FP-8 Sponsored Program Management
II. Cost Sharing
III . Cost Transfer
IV. Financial Conflict of Interest and the Promotion of Objectivity in Sponsored Programs
V. Indirect Costs
VI. No Cost Extension
VII. Personnel Compensation on Sponsored Projects (Effort)
VIII. Pre-award Sponsored Program Account Request
IX. Principal Investigator/Project Director Eligibility
X. Rebudget Requests on Sponsored Projects
XI. Sponsored Program Costs
Sponsored programs are those activities that are supported by funding external to the general operating budget of the institution. Sponsored program funding is restrictive in nature in that the activities it supports are specified by the external agency through the mechanisms of grants, contracts, and/or cooperative agreements. Sponsored program funding is awarded to East Tennessee State University – not to individuals or subunits of the institution - and is managed by the Office of Grant Accounting in the Office of Finance and Administration. The Office of Research and Sponsored Programs Administration is responsible for the review and submission of proposals for sponsored program support, the negotiation of sponsored and research-related agreements, and all non-financial, post-award functions.
The following policies govern the preparation and submission of sponsored program proposals and the management of sponsored program funding at East Tennessee State University:
Cost sharing refers to the expenditure of University or third-party resources beyond the amount funded by the sponsor to support the scope of work defined by a sponsored (federal or non-federal) award. ETSU’s policy is not to voluntarily cost share on sponsored projects. When cost sharing is required by the sponsor or when there is documented evidence that cost sharing is necessary to ensure the competitiveness of the ETSU proposal, the Vice Provost for Research and Sponsored Programs may allow these commitments by approving them in writing and managing the committed university resources. 2 CFR 215.23
ETSU expects that costs directly charged to sponsored project awards will comply with the cost principles outlined in the Office of Management and Budget (OMB) Circular A-21.
Charges to sponsored projects must be:
• allowable (the cost is allowed by federal regulations, sponsor terms and conditions, including program specific requirements and University policy);
• reasonable (reflects whether or not the individuals concerned acted with due prudence in the circumstances);
• allocable (the cost has a direct benefit to the account being charged); and
• treated consistently (like costs in similar instances are treated consistently throughout the University). 2 CFR 220 App A
East Tennessee State University (ETSU) and its employees are committed to the principle of free, open, and objective inquiry in the conduct of its teaching, research, and service missions. The University encourages such endeavors as they enhance personal competency and benefit the community and ETSU. These interactions, however, create the potential for financial conflicts of interest where an individual's financial or personal considerations may affect or appear to affect their ETSU institutional activities. A financial conflict of interest depends on the situation, and not on the character or actions of the individual. It is through disclosure to ETSU of significant financial interests related to an employee’s institutional responsibilities that such activities may be reviewed and, if warranted, managed. The disclosure of significant financial interests is mandatory for all investigators involved in sponsored research. 42 CFR Part 50, Subpart F
Facilities and Administrative (Indirect or F & A) Costs are the real costs of University operations which are not readily assignable to a particular project. These costs are determined by federal auditors under the guidelines of OMB Circular A-21. Facilities and Administrative Cost rates are negotiated with the Department of Health and Human Services (DHHS)--the federal cognizant audit agency for East Tennessee State University. These rates are applicable to all federally sponsored projects and, in accordance with University policy, are also extended to include all non-federal sponsored projects.
Full recovery of these costs is expected on all grants or contracts. The attachments below contain the pdf files of our signed Facilities and Administrative Rate agreements. All deviations from the negotiated Facilities and Administrative Rates must be approved by the Vice Provost for Research. There are three main F&A activity types under ETSU’s negotiated agreement. They are: (1) "Organized Research," (2) "Instruction and Training," and (3) "Other Sponsored Activities." It is important to choose the correct activity type for a proposal, since it determines which F&A rate to use. It is also important to remember that the activity is what occurs during the project period and not for what might result after the project period. (see also “Sponsored Program Costs)
Grants and sponsored agreements are awarded with the expectation that Principal Investigator/Project Director (PI/PD) will complete the sponsored project within a certain time frame. When that time frame cannot be met, the PI/PD may request a time extension at “no cost”, meaning additional time will be provided to complete the project, without additional funds. NCE requests are generally directed to the sponsor for approval. However, some sponsors permit the institution’s business representative, or the authorized institutional official, to approve or deny requests following sponsor-defined guidelines.
Personnel costs on ETSU sponsored projects will be budgeted and charged to the sponsored project commensurate with the individual’s committed ETSU effort on the project and at their established institutional base rate of pay. Under no circumstances will personnel charges to sponsored projects exceed the proportionate share of the base salary for that period. Personnel charges on sponsored projects replace, not supplement, the existing pay source. 2 CFR 220, App A
The establishment of a Pre-Award Sponsored Program Account may be requested prior to the receipt of an official notice of grant award or a fully-executed sponsored agreement if there is sufficient evidence that a sponsored award is imminent and the Principal Investigator/Project Director’s department accepts financial responsibility for any project costs incurred if the event the award does not materialize.
East Tennessee State University (ETSU) assumes significant financial and legal obligations when proposals are submitted to external sponsors and awards are accepted for sponsored projects. Sponsors fund projects based on the professional expertise of the Principal Investigators/Project Directors (PI/PD) submitting proposals. However, the award is made to ETSU. Under the general oversight and authority of ETSU, the PI/PD is the individual who bears primary responsibility for technical compliance, completion of programmatic work, fiscal stewardship of sponsor funds, and compliance with administrative requirements of the project. Thus, the University must ensure that individuals serving in the capacity of PI/PD have the technical competence and administrative capabilities to carry out a sponsored project.
There is considerable variation in sponsor policies relative to approval authorities for budget revisions. Accordingly, sponsor agency guidelines and award terms must be consulted when revisions are contemplated. Budget revisions should be based upon the financial plan and cost trends for the award budget period involved. To the extent possible, budget revisions should reflect all necessary reallocations of resources that are foreseen through the end of the budget period. Revisions solely for the purpose of coping with near-term problems (e.g., a $35.00 overdraft in the supplies category) should be avoided. 2 CFR 215.25
ETSU will charge costs to sponsored projects in compliance with Federal regulations and ensure all costs are reasonable, allocable, consistent and allowable. Those involved in charging costs to ETSU accounts must meet Federal costing standards and ensure that all costs are allowed and charged in a manner that is an accurate reflection of the expenses incurred for the benefit of the project. Unallowable costs will not be permitted on sponsored projects, and, if charged to a sponsored project, will be moved to non-sponsored funds. These costs will be included on the appropriate base when calculating the F&A rate. 2 CFR 220 App. A
ETSU is responsible for the programmatic and financial monitoring of its sponsored research award subrecipients. A subrecipient is a third-party organization performing a portion of the scope of work on ETSU research projects or other sponsored programs. The terms of ETSU subrecipient relationships are documented in subaward, subcontract, or consortium agreements. These procedures delineate specific business activity that should be performed in managing subrecipients of sponsored research awards. OMB Circular A-133 Compliance Supplement M