Procedures Manual for Grants and Sponsored Programs PDF

Procedures Manual for Grants and Sponsored Programs

The mission statement of Augusta State University indicates that the university is committed to excellence in teaching, advancement of knowledge, and enrichment of the community in a climate that fosters humane values and a life-long love of learning. Both effective teaching and the advancement of knowledge presuppose the necessity of research and other scholarly work by the faculty. Although it is true that research is an important aspect of the professional lives of many professor-scholars and can be time-consuming, grants and contracts often offer the opportunity of off-setting some of the expenses involved, as well as the opportunity to enhance the professional status of the individual faculty member and the academic prestige of the university.

Augusta State University is not designated as a research university. Therefore, care must be taken to maintain a proper balance between teaching responsibilities and research activities. In most cases, research undertaken by a faculty member will be in addition to a regular teaching load. In some instances, the grant or contract itself may provide for some reassigned time for the faculty member by providing funds for a substitute. However, reassigned time will not be authorized except in cases where the course needs of the students are guaranteed. As is the case in consulting activities, the faculty member must communicate, in writing, to the Vice President of Academic Affairs that the research activity will not interfere with the faculty member's teaching and other responsibilities.

Faculty members are encouraged to seek external grants and contracts in support of their research, service and instructional activities. The Grants Office serves as the first point of contact for faculty seeking approval for the submission of proposals to external sponsors. Office staff will assist in identification of funding, interpretation of guidelines, project/concept development, editing, preparation of forms and budget development.

It is important to notify the appropriate supervisor early in the proposal development stage to insure that the project is in concert with the mission of the department/unit, and that internal support for project activities will be available. Matching funds, release time, and other institutional commitments should be secured from the department chair and the dean well in advance of developing the actual final proposal. Please allow at least two weeks prior to final deadline to notify that appropriate administrators of your intent and to discuss your plans with these individuals.

To insure accurate, comprehensive and coordinated management of all sponsored activities, all proposals for external grants and contracts originated by faculty or staff members at Augusta State University are to be routed through the Grants Office. The Grants Office serves as the institutional single point of contact for all grant and contract activity.

Section 1: Proposal Development

Section 2: The Budget

Section 3: Application Procedures

Section 4: Post Award Management

Section 5: P Cards

Section 6: Post-Award Compliance Issues

Section 7: Post-Award

Section 1 - Proposal Development

Initial Proposal Procedures - Before the Proposal Leaves Campus

The procedures below exist to expedite, not impede proposal submission by guiding project directors through the application process.

1.1 Preparing a Proposal

All proposals to external funding sources for research and sponsored programs submitted by Augusta State University faculty, staff and administrators are routed through the Grants Office. All project directors should obtain preliminary, informal approval of each project from the department head and dean. Faculty and administrators are welcomed and encouraged to contact the Grants Director to discuss ideas, opportunities, questions, or for assistance in project proposal development and planning. The GASP Office will help to ensure that the submitted proposal is in compliance with application guidelines. The Grants Director will read the submission guidelines to:

• ensure eligibility
• highlight all details and required attachments
• assist in providing historical background, and demographic information as needed
• read and edit the submission for compliance with guidelines
• complete and/or obtain signatures on applications as needed.

1.1.1 The Grants Office drafts or reviews project budgets
T he PI/PD will prepare an initial budget using the proper institutional codes. The Grants Director assists in securing matching funds or developing match or cost sharing resources. In most cases, it will be the responsibility of the PI/PD to locate matching funds. The Principal Investigator or Project Director signs and obtains the signatures of the appropriate department chair and dean on the Budget Summary.

1.1.2 The Principal Investigator or Project Director, with collaborators or key personnel, drafts the narrative segment of the proposal.
The narrative is written according to the application guidelines in regard to margins, font size and type, number of pages, and organization of information. The Grants Director will assist in completing cover pages, certifications, assurances, or other documents required for the submission process.

1.1.3 The Principal Investigator or Project Director completes the Internal Proposal Routing Form .
The Principal Investigator or Project Director completes an Internal Proposal Routing Form . The Principal Investigator or Project Director signs and obtains the signatures of the appropriate department chair and dean on the Internal Proposal Routing Form.

1.1.4 The Vice President of Academic Affairs and the Vice President of Business Operations, prior to submission, approves all proposals, regardless of budget amount.
The Grants Director presents the Internal Proposal Routing Form and the signed budget to the VPAA and the VPBO. The two review the proposals for relevance to Augusta State 's Strategic Plan.

• Source of matching funds or cost sharing
• Faculty release or replacement costs
• Augusta State 's overall ability to implement the project
• Accounting requirements

The Vice Presidents may perform an expedited review when:

• The amount of the proposal budget is $1,000 or less, or
• The budget does not include faculty release or replacement costs.
  

The Grants Director may ask the Principal Investigator or the Project Director to make changes to the proposal and/or budget before submission is approved.
The Grants Office copies, collates, and mails all proposals, or assists with and approves electronic submissions as needed.

1.1.5 The signed Internal Proposal Routing Form serves as documentation of approval to submit the proposal.

•  The signature of the appropriate department chair(s) and dean(s) indicates approval of the budget.

•  The signatures of the Vice Presidents indicate approval by the University.

1.1.6 Any external funding application forms requiring an authorized signature from the University are routed through the Grants Office.
The Grants Office routes the forms to the Vice Presidents for signatures.
In the absence of one of the Vice Presidents, the Associate Vice President of Academic Affairs will sign the form.

1.2 Activity Definitions

1.2.1 University Instruction means the teaching and training activities of the University that are supported by University funds and are not related to a sponsored project. This category includes all teaching and training activities, whether they are offered for credit toward a degree or certificate or on a non-credit basis, and whether they are offered through regular academic departments or separate divisions such as the Division of Continuing Education. This includes activities such as test grading and preparation, class monitoring, demonstrations for student groups, scheduling, revising existing/designing new academic courses, Thesis/Dissertation supervision, serving on student research and academic project committees, etc.

1.2.2 Sponsored Instruction means specific instructional or training activities established by grant, contact or cooperative agreement and that are budgeted and accounted for separately by sponsored account. A separate line should be completed for each sponsored project and associated effort.

1.2.3 Cost Shared Instruction means specific instructional or training activities in support of a sponsored instruction project that is funded by University funds. This category would include both mandatory and voluntary cost sharing on sponsored instruction projects. The sponsored project account number must be specified.

1.2.4 University/Department Research means all research and development activities that are supported by University funds and are not elated to a sponsored project.

1.2.5 Sponsored Research means all research and development activities established by grant, contract or cooperative agreement and that are budgeted and accounted for separately by sponsored account. This category includes activities involving the training of individuals in research techniques (commonly called research training) where such activities utilize the same facilities as other research and development activities and where such activities are not included in the sponsored instruction function. A separate line should be completed for each sponsored project and associated effort.

1.2.6 Cost Shared Research means specific research and development activities in support of a sponsored research project that is funded by University funds. This category would include both mandatory and voluntary cost sharing on sponsored research projects.  Sponsored project account number must be specified.

1.2.7 University Public Service means activities that are established primarily to provide non-instructional and non-research services to individuals and groups external to the University. This category includes community service programs, technical assistance, consulting services, and similar non-instructional services.

1.2.8 Sponsored Public Service means specific public service activities that are established by grant, contract or cooperative agreement and that are budgeted and accounted for separately by sponsored account. A separate line should be completed for each sponsored project and associated effort.

1.2.9 Cost Shared Public Service means specific public service activities in support of a sponsored public service project that is funded by University funds. This category would include both mandatory and voluntary cost sharing on sponsored public service projects.

1.2.10 Departmental Administration means all activities provided for administrative and supporting services that benefit common or joint departmental activities (instruction, research and public service) in academic dean's offices, academic departments, and organized research units. It includes the administrative effort of dean's, department heads, faculty, professional staff and non-professional staff whose activities provide administrative support for activity stated in sections 1.2.1 through 1.2.9. See the Departmental Administration checklist on the reverse side of the Personnel Effort Report.

1.2.11 Other Sponsored Activities means specific activities that are established by grant, contract or cooperative agreement and that are budgeted and accounted for separately by a sponsored account. This category includes activities not reflected in sections 1.2.2, 1.2.5 and 1.2.8. Examples of other sponsored activities would include library grants, student service grants, energy conservation grants, etc.

1.2.12 Additional Activities includes any activity not defined in categories 1.2.1 through 1.2.11. For this category, please provide a short description of the type of work performed.

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Section 2 - The Budget

2.1 Fiscal Considerations: Budget Preparation

The budget of a grant proposal is second in importance only to the description of the principal ideas of the project. While the budget preparation requires much special consideration to comply with the various policies of the university and the funding agency, the budget statement is not a document impossible to construct.

If the funding agency provides a specific budget form, it must be used. In most cases, any special forms will be included by the agency as part of the application package. The PI is required to complete the ASU Budget Sheet attached to routing form. This breakdown will help you to plan in detail for the financial support required for the various components of your project, to calculate personnel time and costs for the project staff, and to calculate indirect costs. It will be valuable in the university's internal review process. Moreover, it will help in determining the university's contributions (matching or cost sharing on a cash or in-kind basis), if these are required by the agency.

2.2 Outline Steps to Follow in Budget Preparation

a) Review the rules and regulations for the budget, as provided in your copy of the agency's guidelines or RFP.

b) Decide on the amount of time that you and other professionals involved in the project will have to contribute.

c) Figure the time required for assistants and secretarial or clerical help, for consultants, honoraria, travel, lodging, subsistence.

d) Estimate the costs of equipment, supplies, printing, duplication, media services, staff services, postage, telephone, data processing time, etc.

e) The finalized budget is included with the narrative portion of the application and processed through institutional review.

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2.3 Direct Costs

Direct costs include all items that can be categorically identified and charged directly to the specific project. Most sponsors allow direct costs funding for the following categories:

2.3.1 Personnel . Calculate the percentage of time spent on the project for each individual and pro-rate the salary for the proposed implementation period of the grant. All salaries must be calculated as a percentage of your current year contract.

•  Principal investigator or project director.

•  Other on-campus professionals.

•  Student assistants. Undergraduate students also may be employed on sponsored research projects, but students on University Work-Study Program (CWSP) may not be paid from a second source of federal funds. PIs may contact Financial Aid for assistance in locating qualified student assistants. Although the PI is responsible for the selection and hiring of all such assistants, appointment forms must be processed through normal university channels. Pay scales should conform to those current within the university.

•  Technicians, etc.

•  Secretarial, clerical help may be charged as a direct cost in some cases. In others, they become part of your indirect pool. Check the regulations appropriate to the funding source. PIs should recognize that "classified" personnel hired on a sponsored program grant must receive comparable salary, duties, responsibilities, and benefits as those in a comparable position elsewhere in the university. The PI should consult with the Personnel Office concerning current or projected salaries for these positions. All personnel who are hired for the specific purpose of a grant must be informed by the PI that their employment period coincides with the award period and that the University cannot be assumed to continue their employment beyond the period for which grant funds are available.

2.3.2 Fringe Benefits . Fringe benefits accompanying salaries paid by the grant will be charged to the grant unless the Vice President of Business Operations agrees that the Institution will pay for it. Consultants are not eligible to receive fringe benefits.

Formulas for Calculating Salary, Wages, and Fringe Benefits

If you are on a 10-month salary:

•  One course reduction = 1/10 of salary shown on your contract

•  One month = 1/9 of salary shown on your contract

Calculation of Fringe Benefits

•  New Full-Time position use =1.45% FICA med, 6.2% FICA, 9.24% retirement, $114 basic life, and $8,560 for health insurance

•  Faculty additional pay = 1.45% FICA med and 6.2% FICA

•  Part-Time Faculty = 1.45% FICA med

•  Regular Summer Faculty = 1.45% FICA med and 6.2% FICA for additional pay only, 9.65% retirement

•  Professional/Admin = 1.45% FICA med and 6.2% FICA and 9.65% retirement

•  Part-Time Administrator (monthly employee) = 1.45% FICA med

•  Staff (bi-weekly employee) = 1.45% FICA med and 6.2% FICA and 9.24% retirement

•  Overtime = 1.45% FICA med and 6.2% FICA

•  Part Time Clerical Staff = 1.45% FICA med

•  Graduate Assistants = no fringe benefits are calculated

•  Student Assistants = no fringe benefits are calculated

Please contact the Grants Office for assistance.

2.3.3 Consultants . Outside consultants may be paid through grant funds. All honoraria, consultants' fees, travel expenses, subsistence, and related expenses must conform to established University Procedure for reimbursement.

2.3.4 Subcontractors . Augusta State University does not normally subcontract. If subcontracts are essential to the successful completion of a sponsored program advance arrangements must be made with the Business Office and institutional approval must be sought.

2.3.5 Travel . All travel paid from grant funds must conform to the university travel. Consult the Business Office for details of current travel policy. The ASU travel policy is posted on the Business Office web site at www.aug.edu/business_office.

2.3.6 Equipment . Equipment may be purchased or rented, according to the policies of the grantor. The equipment budget should reflect the price of freight, installation costs, and maintenance contracts, as appropriate. All equipment purchased with grant funds become the property of ASU.

2.3.7 Supplies and Materials . Supplies and consumable materials must be itemized on the budget explanation page. Spending must be approved by the grantor if it does not fall under state spending policy.

2.3.8 Other Direct Costs . These costs are items that can be identified and related to the project and not included in the indirect costs calculations:

•  Communications - costs of telephone and postage;

•  Publication charges - graphics and printing, duplication, media services, final report costs, etc. and;

•  Miscellaneous cost of project operation.

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2.4 Extra Compensation

Research and Saturday classes will ordinarily be carried by System personnel as part of their normal work load without additional financial compensation. Adequate allowance in time assigned for the extra duties shall be made by a proportionate decrease in the teaching load.

Extra compensation may be paid, however, when all four of the following conditions exist:

• The work is carried in addition to a normal full load.
• No qualified person is available to carry the work as part of his/her normal load.
• The work produces sufficient income to be self-supporting.
• The additional duties must not be so heavy as to interfere with the performance of regular duties.

When extra compensation is paid, it shall be in line with compensation paid for performance of the employee's normal duties.

Payment of compensation to faculty members for full-time employment during the summer session shall be at a rate not to exceed 33-1/3 percent of their regular nine months compensation for the previous academic year.

The above guidelines are strict guidelines to be followed for all state grants and contracts, unless specifically stated to the contrary in the award notification and award acceptance paperwork. Some funding agencies do not allow extra compensation on grants or contracts, and some funding agencies have a limit on extra compensation. Please be aware of these limits before applying for grant funds. There is no limit on extra compensation earned through private grants and contracts, during the summer, unless specifically stated in the grant guidelines.

Augusta State University full-time faculty and employees may be paid for additional services performed under grant auspices. However, authorization for compensation in excess of the regular salary must be in accordance with the University policies and procedures. Please note: Federal regulations prohibit compensation beyond 100% of the individual's salary from sponsored program funds unless explicitly approved by the sponsor.

2.5 Indirect Costs or Facilities and Administrative Costs (F&A)

Indirect costs are those that have been incurred for common or joint objectives of the university and the sponsored program and which, therefore, cannot be identified specifically in reference to a particular project.

Indirect costs include items such as building operations and maintenance, laboratory space, library services, utilities, and administrative services. Indirect costs related to the conduct of a sponsored program are just as real as the direct costs and ultimately must be provided for either by the sponsor or by the university. Note that some federal agencies have specific rules regarding indirect cost rates. For example, the US Department of Education places an 8% cap on IDC recovery for training grants and disallows the use of unrecovered indirect costs to meet matching or cost-sharing requirements for training grants.

Check the rules provided in the agency's guidelines or RFP. Show unrecovered indirect costs in the cost-share column of your budget. If you are not allowed to use these costs to meet your cost sharing requirement, make sure that the sum of the other costs in this column add up to the appropriate amount. Note that indirect cost funds, when awarded, are not available for use in the project itself. Costs of the project must be paid by direct costs as outlined in the original proposal budget.

2.5.1 Augusta State University Procedure For Facilities and Administrative (Indirect) Cost Recovery

A-21, Cost Principles for Educational Institutions , was revised by OMB (Federal Office of Management and Budgets) as of May 8, 1996 .

One of the revisions changed the term "indirect costs" to "facilities and administrative costs" (F & A Costs). Augusta State University policy is to seek full reimbursement of F & A costs in connection with all externally supported programs. It is recognized, however, that some donors and grantors have fixed policies limiting the reimbursement of F & A costs. The University will consider sponsor-imposed conditions regarding the limitation or waiver of F & A costs if required by federal law or regulation, or if the sponsoring agency (foreign, domestic, Private Corporation, foundation, or other business entity) publishes a rate or policy that is consistently applied to all grants and contracts with educational institutions.

In addition, it must be demonstrated that the project is of significant importance to the university to warrant subsidizing the F & A costs from other programs. Gifts and grants for scholarships and fellowships are not subject to this Procedure. Requests for exceptions must be submitted to the Vice President of Academic Affairs and the Vice President for Business and Student Services for approval.

Formula for Calculating Indirect Costs:

Up to a maximum of 50% of salary and wages depending on the funding source (do not include fringe benefits).

2.6 Proposal Negotiation

It is the responsibility of the PI to negotiate with the funding agency for a particular proposal. Many times a proposal is considered eligible by the sponsor, but the funds requested exceed what the reviewers feel necessary or what the agency has available to support the project. A reduction in the budget would then become necessary. Negotiated budgets should be routed through the local review channels before the university accepts the negotiated proposal.

Remember that a reduction in the budget may create changes in the scope of the work. To maintain credibility with the funding agency, the PI should consider a work reduction commensurate with any substantial budget reduction. Often personal and professional relationships develop between individual faculty members and agency staff personnel. ASU encourages the development and maintenance of good contacts and informal discussions with granting agencies. It is important, however, to remember that such informal discussions do not represent the agency or university commitments. It is important that all contracts entered into on behalf of the university be signed by an authorized institutional representative (Vice President of Academic Affairs, Vice President for Business Operations and the President).

ASU urges that the full cost of work-both direct and indirect costs- be requested in every outgoing proposal.

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Section 3 - Application Procedures

3.1 Introduction

Application for financial support from sponsoring agencies is accomplished by the submission of a formal grant proposal which has passed through the internal approval process. The proposal is the document on which the university and the sponsor base their commitments of funds, facilities, and services for the performance of the research or project. The written proposal may be the only contact that the funding agency's evaluation committee has with the project. It is essential that the proposal be technically sound and well composed.

The proposal must address itself specifically to the requirements listed in the guidelines or request for proposal (RFP) and describe the project in the clearest possible terms. Funding agencies review and evaluate proposals with reference to four major considerations:

a) The possibility of significant results to be obtained from the research project;

b) The resources required to conduct the project are analyzed in terms of existing and projected commitments of the agency and the university;

c) The request for funds is evaluated in reference to cost effectiveness and efficiency;

d) The competency of the investigator to undertake the proposed research.

Most sponsors, particularly agencies of the Federal Government, furnish standard application forms, which must be used. In the absence of specified forms and proposal formats, it is most important to follow the guidelines of the RFP and respond to the specific requests in the RFP, in the same order and attention.

3.2 Deadlines

It is the responsibility of the PI to know the deadlines for submission of the proposal and to allow adequate time for the institutional approval process. At least a week should be given for the approval process, but this time will vary. Time for review is essential to the completion of a competitive proposal.

3.3 Institutional Approval Procedure

It is important to realize that the institutional approval process is a necessary step which must be taken before mailing your proposal to the granting agency. Completion of the institutional approval and budget form entitled "Approval to Submit Proposal for External Funding" is required by the University. Submit the original completed and signed form, along with copies of the abstract, face page, final budget and budget narrative, certification and signature pages, and evidence of approval if F&A costs (indirect) are not being recouped, to the Grants Director before you mail the proposal.

Appropriate signatures must be obtained before the proposal is sent to the potential sponsor. These signatures show that your proposal is not at odds with university/college goals or departmental goals, that any university/college or departmental cost-sharing is approved and that you have not committed more than 100% of your time without an approved overload. The approval procedure is designed to ensure that the individual grant-writer does not make commitments, financial or otherwise, which cannot be honored by the University.

The Grants Director is required to keep a copy of all grant proposals, award notifications, reports and other important grant paperwork on file in the grants office. Under no circumstances should a proposal be mailed without first being approved. Changes to the proposal after the approval process is complete will mean that the proposal will need to be rerouted .

The internal review process has been streamlined as much as possible. For instance, the approval form also serves to document your compliance, or lack thereof, with certain federal regulations, thus making a separate memo for each assurance unnecessary. Please remember that, with the exception of fellowships, every grant you receive as an employee of this university will be a grant to the university, not to you as an individual. The recipient of a grant may have certain intellectual property responsibilities to the university and should discuss those issues with the Vice President of Academic Affairs.

3.4 Roles and Responsibilities

The following section defines the roles and responsibilities of each signatory authority in reviewing and approving sponsored activities. Signatures on the "Approval to Submit" Form directly translate to the accountability assigned to each of the approving units, collectively forming the blueprint for a systemic compliance effort, with clearly identified responsibilities in sponsored program management.

3.4.1 Principal Investigator/Project Director
The Principal Investigator/Project Director (PI/PD) is responsible for developing the proposal in accordance with institutional policies, submission guidelines from the agency, and OMB Circulars cost standards, if applicable. The PI/PD should coordinate with his/her immediate supervisor to insure that the proposed activities are in concert with the unit's mission and available resources, and that his/her participation in the project is authorized.

The initial responsibility of the PI/PD is to prepare the project abstract or summary, budget, and budget justification, which are the necessary components of the routing protocol. Following completion of the final project abstract or summary, budget, and budget justification, the PI/PD must obtain and initiate the Approval to Submit Proposal for External Funding process. The PI/PD should complete the "Approval to Submit" Form in its entirety and attaching the necessary documentation .

If funded, the PI is responsible for insuring that the project is conducted in a timely, professional and ethical manner in accordance with sponsor guidelines; that appropriate safeguards are in place to insure the protection of humans, animals and or co-workers; that expenditures are allowable, allocable to project activities and consistent with both University policy and sponsor regulations and that appropriate records are maintained to document such expenditures; that the time/effort expended on the project is accurately documented and reported; and, that data is collected, maintained and archived in accordance with sponsor guidelines.

3.4.2 Department Chair (Unit Head)
Department Chairs are responsible for reviewing, approving, monitoring and supporting projects of interest to their division and area of responsibility. As such, the unit head will review the "Approval to Submit" Form , project abstract or summary, budget, and budget justification in order to (1) assess whether the budget appears to be reasonable and fiscally appropriate and that Cost Sharing/Matching Funds expected from the unit are acceptable, (2) determine that adequate space, equipment, faculty time, and support/collaborating personnel are available to conduct the proposed project; and (3) confirm that the proposed project is consistent with the unit's mission and strategic plan.

If funded, unit heads are responsible for providing guidance to the PI/PD in resolving programmatic and fiscal questions to insure progress; providing administrative support in maintaining appropriate fiscal project documentation, including back-up of fiscal activity; for insuring that the time/effort of senior personnel on the project is accurately reported; and, for providing cost-sharing/matching as specified on the "Approval to Submit" Form .

3.4.3 Dean(s)
Deans are responsible for reviewing, approving, monitoring and supporting projects of interest to their division and area of responsibility. Specifically, they ensure that the intellectual and academic objectives of the college and university are maintained and that the unit will have the resources to meet cost-sharing and other commitments. When a proposed project crosses academic and/or institutional lines, all appropriate deans must provide signature approval. The Grants Office will coordinate the review process, insuring appropriate sign-off as needed.

If funded, the dean is responsible for insuring that project activities remain consistent with the mission of the unit and the college; that issues are resolved in a timely manner; and, for providing cost-sharing/matching as specified in the "APPROVAL TO SUBMIT" FORM.

3.4.4 Office of Grants Administration and Sponsored Programs (Grants Office)
The Grants Office will coordinate the submission and institutional signoff processes for any proposal to a funding agency or organization. The Director and/or representative is responsible for reviewing the "Approval to Submit" Form for accuracy and completeness. In addition, the proposal will be reviewed for compliance with applicable laws and regulations, as well as with the relevant agency and university policies and procedures. The relevant considerations include, but are not limited to, institutional resource and cost-sharing commitments, Conflict of Interest and Lobbying disclaimers, and the cognizant committee's approval of the protocols for activities involving human subjects, biosafety issues, hazardous substances, and the use of animals.

If funded, the Grants Office is responsible for reviewing the award document for consistency with the original application; processing contracts which may be received as a part of the award through the Office of the Vice President for Academic Affairs securing approval signatures in accordance with the Policy on Award Acceptance; notifying the Business Office of the award and coordinating with that office to insure appropriate transfer of documents and responsibility to post-award; insuring that all compliance issues have been resolved, including insuring that all compliance committee approvals have been made; preparing and distributing the Notice of Award letter to all parties: assisting in post-award management through provision of technical advice and interpretation of sponsor rules and regulations; and, insuring that the necessary paperwork to enable fiscal interaction between the Business Office and the grant recipient is prepared and executed.

3.4.5 Vice President for Academic Affairs (VPAA)
Once the proposal has been reviewed and approved by the Department Chair and Dean, the Director of the Grants Office will forward the "Approval to Submit" Form and attachments to the Vice President for Academic Affairs for final review and signature. The Office of the Vice President of Academic Affairs will confirm that issues related to academic offerings, faculty appointments and leave, interdivisional commitments, availability of space and other resources have been properly addressed. The VPAA will not sign proposals or contracts that have bypassed the approved routing process.

3.4.6 Authorizing Official. Vice President of Business Operations (VPBO)
The Vice President of Business Operations has been designated by the President of the University as the signatory authority for all external grants and contracts administered through the University. (Faculty and staff are not authorized to sign on behalf of the University for any proposals or agreements). The VPBO verifies all cost-sharing monies and verifies all grant budgets are accurate and reasonable. Authorization for proposal submission on behalf of the University will be indicated by each of the Vice Presidents' signatures.

3.4.7 University President

The President of the University will act as the signatory authority when specifically required by the application guidelines. The Vice President of Academic Affairs is responsible for reviewing and initialing all proposals, grants and contracts before obtaining the President's signature.

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3.5 Sponsor's Evaluation

Sponsors usually outline the criteria used to evaluate proposals. An applicant has a better probability of receiving an award if the agencies' criteria are considered in the preparation of a proposal. In most cases, the prospective sponsor considers:

a) Significance. The project should focus on problems of major importance. The anticipated outcome of the project should produce communicable results of potential value to others. There should be a clear prospect of accomplishing the proposed project. The PI should either be concerned with the development of new knowledge applicable to the problem or testing previous assumptions or conclusions.

b) Design or Operational Plan. The problem to be dealt with should be well defined. The purpose and value of the project, its plan of development, method of approach, expected outcome, and need for implementation should be clear. The proposal should reflect a familiarity with the historical background of the problem, an awareness of similar projects that have been previously undertaken, and an adequate knowledge of other related activities. The questions to be answered and hypotheses to be tested should be well formulated and clearly stated. The proposal should fully outline the procedure to be followed and include information on applicable points such as sampling techniques, controls, types of data to be gathered, and statistical analyses to be completed.

c) Personnel and Facilities . The role of all professional personnel involved in the project should be clearly stated. The applicant should have facilities available which are adequate for carrying out the project. The PI should have a history of professional experience in the project area or a clearly demonstrated competence for conducting work in that area.

d) Economic Efficiency. The proposal should be reasonable in terms of overall costs, with emphasis given to the favorable relationship between probable results and total expenditures. The period of time required for efficient production should be clearly stated and a general timetable provided. Any parallel requests for support from other agencies for the same project should be indicated. Many agencies require matching funds. The ratio of requested or matching (in-kind or otherwise) contributions must be addressed in the budget and budget narrative.

e) Evaluation Plan . The plan to evaluate the degree to which the program is successful is an extremely important part of any proposal. Both public and private funders are placing increasing emphasis on the evaluation component of the proposals they review. Procedures should be clearly stated and related to each stated activity goal.

3.6 Proposal Rejections

It is very helpful to request a critique of any proposal not accepted for funding. Reviews provide valuable information for investigators and for Augusta State University in any subsequent proposals which the University might submit to the same agency. Please provide the Grants Office with a copy of any critique you receive. The critique will be filed with the original grant proposal for future reference.

In addition to a sponsor's lack of funds for project support, the most common reasons for proposal rejections are:

a) Guidelines were not followed.

b) The project did not respond directly to the sponsor's priorities or mission.

c) The research plan and objectives were not clear.

d) The proposal contained poor methodology or research design.

e) The applicant displayed a lack of knowledge or did previous work in the field which duplicates the proposal.

f) The applicant's qualifications and experience were not sufficient or appropriate to the planned activity.

g) The budget request was unreasonable in terms of the projected outcomes or proposed timetable.

h) The project could not reasonably be completed in the time proposed.

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3.7 Deciding to Resubmit

It is important to keep in mind that rejections are far more common than awards and are often not a reflection of a poor proposal or a bad project idea. Rejections are often simply the result of insufficient funds. It is important to consider resubmitting. After analyzing reviewer's comments, the principal investigator needs to decide whether or not to resubmit. If your analysis leads to the decision that the idea is not significant or is too problematic, a fresh start may be warranted. However, if problems identified by reviewers and program officials are minimal, it is appropriate to prepare the proposal for resubmission.

In many cases, since the proposal has already been approved in its initial form, the institutional approval process will be faster. Try requesting copies of winning proposals before rewriting your own. If you ask, many PI's from other institutions are willing to share copies of their winning proposals. These will give you valuable insight into what the agency will fund and help stimulate your new ideas. If you decide to resubmit to another agency there are several points to remember:

. Submission requirements between agencies often vary widely, and a proposal written to conform to the standards of one agency may need major revision to fit the guidelines of another agency.

. The funds available from an alternate agency may differ from those offered by the original agency.

. Some revision to the overall plan of your project and its budget may be necessary in order to meet funding limits of a different agency.

Section 4 - Post-Award Management

4.1 Post-award Project Management

Administering an award consists of the necessary actions for managing a grant award, from the initial authority to expend grant monies through the fiscal close-out and final report of an expired grant. The post-award management of any grant is the responsibility of the Principal Investigator (PI), the Grants Office, and the Business Office.

The post-award section of this manual contains information on the process of post-award management. In the preparation of this material, the general requirements of federal grants have been considered. However, it is important to understand that there has been no attempt to cover the specific regulations of all federal and non-federal agencies and their various programs. Principal Investigators are responsible for strict adherence to the regulations governing their awards, so it is imperative that they have complete knowledge of those regulations and the university's regulations concerning expenditures of grant awards.

The Grants Office is responsible for advising appropriate University officials on matters relating to Federal and State laws, Board of Regents, as well as University rules, regulations, and policies pertaining to fiscal management of contracts and grants. The office is responsible for insuring that the business interests of the University are protected in the terms of proposed agreements and throughout the operation of such agreements. In addition, the office is also responsible for determining that the University complies with all provisions of contracts and grants, or agreements entered into with outside companies or agencies.

The Grants Office is responsible for maintaining auditable records in support of direct and indirect charges to contracts and grants, as well as for preparing and filing fiscal reports required by grantor agencies or companies. The Grants Office is responsible for billing and collecting costs incurred on cost reimbursement contracts, and for requesting funds relating to said contracts, unless otherwise delegated by the Director.

4.1.2 Purpose of Policies & Procedures for Grant Administration

To make certain that funds provided from external sources to support the instruction, research, and public service goals of the University are administered in accordance with University policies, as well as those of the funding agency. All sponsored contracts and grants will be administered through the Grants Office in accordance with established University policies and procedures.

Faculty and staff members who are awarded sponsored grants and contracts for which the University serves as the fiscal agent have a vital responsibility to vigilantly manage their awards. The Grants Administration and Sponsored Programs Grants & Contracts Policies & Procedures will assist project directors to satisfy their role. Its purpose is to outline the appropriate University procedures in an effort to facilitate a smooth administration of grants and contracts and to provide further information and assistance.

4.1.3 Project Directors/Principal Investigators

Augusta State University 's project directors carry the accountability for the achievement of their sponsored award(s). In addition to their academic obligations, they are required to use good administrative judgment and decision-making behaviors in order to accomplish the purpose and ensure the success of the sponsored award. The purpose of this manual is to outline the appropriate University procedures in an effort to facilitate a smooth administration of grants and contracts and to provide further information and assistance.

4.1.4 Responsibilities of the Project Director/Principal Investigator (PI)

Acceptance of a sponsored program fund by the university commits the university and the PI to conduct the program in a professional manner and in accordance with the policies of the funding agency. It is the responsibility of each PI to insure that the research effort or program is commensurate with the expectations of the grantor and with the highest ideals of professional inquiry. Although the PI is responsible to the funding agency for conducting a particular project, the normal supervisory relationship between the university and the PI is not altered. The ultimate accountability for any sponsored project rests with the university.

The PI should remember that the support of the various administrative units of the university is available during the conduct of the sponsored activity. Explanations of procedures and support are available from the Personnel department concerning the hiring of new personnel, and from the Business Office and Purchasing concerning appropriate expenditures of all types -- from equipment purchases to required telephone service.

Throughout the entire implementation of the project, the Principal Investigator should document all activities to ensure proper reporting of all activities and expenditures as required by the sponsor.

4.1.5 Helpful suggestions for the Project Director/Principal Investigator (PI)

. Make an appointment with the Grants Office as soon as you receive the award notification in order to set up your PeopleSoft account.

. Do not incur obligations under new or renewed projects until authority to expend has been received and an appropriate account number has been assigned.

. Read the award guidelines and budget carefully to insure proper management of the award.

. Verify all charges on the grant with the Grants Office before such financial commitments are made. Common budget items and recurring expenses, such as salaries, may be verified when the account is established.

. Process all budgetary adjustments through the Grants Office to avoid audit disallowances.

. Each month monitor the grant expenses and encumbrances as a check on the remaining funds via your PeopleSoft account.

. Do not make expenditures on a terminated grant account while awaiting assignment of a new account number for a renewal grant.

. Do not incur obligations if you have any doubts as to whether they will be allowed. Always check with the Grants Office.

. Make a point to submit required periodic and final reports on time. Submit a copy to the Grants Office as well.

. The PI cannot approve additional pay, salary or travel for him/herself.

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4.2 Management Responsibilities of the Grants Office and Project Directors

4.2.1 Fiscal Management Responsibilities

The Business Office is responsible for assigning account numbers, setting up budgets and assisting in the preparation of budget amendments for any contracts/grants awarded to ASU.

The Business Office is responsible for advising appropriate university officials on matters relating to Federal and State laws, Board of Regents, and university rules, regulations, and policies pertaining to fiscal management of contracts and grants.

The Business Office is responsible for assisting Project Directors in the proper fiscal management of their awards by providing monthly budget. The Project Director is responsible for reviewing these reports each month and contacting the Business Office with any discrepancies.

The Grants Office will be responsible for issuing invoices and financial reports to the awarding agencies. The financial data is compiled and reported based upon the major budget categories of the financial statements of the University. In certain sponsored agreements, the invoicing and/or reporting requirements may exceed the level of detail provided by the major budget categories. If the agreement is accepted with these additional invoicing/reporting requirements, the responsible college/department is required to prepare and submit this data to the Grants Office on a timely basis. Any reimbursement checks received by Project Directors or departments should be forwarded to Corrina Warner in the Business Office for processing.

Any revision to proposed budgets or other correspondence with grantors regarding financial matters should be processed through the Business Office before being submitted to the granting agency.

The department or Project Director is responsible for providing records in support of cost share, matching or in-kind requirements to the Grants Office.

4.2.2 Award Notification, Post-Award Meeting and Establishing an Account

Upon receipt of grant award notification, the PI should examine the document for possible administrative errors or omissions. Next, the PI must send a copy of the award letter along with a departmental PeopleSoft contact to the Grants Office. The Grants Director is required to file the award letter with the proposal and routing forms.

All project directors, regardless of previous awards, must attend a post-award meeting with the Grants Office. This meeting will provide an opportunity to discuss any unique project requirements and to address concerns that the Project Director or the Grants Office may have. As appropriate, the Sponsored Accountant, along with the Grants Office will attend the meeting.

This meeting will be held before any account numbers are provided for the new project.

No one receiving grant funds is permitted to establish separate bank accounts or is, in any way, allowed to execute financial transactions separate from University procedures. The Grants Director will forward the award information to the Business, Budget, and PeopleSoft Offices. An account and budget will be set up according to the budget form completed by the PI. Once the account and budget have been established, the PeopleSoft Office will establish user security. Note: if you or your contact have never used PeopleSoft, you must take a PeopleSoft class in order to access your account. All departments have at least one PeopleSoft user.

4.2.3 Managing and Documenting Expenditures

The PI should consult the grant contract throughout the project concerning expenditures. All invoices, bills, receipts, and any other documentation showing expenditures should be kept. Consistent and thorough recordkeeping will document compliance with all grant guidelines. Please be sure that all expenditures are documented, allowable, and allocable. All grant and contract expenditures are subject to purchasing, budgeting, personnel and other university policies and procedures. They must be approved by the department head.

Regardless of the funding source of any grant, all expenditures must comply not only with the guidelines of the sponsor but also with existing university, Board of Regents, and state policies. Any anticipated variances with the Procedure must be discussed with the Vice President for Business Operations and formally approved.

The Federal government's Office of Management and Budget (OMB) Circular A-21 contains requirements for procedures and documentation in support of the distribution of salaries and wages (direct and indirect) under a system of Personnel Effort Reporting. The Circular provides that "All Federal agencies that sponsor research and development, training, and other work at educational institutions shall apply the provisions of the Circular in determining the costs incurred for such work."

Personnel activity reporting is a requirement of all federal and state grants. All personnel activity reporting will be supported by personnel activity reports. These reports should be turned into the Grants Office at the end of each semester, including summer semester. Each report must be signed by the employee and by the department chair. It is the responsibility of the Project Director to return the completed personnel activity form to the Grants Office no later than one month after the end of each semester.

4.2.4a Requirements

Under the Personnel Effort Reporting System, the distribution of salaries and wages will be supported by personnel effort reports as follows:

1. Personnel Effort Reports will reflect the distribution of effort expended by activity for each employee covered by the system. Such reports must reflect an after-the-fact reporting of the effort expended by the employee.

2. Each report will account for 100 percent of the effort for which the employee receives regular compensation and which is required in fulfillment of the employee's obligation to the institution.  The report shall reasonably reflect the percentage of effort applicable to each sponsored program, each indirect cost category, and each major function of the institution.

3. Each report will be signed by the employee or by a responsible official having first hand knowledge of the work performed. OMB Circular A-21 further requires that Personnel Effort Reports (PER) support cost sharing of salaries and wages on the sponsored programs. Personnel Effort Reports should document personnel effort provided in support of departmental administration activities.

4.2.4b Employees Subject to Personnel Effort Reporting

Augusta State University employees who meet the following criteria are covered by the personnel effort reporting system:

1. Employees with any portion of their salary charged directly to a sponsored program; and/or

2. Employees who have a portion of their salary charged to a major function of the University (i.e. Instruction, Research, Public Service, or Departmental Administration).

A PER will not be generated for any employee who does not meet the above criteria.  However, if that employee did, in fact, expend effort on an activity described above, then that employee should request a PER for completion from the Grants Office.

It is the responsibility of the employee (or certifying responsible official, if other than the employee) to identify and properly report effort expended.

The exceptions to the above criteria are any employees whose effort is accounted for by time sheets (i.e. student assistants, temporary employees, etc.), part time instructors, and graduate teaching assistants.  A PER will not be generated for these employees.

All Faculty, Staff and Graduate Assistants who meet the above criteria will complete a PER by semester.

4.2.4d After-the-Fact Certification Procedures

As stated in 4.2.4a1 above, OMB Circular A-21 requires that certification of effort expended be reported on an after-the-fact basis. One PER will be generated for each position in which the employee works during each reporting period. 

4.2.4e Monitoring and Review

The Grants Office will monitor the system to insure that all personnel effort reports are returned and properly reflected in the records. 

4.2.4f Departmental Administration

The Personnel Effort Reporting System will support personnel effort expended for departmental administration.  Departmental administrative effort includes, but is not limited, to the following:

1. Supervisory or managerial activities.

2. Administering personnel policies (appointments, evaluations, promotions, and review of Personnel Effort Reports).

3. Preparation and review of faculty workload assignments (including assignment of duties to sponsored agreements).

4. Preparation and review of budget documents.

5. Preparation and/or approval of purchase requisitions, travel authorizations, consultant forms, and miscellaneous payment requests.

6. Preparation and review of payroll documents.

7. Space management and assignment.

8. Property inventory and control.

9. Effort directly related to administration of contracts and grants within the department.

Salaries of department heads are, by virtue of their position, deemed to be all or in part administrative in nature. For salaries of professorial and professional staff to be included in departmental administration, it is necessary for their workload to include administrative work as described above.

Some grant programs require that federal grant funds be matched proportionately with nonfederal funds or that the grantee participate to some extent in the cost of the project. Cost Sharing/Matching is defined as all contributions, including cash and third party in-kind that meet the following criteria:

• verifiable
• not included as contribution for any other federally assisted project or program
• necessary and reasonable for accomplishment of objectives
• allowable

OMB Circular A-21 requires that all cost sharing be recorded, accounted for and documented in the same manner and to the same extent as all other costs of the grantee. Such documentation is frequently required by Federal, State, Local and Private sponsors.

All cost-shared salaries must be accounted for by Personnel Effort Reports.  The sponsored project for which the effort is being cost-shared must be indicated on the PER. 

It is emphasized that the amount of University cost sharing included in proposals and applications should be limited to the amount specifically required by the funding agency.  Documenting cost sharing will continue to be the Department Chair's responsibility.

If a grantee does not contribute a sufficient match, federal support will be reduced proportionately to maintain the required matching ratios.

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Section 5 - P Cards

5.1 Responsibility

It is the responsibility of each Project Director to verify that all procurement card charges booked to his or her grant are in compliance with the award/contract. If invalid or unauthorized purchases are booked to a grant using a procurement card, the College/Department budget will absorb the expense. If the expenses cannot be absorbed by the College/Department, i.e. expenses cannot be paid with state funds, all charges will become the responsibility of the Project Director.

5.2 PCard Deadlines

During the last 60 days of the award no procurement card charges should be booked to the grant. Any procurement card expenses that are not on ASU's ledgers by the grant end date will become the responsibility of the department the grant is housed under.

Project Directors should keep copies of any procurement card statements and receipts that are charged to their grants and send a copy to the Grants Office for the grant file.

5.3 Purchasing

Even with grants, since the funding goes through the university, we must follow our internal purchasing procedures. All grant expenditures must be posted on ASU's financial ledgers prior to the grant end date. Our procurement policy is stated as follows:

The Board of Regents of the University System of Georgia directs that each Procurement Office comply with various state, local and University System statutes, rules and regulations governing purchases with state appropriated funds. In addition, the same regulations shall apply to purchases from funds to which the University System has title. All purchasing by departments of the University will be centralized under the direct management and control of the chief business officer of the University.

The Procurement Office will work with the PI and Grants Office to make the purchasing process to be as smooth as possible. Please communicate your needs for success you're your grant as soon as the award is made.

The Purchasing Card (P-Card) is available, with appropriate approvals, to full time employees who have purchasing authority for their department. The Purchasing Card saves time by allowing the cardholder to order on line or by phone; most orders are received in one to three days. There are qualifications to receive a P-Card, so if there is someone in the department who already does the purchasing, this person should also do the purchasing for the grant. If a department receives a grant, it is recommended to have a P-Card specifically issued for that grant to the person who handles the purchasing in that department.

5.3.1 Equipment

Equipment CANNOT be purchased with a P-Card. Equipment is any item greater than $999.00. Equipment purchases must be done by requisition. Any equipment purchased by a grant must be properly inventoried. Equipment should not be purchased during the last three months of a federal grant. The auditor may disallow the cost of the equipment purchased near the end of a grant. Under ordinary circumstances, PI's should not order supplies during the last month of a grant.

5.3.2 Deadlines

1. ASU Pcard Deadlines - 30 days before the end date of the grant

2. ASU Travel Expense Statement Deadline - 30 days before the end date of the grant

3. Grant Specific Deadline(s) - You must reference the individual grant contract for grant specific deadlines set by funding agencies (i.e. narrative reporting, etc.). All fiscal reporting is done by the Business Office.

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Section 6 - Post-Award Compliance Issues

6.1 Introduction to Compliance

It is expected that Augusta State University faculty will engage in research on a continuing basis and, from time to time, may accept consulting responsibilities. In the case of consulting activities outside the university, for additional compensation or on a service basis, the following guidelines apply:

No member of the faculty or other employee in the service of the university shall devote to private purposes any portion of time due the university without the consent of the President, or his/her delegated authority. Administrative approval of such activity shall be granted only after taking into account the time required, the nature of the service, and its contribution to the professional advancement of the staff member. Any changes after a project has been initiated shall also require approval in advance.

6.2 Intellectual Property

The grant or contract between a sponsor and ASU, under which Intellectual Property is produced, may contain specific provisions with respect to disposition of rights pertaining to these materials. The sponsor (1) may specify that the materials be placed in the public domain, (2) may claim reproduction, license-free use, or other rights, or (3) may assign all rights to ASU. In those cases where income is realized by ASU, the inventor or creator may appropriately share in the income. The nature and extent of inventor or creator participation in this income, however, shall be subject to sponsor and ASU regulations. The ASU regulations are set forth in Section 3-F of the ASU Faculty Manual. Please refer to Section 545 of the ASU Faculty Manual which details the Intellectual Property Policy of the university.

6.3 Human Subject and Animal Research

Three ethical principles and six points of procedure (Belmont Report, 1978) define the philosophy and practice of research on human subjects. The three ethical principles are:

(a) respect for persons and their capabilities, including the idea that those with diminished autonomy, such as minors, are entitled to protection;

(b) beneficence, or the dedication to the fact that the investigator will not harm the research participant physically or psychologically, will minimize risk of harm, and maximize possible benefits; and

(c) justice, or the idea that all individuals should be treated equally and fairly in research investigations.

These ethical principles embody specific ethical convictions. Individuals should be considered "autonomous agents" capable of thinking clearly about their personal goals. Research participants should be dealt with openly and fairly. Research participants should be able to trust those who conduct research. Finally, justice as a strategy implies careful scrutiny of any process by which research participants are selected.

The three ethical principles are embodied in and inform the evaluation criteria established for Institutional Review Boards by the Office for Protection from Research Risk (OPRR), a division of the Department of Health and Hu­man Services for research on human subjects:

(a) risks to subjects are minimized;

(b) risks to subjects are reasonable in relation to anticipated benefits (if any) to subjects, and the impor­tance of knowledge that may reasonably be expected to result;

(c) selection of subjects is equitable;

(d) informed consent will be sought from each prospective subject or the subject's legally authorized rep­resentative and be appropriately documented;

(e) when appropriate, the research plan makes adequate provision for monitoring the data collected to ensure the safety of subjects; and

(f) when appropriate, there are adequate provisions to protect the privacy of subjects and to maintain the confidentiality of data.

6.3.1 ASU Guidelines for the Conduct and Authorization of Human Subject and Animal Research

Augusta State University encourages and supports research by its faculty and students. However, the university recognizes the need for ensuring the privacy, safety, health, and welfare of research subjects. The Oversight Committee on Human Subject and Animal Research was created to review and approve all research conducted by individuals affiliated with the university.

All individuals affiliated with ASU who intend to use its facilities and/or personnel to initiate research involving human or animal subjects are responsible for ensuring that the research is reviewed and approved by the Oversight Committee on Human Subject and Animal Research prior to the recruitment and involvement of human and/or animal subjects. Any subsequent changes in the research procedures must also be approved. Proposals seeking support from extra-university agencies must be reviewed and approved prior to submission to an agency. Any appeals of decisions made by the Oversight Committee shall first be addressed to the committee and then, if not resolved, to the VPAA. Appeals that are not resolved administratively may be processed under the grievance procedure in section 802.2 and following in the ASU Faculty Manual.

The Oversight Committee on Human Subject and Animal Research reviews research proposals and approves those meeting ethical standards as established by law, the Department of Health and Human Services, and professional organizations appropriate to the research.

6.3.2 Procedure For Submitting Research Proposals to the Oversight Committee

a. Obtain a copy of the "Application for Review of Research Involving Human or Animal Subjects" from grants office of from APPENDIX C - FORMS FOR HUMAN AND ANIMAL RESEARCH in the ASU Faculty Manual .

b. Follow the instructions on the application and answer all questions completely.

c. Before completing the application, read the criteria appended to the application which define the three cat­egories of review (i.e., Full Committee, Expedited, and Exempt) as defined by DHHS regulations and check which criteria apply to this research. The Oversight Committee on Human and Animal Research will make the final determination of the category for review.

d. Submit six (6) copies of the application to the committee chair.

e. Applications must be received at least ten working days prior to an established calendar meeting of the committee. (Calendar of committee meetings will be established annually and posted on the web page.)

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6.4 Conflict of Interest Policy: Nine-Month Faculty

A. This policy applies to all faculty with nine month contracts with Augusta State University .

B. In the event of any conflict between this policy and the policies of the Board of Regents as stated in Board of Regents Manual sections 802.14 and 802.16, the Regents Manual shall govern.

C. Outside activities, except as provided in paragraph 4, must receive advance approval from the President or his designee. Approval for continuous or repeated activity expires one calendar year after it is granted.

D. Activities that do not have to be submitted for approval are:

1. Uncompensated activities, provided they are linked to institutional service.

2. Activities that are entirely conducted while the faculty member is off duty. "Off duty" is defined as holidays, and other times that the faculty member is not required to be on duty, and periods that the faculty member is not under contract. Duty time must include sufficient time for faculty to teach, prepare classes, serve the institution, and engage in professional development, as required by the Augusta State University Role Model; provided, however, that time spent conducting outside activities that constitute professional development as defined by the Role Model shall be considered as on-duty time.

3. Public and community service, provided that the standard in paragraph 4(a) above is met.

4. Single occasion activities. A single-occasion activity is an activity that relates to the faculty member's area of expertise and does not occupy more than three working days at one time. This exception cannot be used for a total of more than five working days during the academic year. Working days refers to days that the employee is required to be on duty.

E. The burden for correctly ascertaining whether or not an activity falls within the exceptions in paragraph 4 above lies on the employee. Failure to request permission for an outside activity can result in disciplinary action.

F. A request for permission to engage in a planned or prospective outside activity must be directed to the President or his designee at least ten working days before the activity is to commence, except when the activity was not known to the applicant in time to meet this requirement. A decision shall be rendered and communicated within five working days of the receipt of the request for permission. Failure to communicate a decision within this time period will be the equivalent of the granting of permission.

G. Decisions by designees shall be reported to the office of the President for record-keeping purposes.

H. If the outside activity involves the use of University personnel or facilities (see B.O.R. 802.1602), the employee must submit a separate letter detailing this use to the President, who will refer it to the appropriate administrator for determination of costs and how the University is to be reimbursed. Use of institutional resources should not occur prior to approval by the President or designee.

I. A decision by a Presidential designee may be appealed to the President, provided that the appeal is made within five days of the designee's decision.

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Section 7 Post-Award

7.0 Grant Close-Out Requirements

Finishing a grant project is just as important as starting one. In many cases, the way in which close-out procedures are handled, such as timely submission of final reports and the quality of those reports, can have a direct impact on chances for future funding.

There are several areas of management that need particular attention at the close of the funding project: Budget, Personnel, Purchasing, Grants Files and Publications:

Budget: Make sure final budget revisions are on file; and notify the staff and other appropriate personnel that your FLD# has expired and should not be used after the grant period has ended.

Personnel: Please complete all termination paperwork for all staff. If needed, transfer all payroll changes for staff to new cost centers or to the new assigned number for the "continuation grant". If the grant has expired, it is imperative that all personnel is moved from the cost center associated with the "old" grant.

Purchasing Activities: Telephones must be transferred to other FLD#'s or removed. Bookstore charges should be checked and reconciled, and the bookstore notified that charges to the grant FLD# are no longer valid. Equipment purchases should be matched with requisitions and receipt of items confirmed.

Grant files: Please review all files for grant documentation associated with personnel records, purchase orders/requisitions and budget records. Include any necessary back up when changes occurred. Keep in mind that an auditor may contact you regarding the records associated with your grant. Your diligence in keeping and recording accurate files is essential for future funding. It is important to "clean up" all files/records once at the end of a grant cycle.

Publications: Double and triple check publication to be certain that the funding source is credited before printing is approved. Civil rights compliance statements are a requirement for all publications.

Storage: "Finally, arrange for storage of grant files. It is important to let the pertinent staff in your location know where these files are stored.

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7.1 Grant Filing System

The following is a list of file names that should be used when creating your working grant files:

Proposal

Contracts

Budget

Narrative Reports

Financial Report

Correspondence

This will help you organize your grant files and will be helpful if an audit is ever conducted internally or externally.

NOTE: Most grant records must be retained for at least 3 years after the termination date, unless audited. If an audit has been announced, the records shall be retained until the audit has been completed and all audit questions have been resolved.

7.2 Grant and Contract Record Retention Requirements

Grant and contract records are required to be kept for specific periods after completion of the project. There are different record retention requirements for different types of agreements.

For Federal grants and cooperative agreements, you should refer to Office of Management and Budget (OMB) Circular A-110, section __.53. In most cases, a three-year retention requirement from the date of submission of your final expenditure report is required. There are, however, exceptions for other types of records or litigation. Please note that the United States Department of Education has a statutory five year retention period.

For contracts, the provisions of the Federal Acquisitions Regulations (FAR) apply with varying times; six years is a good choice. Agreements with non-federal sponsors (state, foundations, etc.) may have record retention requirements which are different again.

Keeping grant and contract records for seven years from the date of project termination would seem to cover most requirements. Remember, retention should be in accordance with project not budget period. OMB rules that record retention requirements also apply to technical data.

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