UCD|AMC financial
system through OGC and/or the OGC lock box mechanism.
•
PI understands that a residual balance of equal to or greater than
$25,000 at the conclusion of the clinical trial is to be reported
through the “Disclosure of Financial Interests Related to Sponsored
Research” form (Fiscal Policy 4-9)
– Reported through annual reporting of conflict of interest to the
chair/unit director
– Reported as required under COMIRB policy.
•
It is the PI’s responsibility to apply the accounting practices
(allowability, allocability, and reasonableness) for costs associated
with the agreement.
Costs that are allocable to a particular agreement may not be shifted to
other sponsored agreements, to other government or commercial health
insurance payers or to the patient.
OGC Review and Approval
OGC reviews proposals for the following:
 Does the proposal have the appropriate internal
approvals?
 Does it meet all sponsor guidelines?
 Is the budget appropriate?
For example, does the budget calculate correctly?
 Is the proposal in compliance with University policies
and procedures?
– PI eligibility
– Terms and condition
Routing Benefits the PI
Routing benefits the PI because it:
 Helps the PI present the best proposal to the sponsor.
 Reduces surprises. The division/department, school and
University are all on board with proposal commitments.
 May reduce negotiations between OGC and sponsor.
 May reduce time or administrative efforts handling
Post-Award issues after the award is received
Sponsor approvals, cost transfers, etc.
 Improves relations with sponsors and may improve
future funding opportunities.
Award Negotiation, Award Approval and Set-Up
(Module 6.00)
In this module
Awards
Records
Why is the Award So Important?
Award Set-Up
Academic Freedom
Gift Awards
Approvals
Pre-Awards
How Awards are Made
Billing and Payment
Award Acceptance
Residual Balances
Award Monitoring
Payments
112
The Proposal Award
Awards: Provides funds from a sponsor for support of a sponsored project.
• This term is used for the original award, and subsequent supplements or
modifications.
(Could also be referred to as an agreement.)
• The award sets out the obligations of the parties.
– A written, legally enforceable document between an institution and sponsor.
– Involves the expectation of an economic benefit and the generation of:
•
•
•
•
Tangible product
Report
Service
Other consideration to the sponsor
– The benefits to the sponsor might include:
•
•
•
•
Receipt of technical reports
Evaluation, testing or evaluation of proprietary products,
Development or construction of equipment
Access to data, patents, copyrights, or consulting services.
Agreements can take many forms including grants, cooperative agreements,
contracts, sponsored research agreements, or any other agreement that is used
to fund a sponsored project.
Awards from…
Grant Applications
Contract Proposals
Once the proposal has
been sent to the sponsor
Many times once the draft
contract is received by OGC
 A waiting process
before the PI or the
institution is informed
by the sponsor that an
award will or will not
be granted.
 There may be a delay
finalizing the contract
while terms and
conditions are
negotiated.
Why is the Award so Important?
The award document defines how the project can be carried out.
Awards may:
• Set limitations on the amount of freedom the PI and staff have
to carry out the work.
• Establish the number and complexity of financial and technical
reports to be completed.
• Limit how funds can be spent and restrict re-budgeting without
prior approvals.
The potential that the award document may restrict the PI and/or
the institution, requires that the award be read, understood, and
if necessary negotiated before it is accepted by the institution.
Why is the Award so Important?
The terms and conditions of the award are typically included in the
award document and/or may point the reader to the source of such terms
and conditions.
For example, on federally funded awards there are standard regulations
that apply and/or typically referenced rather than given in full text.
• Office of Management and Budget (OMB) Circulars A-21 and A-133 are
applicable to all federal awards, including both grants and contracts.
• OMB Circular A-110 is applicable only to federal assistance awards.
(grants; cooperative agreements)
• Federal Acquisition Regulations (FAR) are applicable to federal contracts.
 Federal awards are governed by standardized rules and regulations
(OMB Circulars and FARs), although each may also have unique terms.
 Non-federal awards do not have standardized rules and regulations, but
usually have sponsor specific terms and conditions.
Why is the Award so Important?
Some awards require negotiation of terms and conditions
before the award is acceptable.
These terms and conditions may include:
 The designation of
confidential information
 Publication rights
 Intellectual property
ownership
 Indemnification
(liability and risk)
 Terms and termination of
the agreement
 Choice of law
 Confidential information
 Use of the University’s name
 Compensation and payment
 Expenditure of funds
 Ownership of equipment
acquired under the agreement
Why is the Award so Important?
For the award to be acceptable, it must:
 Be in compliance with UCD|AMC, State of
Colorado, and Federal policies and procedures.
Terms and conditions must:
 Be reasonable under the circumstances and
acceptable to the PI.
For example, publishing rights are governed at the University by the
concept of academic freedom and the Classified Research Policy.
Administrative Policy Statement on Restricted, Proprietary
and Classified Research
The University functions on the premise of academic freedom
and the University continually works to achieve an atmosphere of
free inquiry and discussion.
Academic Freedom
A fundamental concept and defined as
 The freedom to inquire, discover, publish and teach truth as the faculty member
sees it.
 Subject to no control or authority and save the control and authority of the
rational methods by which truth is established.
Academic freedom becomes an important issue when paired with sponsored
research since:
 Sponsors of extramurally funded research often want to impose some
restrictions on the PI and those working on the project.
One of the reasons UCD|AMC reviews awards prior to acceptance is to
 Ensure that academic freedom is protected.
 This includes the requirement that faculty have complete freedom to study,
learn, do research, and communicate the results of these pursuits to others.
 Academic freedom includes students who must be able to freely study and
discuss issues.
Academic Freedom
This freedom will be restricted if the award
offered by the sponsor:
• Limits the ability to publish
• Too broadly defines confidential information
• Too broadly defines a sponsor’s ownership
rights to intellectual property, including data
and copyrights
Academic Freedom
The University of Colorado has an established policy on the
acceptance of classified research.
• Classified research is either:
– Federally funded research with a designated security
classification, or
– Industrially funded research in which the sponsor requires a
delay in publication in the open literature in excess of six
months from the date of submission of the final project report by
the PI to the sponsor.
The policy excludes “routine testing services” and personal consulting by
faculty members.
• If the award document is in conflict with the policy on
academic freedom or classified research:
– OGC will pursue negotiation with the sponsor to reach agreement on
acceptable language.
Approvals
Prior to UCD|AMC’s acceptance of an award, the PI may be
responsible for obtaining any required approvals not already
obtained in the routing process:
Approvals might include:
•
•
•
•
Human subjects
Lab animals
Hazardous materials
Bio-safety agents
The PI is also responsible for
 Answering project-specific questions of the sponsor
 Working with OGC to resolve any award issues that may need to
be negotiated with the sponsor.
OGC acts as primary institutional contact point for all Federal and
non-federal sponsoring agencies.
How Are Awards Made?
OGC considers an award to be made when the award document is received
by OGC and properly executed.
Awards from Grant Applications
Awards from Contract Proposals
 The PI and/or OGC normally
receive written notification of the
sponsor's decision regarding
award of a grant application or the
denial of funding.
 Awards made by contractual
agreements are usually more
complicated than awards made
with grants. Contracts take longer
to review, negotiate and approve
than grant awards; be prepared
for the inherent delays.
 Awards received must be
reviewed by OGC, the PI, and/or
designee to determine the terms
and conditions that must be
adhered to.
 Initial discussions between
sponsor representatives and
UCD|AMC faculty or staff are
encouraged as necessary to
confirm mutual interest.
Contract Review and Approval
Before any commitment is made, the following need to be
submitted and approved through regular internal review
procedures:
• A routing form
• An agreement (including a budget) must be submitted and
approved through regular internal review procedures
• Approved by an OGC authorized institutional official.
Typical types of contracts include:
 Clinical trials
 Corporate sponsored agreements
 Federal contracts
 State agreements
Contract Review and Approval
OGC is responsible to negotiate contracts with industry, agencies or state
and the Federal government, local municipalities and non-profit
organizations before the award is approved.
OGC will review:
 The terms and conditions of the award before obtaining an authorized
signature (when a UCD|AMC signature is required for award acceptance).
 Agreements and award documents for
• Comprehensiveness
• Appropriate language
• Compliance with guidelines set by the sponsor as well as the UCD|AMC and
State requirements.
 The award notice for special terms and conditions, including prior approval
requirements, and cost sharing.
 Negotiate terms and conditions for all UCD|AMC awards as needed.
Intellectual Property issues (e.g., ownership of inventions and confidentiality)
 Requires the review by the Office of Technology Transfer.
Contract Review and Approval
OGC will review the award language to ensure that:
• The terms are clear.
• The essential elements of a contract are included and
appropriate based upon the scope of the contract.
• There is a budget providing for compensation of the work
performed.
• Terms of payment are clear, appropriate and manageable.
• The sponsor’s invoicing requirements are appropriate and
clear, including how the sponsor will be invoiced.
Contract Language
Some contracts have terms and conditions that are likely to
cause problems down the road.
Some examples of real problems include:
• Contracts with reporting terms that could not be fulfilled by UCD|AMC
and thus jeopardized payment by the sponsor.
• Terms that included “payment will be withheld” meant that UCD|AMC
was never paid.
 Also consider the financial stability of the company and the ability
of the sponsor to meet the obligations of the contract.
 Acceptable agreements are to be signed by the authorized
representative of the parties involved.
Award Acceptance
Award documents requiring a signature for acceptance must be signed by an
authorized official of UCD|AMC.
• Only those persons specifically authorized by the Regents of the University of
Colorado or authorized delegates may legally sign agreements for the Regents,
acting for and on behalf of UCD|AMC.
Gentlemen's Agreements and/or Handshakes ≠ Awards!
• Awards requiring a signature for acceptance are not considered final until all parties
have signed the agreement and one original of the fully executed agreement is
received by OGC|AMC.
• Awards not requiring a signature for acceptance by UCD|AMC will be reviewed before
the award is accepted internally by OGC.
• When a UCD|AMC signature is required for award acceptance, OGC in consultation
with the PI, will review the budget, terms, and conditions of the award before
obtaining an authorized signature.
Award Acceptance
Important Points:
 The award is to UCD|AMC
 The award is not the PI’s personal spending
money
 Most awards have restrictions
 Most awards require some accountability
Award has been Accepted: Now Monitor it!
Award Monitoring
• UCD|AMC is required to keep separate records of each award that
is funded.
• This separation of records is maintained in a paper file in OGC
while financial information is maintained in the PeopleSoft financial
system.
• In addition to institutional records, it is critical that the PI and
department keep records (segregated by award) to keep track of the
day-to-day activities of the project.
– The record should include:
 Hiring
 Expenditures
 Reporting activities
Keep Good Records!
The PI or designee should establish a filing system for award
monitoring:
• Each award should be maintained separately, with the complexity
of the record retention method being dependent on the type of
award, reporting requirements including financial and technical
reporting, the term of the award, purchasing and subrecipient
arrangements, cost sharing, human, animal or bio-safety
documentation, approvals and other requirements.
• All documents related to the preparation, negotiation, award
acceptance, expenditure activities including electronic Personnel
Effort Reports (ePERs), hiring activities, monthly project or
program statements, reports, subrecipient agreements or other
services agreement should be maintained.
Award Set-up
An awarded proposal will be given a particular
designation in the financial system.
• Awards will be set up in the PeopleSoft Financial System
based on the type of award.
• The PeopleSoft Financial System is the centralized
electronic financial system for the University:
 Processes on-line purchasing documents
 Provides financial status updates
 and Produces monthly accounting reports.
Restricted Funds
Fund 30 - Federal, State & Private Sponsors
Records financial activity as a result of grant or contract awards to
the UCD|AMC where the sponsor of the activity is a Federal, State,
or private sponsor.
Fund 31 - Local Government Sponsors
Records financial activity as a result of grant or contract awards to
UCD|AMC where the sponsor of the activity is a level of local
government, such as a city or county within Colorado.
Fund 34 - Gift Funds
Records monies accepted by the CU Foundation as charitable
contributions and subsequently transferred to UCD|AMC for use by
UCD|AMC exclusively to fulfill its exempt purpose(s). There can be
no expectation of economic benefit on the part of the donor; i.e., no
deliverable.
Account Codes in PeopleSoft
PeopleSoft utilizes categories and subcategories for
budgeting and spending on a project.
• Subcategories allow the funds to be recorded and
monitored in finer detail.
For example: there is an account code to use when charging UCD|AMC
projects for UPI physician services called UPI Physician Billing.
• Correct recording of expenditures is beneficial,
helping to reduce accounting and reporting problems
later.
• PeopleSoft can work to the advantage of the PI,
administrative unit, and UCD|AMC if used correctly.
Account Codes
It is the Office of Grants and Contracts responsibility to:
• Set up the project in the financial system (PeopleSoft)
• Establish the appropriate budget for the project, in accordance
with the sponsor’s award.
 A project number will be set-up and assigned.
 OGC will contact the designated departmental administrator with the
awards’ project number(s) and speed type number(s).
These numbers should be used to appropriately charge the financial
activity (deposits and expenditures) for the award.
• Always check the budget in PeopleSoft to ensure it fits with your
understanding of the award.
• Clinical trials are not set-up with budgets in PeopleSoft given the
nature of the work and the funding.
Gift Funds
The CU Foundation handles gifts, therefore, gift funds should only
be deposited with the CU Foundation.
Handled differently from Grant or Contract funding
Gift funds should never be:




Directly deposited into a program fund at the campus level
Deposited in a bank account outside of the University
Deposited with UPI
Transferred into a program fund from another project or
program (either by crediting a revenue or expenditure
account).
See Fiscal Policy 4-14, Accounting for and Deposit of Gifts.
Pre-Awards
The mechanism used to set
up a project in the financial
system prior to the actual
receipt and acceptance of
an award document.
What is a Pre-Award?
How do I apply for a Pre-Award?
For more information and Guidelines, Read the Fiscal Policy 4-10
“Establishing a Sponsored Program/Project Without an Award Document”
Pre-Award Procedure
To request a Pre-Award for a proposed project
Submit the following to OGC in accordance with Fiscal Policy 4-10:
 Completed Routing of the Proposal Application with Approvals
 Completed Departmental Guarantee Memorandum Form (Pre-Award Request Form)
If a Pre-Award is granted
 It will result in the assignment of a financial system project number being set up.
 The PI can then charge expenditures to that project number within the restrictions
placed on the pre-award.
The department assumes full financial responsibility
 For ALL expenditures incurred on a pre-award basis.
Note! It is inappropriate (and at times even considered fraud) to incur costs on other
sponsored projects with the intent to transfer those costs later to another project.
There is a risk!
 If an award is not received, (and a contract goes unexecuted, or a
sponsor decides to disallow pre-award costs regardless of the reason)
the department must transfer any disallowed or unfunded costs to the
unrestricted account designated on the Guarantee Memorandum.
Billing and Payment
Once the award is set-up in PeopleSoft
• There is the expectation by UCD|AMC that
funding (in whole or in part) will be received to
cover the expenditure activity of the project.
The cash management expectations of awards will vary based on the
funding mechanism and sponsor.
Funding Mechanisms
There are several funding mechanisms
that may be used when UCD|AMC enters
into a sponsored project.
The three primary types of funding mechanisms are:
• Cost Reimbursement
• Fixed-Price
• Fixed-Rate
Cost Reimbursement Funding Mechanism
The cost reimbursement type of payment mechanism is set up so that
the sponsor will reimburse UCD|AMC for actual dollars spent on
allowable expenditures to carry out a project.
• Also known as “Pay after the fact”
• Agreements are normally performed on a best efforts basis and
create the least amount of risk for the University.
• Many federal agencies will provide grant award funds for a specified
budget period in advance. These are still considered cost
reimbursement.
A common component of federally funded cost reimbursement grant awards is that
any monies paid in advance, which are not spent, are to be returned to the sponsor
at the end of the budget period (unless indicated otherwise).
• UCD|AMC can only keep funds that have been spent appropriately.
• Any advance payments may also place a requirement on UCD|AMC
to pay interest to the sponsor.
Fixed-Price Funding Mechanism
Occurs when UCD|AMC agrees to provide services or deliver a
product for a fixed level of compensation.
• If the cost of providing such service or product exceeds the fixed
amount of funding, UCD|AMC (and thus the administrative unit) would
be required to cover any uncompensated costs.
• A fixed-price funding structure is more complicated if the award is
terminated early.
Termination may require UCD|AMC to negotiate final payment amounts based on
actual expenditures.
• PI’s often view a fixed-price funding structure as more favorable, but
this method carries with it additional risk
For example: Cost Over-runs
• Fixed-price funding structures are not appropriate for certain types of
research.
For instance: Basic or development research with defined deliverables that specify
certain results would not be appropriate.
Fixed-Rate Funding Mechanism
The Fixed-Rate funding mechanism structure occurs when:
•
Payment is not based on actual costs expended, but on a mutually
agreed upon rate per activity performed.
Fixed-price and fixed-rate agreements may result in large residual
balances at the end of a project if expenses are lower than budgeted.
Residual Balances
Large residual balances raise suspicions that
expenditures were charged inappropriately
• A red flag for auditors is finding large residual balances
(excess funds) at the end of an award.
Examples of Suspicions raised by red flag items:
• Charges were made to another project inappropriately
• Patient billing was not handled appropriately
• A conflict of interest may be present
Keep this in mind when managing fixed price and fixed rate agreements
Payments
Payments are received by UCD|AMC from a sponsor in one of the following
ways:
•
•
•
•
•
•
Advance payment of the entire award amount
Scheduled payments made on receipt of deliverable(s) or at a given time frame
Payments made upon receipt of invoice(s) that include actual expenditure
information
Mixed payment method,
For example: An advance partial payment and then scheduled
payments on receipt of deliverables.
Many non-federal or federal flow-through agreements require UCD|AMC to
invoice the sponsor in order to receive payment.
OGC will prepare and submit invoices to the sponsor based on expenditures
made and recorded appropriately in PeopleSoft
Non-federal Clinical Trials are normally based on patient information
and accordingly are not billed by OGC.
•
OGC also manages accounts receivable for projects. OGC bills and assists in
pursuing prompt payment of sponsor commitments.
Final responsibility is with the departments.
Invoicing
If PI’s signature is required on
the invoice
 The signed invoice must be
returned to OGC as soon as
possible.
If the PI is required to provide
additional information to the
sponsor for billing purposes
 It is the PI and department’s
responsibility to provide
necessary documentation on
a timely basis to OGC.
Clinical Trails
In the case of Clinical Trials, it is appropriate for the PI to work
directly with the sponsor to receive payment.
If the sponsor requires receipt of a deliverable then it is the PI’s responsibility to
provide such information in a timely manner.
For Example: A technical report, case report forms, etc.
For clinical activities
• It is the responsibility of the PI to ensure expenditures are charged to the
project appropriately.
• This includes ensuring that (if any)
- Invoicing/financial reporting
- Hospital/patient care charges
- Billing for patient care charges
- Medicare billing is handled appropriately
- The project functions on a positive
cash basis
See Fiscal Policy 4-1, Clinical Trials for details
• Departments with multiple clinical trial awards may want to consider
establishing a Service Center for the provision of services to the clinical
trials due to the variety of payment methods.
See Internal Service Centers and Core Laboratories policy for more information.
Wire Transfers
Wire transfers can be set up
for receipt of payment from
sponsors.
• Contact OGC for wire
Information and assistance.
Receipt of Payments
When payment is received for a project
 OGC will attempt to determine where the
payment should be recorded.
 OGC will contact departments as needed for
assistance.
For information about payments received, check PeopleSoft or contact
your Post-Award Administrator.