UNIVERSITY of WYOMING

SPONSORED PROJECTS PROCEDURES MANUAL

CONTENTS

PREFACE

SECTION I. THE ROLE OF THE OFFICE OF THE VICE PRESIDENT FOR RESEARCH

SECTION II. PROCEDURES FOR SUBMITTING PROPOSALS

SECTION III. INDIRECT COSTS

SECTION IV. UNIVERSITY COST SHARING

SECTION V. ADMINISTRATION OF THE SPONSORED PROJECT

EXHIBITS

1. Sample Project Budget
2. Institutional Review Board for Projects Involving Human Subjects Information and Guidelines for Proposal Approval
3. Institutional Animal Care and Use Committee Protocol Approval
4. Greensheet for Approval of Contracts, Grants, Contributions and Personal Consulting
5. Personnel Activity Report
6. Report of Non-Salary Cost Contribution for Sponsored Projects
   
   

 PREFACE

This manual is intended to acquaint University of Wyoming faculty and staff with the policies and procedures related to research and other sponsored programs or activities and to inform the University community of the services and programs offered by the Office of Research. The Sponsored Projects Procedures Manual should serve as a reference for proposal preparation and project administration, as well as a guide to further information and assistance. When seeking assistance regarding sponsored projects:

inquiries about a project in the pre-award stage, from the beginning of the project concept through the execution of the award, should be directed to the Office of Research (766-5320); inquiries about a project in the post-award stage, when an award has been made or a contract or agreement fully executed, should be directed to the Office of Contracts and Grants Accounting (766-3131). The staff of either office will be able to direct any inquiry to the appropriate unit for response.

Faculty and staff who seek external funding and those who become principal investigators or project directors have an important responsibility to be aware of the applicable University policies and approval procedures, as well as the sponsoring agency's policies and requirements. This manual provides information helpful in submitting proposal documents and managing project awards, and explains the role of the various areas involved in sponsored research.

University employees wishing to propose changes or additions to this manual may do so by submitting them in writing to the Office of Research, Room 308, Old Main. Additional information and assistance may be obtained by visiting the office or by calling 766-5320 or 766-5353.

January 1992

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 SECTION I. THE ROLE OF THE OFFICE OF THE VICE PRESIDENT FOR RESEARCH

The Office of the Vice President for Research (herein referred to as the Office of Research) assists University of Wyoming employees in the development of proposals, negotiation of contracts, cooperative agreements and grant awards, and in the management of the resulting sponsored projects. The Office of Research also disseminates grant, contract, and other sponsored program information, assists in the identification of potential funding sources, maintains records of faculty/staff efforts related to sponsored projects, and seeks to encourage research and creative activities consonant with the University's goals.

Proposal Development Services

The Office of Research provides the University community with current information on funding opportunities and assures that research applications and proposals are prepared appropriately and in accordance with applicable University and sponsoring agency requirements.

The services and/or information sources described below are available in the Office of Research, Room 308, Old Main.

Sponsored project information material

Information on external funding sources of potential interest to faculty and staff is collected and maintained in the Office of Research.

Reference materials

References include books to aid in proposal development and success in grantsmanship. The Office subscribes to many research-oriented periodicals, such as Science and Government Report, and funding opportunity publications such as the ARIS Funding Report for the biomedical sciences, arts and humanities, and the social and natural sciences, Federal Grants and Contracts Weekly, The Grant Advisor, Federal Research Report, and the NIH Guide to Contracts and Grants. Program guidelines, application forms, and information on sponsoring agencies' research interests are received routinely. These materials are scanned by the Office of Research staff and are a source for the information provided to faculty members through the monthly newsletter, described below, and are available for use by any interested individual. Other references include The Foundation Directory, Source Book Profiles, and The Foundation Grants Index.

Computer data bases of funding sources

The Office of Research subscribes to two computerized networks which provide information on external funding sources: SPIN (Sponsored Programs Information Network) operated by InfoEd of New York, and IRIS (Illinois Researcher Information System) maintained by the University of Illinois at Urbana-Champaign. Both systems provide sponsor information matched to search terms selected by the researchers from the network's list. Once the key words are identified by the individual seeking support, searches are conducted electronically by Office of Research staff. A printout of the results which lists potential sponsors, contact information and a brief description of the sponsors' programs, are mailed to the requestor, usually within a week. Information on selected sponsors, deadlines, and specific types of funding, such as equipment or travel grants, may also be obtained.

Other sources

The Office of Research purchased a series of ten video tapes entitled Winning Grants. The tapes provide tips on how to prepare an effective grant proposal and shares the secrets of a successful grantsman. The tapes are available to be checked out from Audio Visual Services in the basement of Knight Hall.

Dissemination of funding source information

Information received by the Office of Research on possible funding sources is disseminated in several ways including:

Direct Mailings--individual faculty and staff who have made their interests known to the Office of Research staff may receive direct mailings of funding source information that match their research and creative activity interests.

Approval prior to proposal submission

The Office of Research is responsible for reviewing all proposals to ensure that the necessary information, certifications, and authorizations required by the potential sponsor and the University are included, and that the proposal has been approved by the appropriate University administrative officers.

Budget verification

Proposal budgets are verified to assure that they meet both the sponsor's guidelines and the University's regulations.

Other Proposal Development Services Available

Identification of potential sponsors

Contact of potential sponsors

Assistance in budget preparation

Program guidelines and application requests

Regulatory Activities

Externally mandated regulatory activities (biosafety, review of projects involving human subjects and animal care and use, radiation safety, and controlled substances use, etc.) are closely coordinated with the Office of Research and the institutional committees. The Office offers assistance to faculty and staff in the preparation of required approval forms and may serve in a supervisory capacity. Specific procedures for regulated research activities appear in Section II.

Patents and Copyrights

Authorized by UNIREG 641, Revision 2, the Vice President for Research is the cognizant University officer for patentable inventions and copyrightable works originating with the faculty and staff. The Office is responsible for the determination of the University's interest in pursuing a patent or license agreement, and will assist in the preparation of such copyright/patent applications and in the possible commercialization of patented inventions and copyrighted works.

Internal Funding Mechanisms

The Office of Research sponsors and manages various internal funding programs, including:

Research Challenge Grants

This program may provide up to $2,000 of University funding to match a minimum of $1,000 from an external source. It is aimed toward initial support of projects which show promise for additional future support from external sources. Proposals may be submitted at any time.

Major Equipment Fund

This fund provides support for the purchase of equipment for research and creative activities which are beyond the capacity of the department and college budgets. The program requires a match of at least 50 percent from an outside source. A competition is usually opened once annually.

Biomedical Research Support Grants

The BRSG program provides support for start-up programs or for the purchase of small equipment for projects of types which are regularly funded by the National Institutes of Health. A competition is usually opened once per year.

Faculty Grants-in-Aid

Competition for this program is usually opened once annually and will provide successful proposals with support for faculty research projects and creative activities.

Revolving Lease Account

The fund was developed to provide support in the form of leases for the purchase of equipment for research and creative activities which are beyond the capacity of department and college budgets. Funds for approved purchases may be made available and lease payments are made from grants/contracts which have a duration greater than one year. Proposals may be submitted at any time.

Other Programs of the Office of Research

Affiliated Fellows

Public Participation Program

Student Invention Program

Interdisciplinary Speakers Series

President's Speakers Series

Burlington Northern and President's Faculty Award

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 SECTION II. PROCEDURES FOR SUBMITTING A PROPOSAL

This section is designed to facilitate the submission of proposals and inform investigators and project directors about University policies and procedures which govern these activities. The proposal is a formal document which describes and justifies the work to be done, details project costs, and requests funds to conduct the proposed activity. The proposal is submitted to a potential sponsoring agency by the University on behalf of the principal investigator desiring support.

Preliminary Proposals

A preliminary proposal may serve as a guide for discussion of a proposed project between the principal investigator and potential sponsor. A preliminary proposal should include the following elements:

• a statement of work
• the proposed methodology
• the significance of the proposed project
• the information and conclusions anticipated
• a project work schedule
• vitae of project personnel
• an estimated (non-detailed) lump sum budget

Although preliminary proposals may contain a request for funds, they are informal and do not require approval through the "greensheet" process (described in Section II. Internal Approval of Proposals). Any preliminary discussion and preliminary proposals should explicitly inform the potential sponsor that the University is not committed by preliminary agreements between the principal investigator and the sponsor. Research agreements are not binding on the University unless they are approved and signed through the formal "greensheet" process.

Preliminary Proposal Development with University Administration

Although the preliminary proposal budget is only an estimate, it frequently becomes the financial limit of the formal proposal. For this reason, the department head, dean, and the Office of Research should be involved in estimating the project costs so that they will be as realistic as possible. Principal investigators should discuss any aspect of a proposed project (space, personnel, equipment, relationship to teaching, etc.) that might affect departmental administration with their respective department head and dean.

Preliminary proposals which involve large projects, inter-departmental or inter-university cooperation, activities in a foreign country, or other unusual aspects, should be brought to the attention of all appropriate personnel so that potential problems can be discussed and dealt with early in the proposal process.

Submission of Formal Proposals

Any formal proposal or application to a source outside the University for financial support of programs to be conducted under the auspices of the University must be submitted and approved through the appropriate University channels as specified on the "greensheet." This approval process in described in Section II, Internal Approval of Proposals. Successful proposals result in what is termed an "institutional" award and/or contract. Typical proposals or applications are for research projects, training programs, educational service agreements, cooperative agreements, institutes or conferences, or a creative activity.

Preparation of the Proposed Budget

The proposed budget should include both the anticipated direct and indirect costs associated with conducting the proposed project. It should be noted that money for possible salary increases and other inflationary increases should be included in the original budget. (See Exhibit A for a sample budget format; most major federal funding agencies provide forms or may require that the budget be prepared in a specific format.)

Direct Costs

Direct costs are those costs which can be identified and charged directly to a project or sponsored activity.

Following is a checklist of possible direct costs for a project. Any given project budget may include only some of these items, depending on the proposed activities and resources available to the proposer.

Salaries and Wages (UW employees only), e.g.:

• Principal investigator
• Other faculty
• Research Associates
• Technicians
• Secretarial-clerical
• Graduate Assistants
• Hourly personnel

The Personnel Services office has prepared a handout,"How to Fill Grant Funded Positions" to assist with salary and classification information. The handout is available from either the Office of Personnel Services or the Office of Research. The University of Wyoming is an Equal Opportunity/Affirmative Action Employer.

Fringe Benefits include the employer's contribution to Social Security, Wyoming Retirement System, Workers' Compensation and Health and Life Insurance. Fringe benefits are calculated as a percent of all salaries and wages except for those of full-time students formally enrolled in school.

Currently, fringe benefits are estimated at 24 percent of non-student salaries. It should be noted that this is an estimate and fringe benefits are charged to contract and grant accounts at the actual cost. Projects involving personnel whose rate of pay is less than $36,000 per year may need as much as 28 percent to cover the fringe benefits related to those employee's salaries. Proposers should contact the Office of Research to verify the current rate to estimate fringe benefit costs.

Equipment (Equipment purchases are subject to policies outlined in the Purchasing Manual available in departmental offices or from the Purchasing Office.)

Expendable Materials and Supplies, e.g.:

• Office supplies
• Duplicating materials
• Laboratory supplies
• Glassware
• Chemicals
• Electronic supplies
• Photocopying

Travel, e.g.:

• In-state and out-of-state lodging and meal expenses (For current allowable travel expenditures
• and rates, check with Accounts Payable at 766-5596/766-5576)
• Professional meetings
• Field work and data collection
• Automobile rental
• Air fare
• Vehicle mileage

Contracted services, e.g.:

• Subcontracts
• Consultants
• Leases
• Machine shop charges
• Glass shop charges
• Service contracts

Communications, e.g.:

• Telephone
• Postage

Other direct costs, e.g.:

• Publication costs
• Photographic services

Indirect Costs

Indirect costs are calculated at an approved percentage of the modified total direct costs (MTDC) which excludes items of equipment which cost over $500 per item and subcontracts in excess of $25,000. The current approved indirect cost rate for the period July 1, 1991 through June 30, 1992 for research is 40 percent. The approved indirect cost rate in effect for the period July 1, 1992 through June 30, 1995 will be 41 percent. Proposed budgets should include indirect costs calculated at the appropriate rate for the proposed project period. Section III. contains additional information on indirect costs and specific details on other indirect cost rates.

Certifications and Representations

Many grant applications and requests for proposals (RFP's) contain certifications and representations which must be completed and signed by an authorized University representative. Often these certifications and representations request information not readily known to the proposer. This information may be obtained from the Office of Research or if the proposal includes forms which require completion, these forms should be brought to the attention of the Office of Research staff when the proposal is submitted for approval. The Office of Research will complete the forms if desired. Additional information on selected certifications and representations is provided later in this section.

Federal Regulations Requiring Committee Review of Proposals

Federal regulations and guidelines require institutional committee review and approval of proposals which involve the use of human subjects, animals, drugs or other controlled substances, and radiological materials. This review and approval is mandatory prior to submission of the proposal to the potential sponsoring agency. The role of these review committees is simply to evaluate the projects to assure that they comply with regulations established by the Federal government which exist to protect not only the human and animal subjects, but to protect the researcher and the University as well. This review in no way attempts to examine the scientific merit of proposals. Non-compliance with these requirements puts the University's Federal funding at risk.

Institutional Review Board for Projects Involving Human Subjects (IRB)

The U.S. Department of Health and Human Services (HHS) has established mandatory, comprehensive, agency-wide requirements for the use of human subjects in any activity which involves interaction or intervention with human subjects, or where there may be risk or invasion of privacy, regardless of the source of funding. The University of Wyoming Institutional Review Board for Projects Involving Human Subjects (IRB) is comprised of the Associate Vice President for Research who serves as the chairman, UW faculty who represent the disciplines that most often use human subjects, and non-affiliated members of the community. The University staff attorney provides interpretation of the regulations and serves in an advisory capacity to the Board. The Board is charged to oversee research activities at UW to assure compliance with these regulations.

All activities which involve the use of human subjects, regardless of funding source, require review by the IRB. Researchers are asked to submit proposals for IRB review to the Office of Research at least one month in advance of the proposed initiation of the research activities. The necessary elements of a proposal to the IRB are listed in Exhibit B, Information and Guidelines for Proposal Approval.

IRB Proposal Approval Categories. The Code of Federal Regulations, Title 45 CFR Part 46.101 enumerates six categories of research that may be exempt from IRB review. Part 46.110 lists activities which may qualify the proposal for an expedited review and approval procedure. All proposals which do not meet the specific requirements for these two categories require review by the full Board. These determinations will be made by the chairman of the IRB in consultation with the UW staff attorney. Principal investigators will be notified by letter of the status of their proposal.

Assurance of compliance. The University does not have an approved assurance on file with HHS but instead certifies that it will comply with the applicable federal regulations regarding the use of human subjects for individual projects. Some agencies require this assurance to be signed by an authorized university representative or require certification that a project has been reviewed and approved by the IRB. Sponsoring agencies' requirements may differ with regard to required approval prior to submission or if pending approval is acceptable. Proposers should check the potential sponsor's proposal submission guidelines.

Institutional Animal Care and Use Committee (IACUC)

The use of animals in research is also guided by federal regulation. Cognizant federal agencies are the Public Health Service (PHS) and the U.S. Department of Agriculture (USDA). These regulations apply to the use of all vertebrate animals and include laboratory animals, such as rats and rabbits, farm animals, and wild animals, regardless of the project sponsor or project activity. The use of animals for instructional purposes requires the same approval procedure. Principal investigators who propose to use animals must submit an Animal Care and Use Committee Protocol Approval Form (Exhibit C) and attachments with additional information or a copy of the project proposal to the Office of Research. Proposals are reviewed and approved by the IACUC attending veterinarian, the chairman of the IACUC and the Associate Vice President for Research. Proposals are circulated to the IACUC for review and concurrence. Principal investigators will receive a copy of the IACUC protocol after approval.

Assurance of compliance. The University has an assurance on file with the Public Health Service Office for Protection from Research Risks. The assurance number is A-3216-01. The University is not certified by the AAALAC. An approved copy of the IACUC Protocol Approval form should satisfy the certification requirements of most sponsoring agencies, however some agencies' requirements for certification of IACUC approval may differ. Principal investigators should consult the agency's program guidelines.

Drugs or Other Controlled Substances

The University is required to conform with licensing procedures established by the Department of Justice, other Federal agencies and the State of Wyoming to ensure the proper handling of controlled substances under the jurisdiction of the University and its personnel. If a project involves the use of controlled substances, a narrative of how the substance is to be used, and the qualifications of the user(s) must be submitted to the Controlled Substances Use Committee. Clearance from this committee must be obtained before the proposal is submitted. The request should be addressed to the Chemical Safety Officer in the Safety Office, Room 312, Merica Hall.

Recombinant DNA Research (Biosafety Subcommittee of the IRB)

Guidelines and Federal Regulations are available in the Safety Office. The Biosafety Committee functions as a subcommittee of the IRB, through which all projects must be reviewed. A Registration Document must be filed with the Biological Safety Officer in the Safety Office before any recombinant DNA research project activities can begin.

Radiation Safety Committee

This committee must approve proposals for research

which requires new radiation sources, or the use of radio-isotopes by personnel not previously approved for handling such sources and materials. The request should be submitted to the Radiation Safety Officer in the Safety Office for submission to the Committee.

Internal Approval of Proposals

Before a formal proposal may be submitted to an outside sponsoring agency it must be approved by the appropriate administrative officers of the University. Approval may be obtained by completing a Greensheet for Approval of Contracts, Grants, Contributions and Personal Consulting (Exhibit D), and obtaining the appropriate signatures. Greensheets are usually available in the departmental administrative office or may be obtained from the Office of Research. Care should be taken when completing the greensheet to assure that the information is complete and accurate. When an award is made, information is taken from the greensheet to report the award to the Board of Trustees, the University community, the public, and in the Annual Summary of External Awards prepared by the Office of Research. Credit for the project and the indirect cost allocations (described in Section III.) are given to the departments/colleges listed on the greensheet. Additional instructions for completing the greensheet for approval of proposals are on the back of the form.

Approval signatures of the principal investigator/project director, department/unit head, and college dean must appear on the greensheet and are to be obtained by the principal investigator, prior to the submission of the greensheet and proposal to the Office of Research.

The department head or unit director and the dean will evaluate the academic soundness and propriety of the project and determine whether the departmental budget and facilities will accommodate the proposed project, as well as determine if the proposed project fits within the academic framework and resources of that college.

After the above signatures are obtained by the principal investigator, the completed greensheet, the original proposal which may require the signature of an authorized university representative, and one copy of the proposal (which will be retained by the Office of Research) should be delivered to the Office of Research. The greensheet and proposal will be routed by the Office of Research for the remaining signatures.

Vice President for Research: The proposed project and budget will be reviewed for completeness and for conformance to University and agency policy, and any University commitments.

Vice President for Finance: makes a final check for conformance with fiscal policy and signs the proposal application and accompanying certifications as the authorized university representative.

Vice President for Academic Affairs: makes a final check for general academic suitability and conformance to University policy.

Time line for approvals. PLEASE ALLOW ONE WEEK FOR PROCESSING. Every effort will be made to obtain approval and return the signed original proposal to the principal investigator/project director for submission to the sponsoring agency in a timely manner. Approval may be obtained in less time, but in some instances may require extensive processing or an opinion of legal counsel. Please allow sufficient time to guarantee that a submission will meet an agency's deadline for consideration.

Authorized signatures. Sponsoring agencies use different terms for signatures required or other responsible officials. Some of those terms and the corresponding University position are as follows:

PLEASE NOTE: The President and the Vice President for Administration and Finance are the only signatories authorized to bind the University in any contractual arrangement or agreement. In the absence of the President, the designated Acting President may sign on behalf of the President.

Mailing of Proposals

After all required signatures are obtained, the original proposal will be returned to the principal investigator for mailing to the agency. The greensheet and one copy of the proposal will be retained in the Office of Research.

Amendments to Proposals

If an investigator wishes or is requested to amend a proposal which has been submitted to an agency and the amendment entails any change in the budget, personnel, or facilities requirements, or any substantial change in the research program, the amendment must be formally submitted following the same procedure required for the original proposal; that is, the revision must be "greensheeted."

Negotiation of Proposals with Sponsors

Negotiations between the University of Wyoming and the sponsor which involves budget items will be handled by the Associate Vice President for Research in consultation with the appropriate legal counsel, the principal investigator/project director and/or other university officers. Proposers should refer contacts of this nature from potential sponsors to the Office of Research.

Proposals to Corporations and Foundations

Unlike federal funding agencies, private foundations and corporations do not encourage nor tolerate a system of open proposal submission and review. Rather, they expect proposals to support an institution's top priorities which have been established by the institution's president and academic officers. Proposals to corporations and foundations should be discussed first with the Director of Development. If the proposal is determined to be consistent with University and agency priorities, the proposal should be submitted through the greensheet process for appropriate approval. The proposal will be forwarded to the President for review and sent with a cover letter from the President to the funding agency.

This prior review procedure has been established to increase support for faculty and avoid time wasted on proposals with little chance of success. The review procedure applies to corporate and foundation proposals for projects which would not routinely be considered research projects. Questions as to what is or is not considered research should be directed to the Vice President or Associate Vice President for Research.

Patent Provisions

If patent or copyright matters are involved in a proposal or an award, activities must comply with the University of Wyoming Patent/Copyright UNIREG 641, Revision 2. This Unireg was designed to protect the rights of the University and the faculty/staff in patent/copyright matters. Questions with regard to patents or copyrights should be addressed to the Office of Research. The Vice President for Research has the responsibility for negotiation of license agreements which are a result of research performed at the University of Wyoming.

The University has an agreement with Research Corporation Technologies which, if deemed appropriate, allows RCT to review disclosures of research results which might be patentable or have potential for commercialization. An investigator should contact the Office of Research to obtain additional information about the program and to obtain the disclosure forms.

Assurances; Representations and Certifications

The required compliance reports have been submitted by the University to the Department of Health and Human Services and the dates indicated should be shown on proposals which may require such information. Questions regarding compliance with these regulations should be directed to the Employment Practices Office (6721).

Civil Rights: Form HHS 441 regarding Title VI of the Civil Rights Act of 1964 submitted January 15, 1965

Title IX: Form HHS 639 regarding Title IX of the Education Amendments of 1972 (Sexual Discrimination) submitted September 30, 1976

Rehabilitation Act: Form HHS 641 regarding the Rehabilitation Act of 1973 (Handicapped Persons) submitted September 14, 1977

Age Discrimination: Form 680 regarding the Age Discrimination Act of 1975

The University is also required to certify, before a federal grant can be awarded, to the following:

Non-delinquency on federal debt (that the institution is not delinquent on the repayment of any federal debt)

Debarment and Suspension (that neither the institution nor its principals are debarred, suspended, proposed to be debarred or declared ineligible or excluded from covered transactions by any federal agency)

Drug-Free Work Place (that the institution will provide a drug-free work place)

Misconduct in Science (that an administrative review process has been established according to the requirements of the scientific misconduct regulations)

Lobbying (that the institution has not and will not use federal funds to lobby an agency or member of congress to influence an award or federal contract; and that if funds other than federal funds are used for that purpose that the institution will submit a "Disclosure of Lobbying Activities" to the federal agency) A granting agency may also require additional certifications and assurances. If information is needed on any additional representations or certifications, please contact the Office of Research.

Other Required Documentation

Granting agencies may request other institutional information or documentation, such as a copy of the negotiated approved indirect cost rate agreement, the University's annual financial report, tax exempt statement, or Statutes of Incorporation. These documents will be provided by the Office of Research upon request.

Consulting

The Regulations of the Trustees of the University of Wyoming, Chapter VII., Section 3, Part b., addresses the conditions under which a full-time employee during the regular term of service may receive supplementary compensation from University funds, state agency sources, and other outside sources. The regulations also state that the facilities of the university may not be used for outside work without the approval of the Vice President for Administration and Finance. Copies of the Trustee regulations should be available in all administrative offices and are available in the Office of Research.

Approval to perform professional and consulting work for supplementary compensation for an outside agency is obtained via the Greensheet for Approval of Contracts, Grants, Contributions, and Personal Consulting form. Approved greensheets for consulting activities are retained by the appropriate dean's office.

Notification of Award

The notification of award is sent from the sponsoring agency to the University, usually to the President, Vice President for Administration and Finance, or the Office of Research. Principal investigators/project directors may also receive a copy of the award notification. When an award is received, the Office of Research coordinates with Contracts and Grants Accounting to establish an account number for the project. The principal investigator/project director, department head, and dean are notified when an account is established. The approved greensheet, proposal, and other executed documents pertaining to the award are forwarded to Contracts and Grants Accounting and become part of the permanent project file. Contracts and Grants Accounting will provide any other project management assistance requested. Contracts and Grants Accounting's responsibilities for project management and administration are outlined in Section V.

If notification is received from the sponsor by the proposer that an award has been made and it appears that the University administration has not been notified, the principal investigator should contact the Office of Research.

Awards that involve a formal contract require review by the University's legal counsel for compliance with University regulation and State law before it can be accepted by the University. The Office of Research will route these documents as appropriate.

Rejected Proposals

The University and/or the principal investigator may receive notification from a sponsoring agency that an award will not be made or that a proposal has been declined. The Office of Research will return the greensheet and the proposal to the principal investigator when such notification is received. If the proposal is revised and/or resubmitted to the same or a different agency, that proposal must be resubmitted through the greensheet process for approval.

If such notification is received by the principal investigator and it is not apparent that the University administration has been advised of the action, the principal investigator should contact the Office of Research.

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 SECTION III. INDIRECT COSTS

A budget component for sponsored projects that generates much discussion, controversy, and misunderstanding is indirect costs. What indirect costs are, how the indirect cost rate is determined, how the rate is established for each project, and what is done with the indirect cost monies recovered by the University are explained in this section.

What are Indirect Costs?

Indirect costs are those costs that have been incurred which cannot be directly related to a specific project, but are incurred by the University as a consequence of the project. At educational institutions such costs are classified under functional categories provided by Federal guidelines: general administration, sponsored project administration, departmental administration, operation and maintenance, library, student services, and equipment and building use allowance. Facilities, electricity, research administration, and accounting support for research projects are typical examples of indirect costs. In addition, that portion of a department head's, dean's, vice president's, or the President's time spent on administrative activities related to research and other sponsored programs or activities, are viewed by the Federal government as indirect costs of engaging in these programs.

Indirect costs are not recovered from sponsoring agencies until after the costs have been incurred. Under Federal guidelines, the reimbursement replaces dollars that have already been spent--they do not represent new dollars that can be spent for any purpose. It should be noted that indirect costs do not represent profit. The University can recover indirect costs only at the rate which is audited and approved by the Federal auditors. That rate is recognized by Federal agencies and by the University as the legal basis upon which the University can make claims for reimbursement. When the rate is negotiated with Federal auditors, it becomes the only bona fide basis for claiming indirect cost reimbursement.

How the Indirect Cost Rate is Determined

The University of Wyoming is required by the Federal Government to develop an indirect cost rate proposal for each year. The rate is based on an analysis of indirect costs associated with the sponsored program activity for the prior year developed by the cost analyst under the Office of the Vice President for Administration and Finance. This proposal is submitted to the U.S. Department of Health and Human Services, the University's cognizant federal audit agency. Once an indirect cost rate is negotiated that rate agreement is recognized by all federal agencies as the established rate by which indirect costs may be recovered.

The indirect cost rate for research negotiated with HHS for the period July 1, 1991 through June 30, 1992 is 40 percent. The negotiated rate for the period July 1, 1992 through June 30, 1995 is 41 percent. Copies of the University's rate agreement is available in the Office of Research.

The elements of the approved indirect cost rates for these periods and their relationship to the total indirect cost rate for on campus organized research are as follows:

The government distinguishes between the kinds of activities and the location in which the activities are performed; corresponding rates are negotiated. The types of rates and a definition of each rate follows. Questions regarding which rate to use should be directed to the Office of Research.

On-Campus Organized Research --FY 92 = 40%; FY93-95 = 41%

This rate applies to the majority of sponsored projects and is used for research projects conducted on the campus or when the campus serves as the primary base of operations even though the work itself may be performed at a site away from the campus. The University of Wyoming campus proper, the facilities at the Laramie Airport, Elk Mountain Research Facility, Science Camp, and the Jelm Mountain Infrared Observatory are all considered on-campus units. The rate is applied to all direct costs including the first $25,000 of any subcontract and equipment items which cost less than $500. Excluded from indirect cost assessment are items of equipment costing $500 or more each, and the subcontract amount which is greater than $25,000. This rate also applies to projects sponsored by non-Wyoming corporations.

Off-Campus Organized Research -- FY92 = 23%; FY93-95 = 23%

This rate is used when, as a result of a research project, personnel conduct the activities at an off-campus site not owned by the University and located at least 100 miles from Laramie for a period longer than an academic session (i.e., a semester or a summer session). The rate applies to all direct costs except items of equipment costing $500 or more each. A project budget may include the use of both the on-campus and the off-campus organized research rate. The appropriate use of the off-campus organized research rate should be verified with the Office of Research prior to the proposal budget preparation.

Instructional Agreements:

(on-campus) --FY92 = 50%; FY93-95 = 50%; (off-campus) FY92 = 23% FY93-95 = 23%

An instructional agreement is any sponsored project which will provide training or other educational services. Typical projects include special training programs, summer institutes, and similar instruction-oriented projects. The rate applies to all direct costs except items of equipment costing $500 or more each.

Other Sponsored Projects:

(on-campus) FY92 = 30% FY93-95 = 30%; (off-campus) FY92 = 23% FY93-95 = 23%

This rate is used when the sponsored project involves activities that are not related to research or instruction. Examples of these types of activities are Intergovernmental Personnel Agreements, traineeships, and surveys.

Wyoming State Agencies and Wyoming Companies FY92-95 = 20%

This rate is used for all sponsored projects for research, instructional, or other sponsored activities for any State of Wyoming agency or company or corporation whose home offices are in the State of Wyoming. The 20 percent indirect cost rate is applied to all direct costs.

How Indirect Costs are Established for Each Project

When a proposal for a sponsored project is "greensheeted" and submitted for approval, the proposed budget must include the appropriate audited indirect cost rate as defined in this section. Exceptions to this policy must be approved by the Vice President for Research prior to submission of the proposal to the potential sponsor.

Some federal assistance programs have statutory requirements that limit indirect costs to a percentage of the total direct costs which may be lower than the negotiated rate for MTDC. Such limitations are specified in program guidelines and may be approved by the University only when so specified.

When proposals are contemplated for submission to sponsors that do not pay indirect costs or pay only a portion of the audited rate, the Office of Research should be involved in the proposal budget preparation so that a workable agreement acceptable to all parties can be established. Principal investigators are not authorized to negotiate indirect cost rates with potential sponsors that differ from those officially established.

Distribution of Indirect Costs Recovered by the University

The University's budget requests to the State Legislature by necessity incorporates in its income sections estimates of the indirect cost reimbursement for each biennium. The bulk of the indirect cost recovered is returned to the University to support the general operating budget.

However, a portion of the reimbursement funds is allocated to the generating departments under a Trustee policy whereby the funds are to be used to relieve impact of the sponsored project program on the department/unit and applicable college and to stimulate its further growth. Of the actual amount collected on a fiscal year basis, 75 percent funds general University expenses, five percent is distributed to the Office of Research, 15 percent to the Department, and five percent to the College. The college and department distribution is determined by the information provided on the greensheet for individual projects, and is based on actual indirect costs recovered for that fiscal year.

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 SECTION IV. UNIVERSITY COST SHARING

Cost sharing, cost contributions, and matching are all terms used to refer to that portion of a project's total cost which is to be furnished by the University. These funds plus those funds awarded by the sponsoring agency comprise the total project budget. Cost sharing requirements may be mandated by state or federal legislation or may be an inherent requirement of the sponsor's program, and must be shown on the proposed project budget. Where cost sharing is required by a federally sponsored program, the contribution MUST COME FROM NON-FEDERAL SOURCES.

Sources of non-federal cost sharing may include:

• Time of personnel who are supported by state funds but work on a sponsored project, including salary, related fringe benefits, and indirect costs. This time must be documented by the Personnel Activity Report (PAR) which must be filed within 10 days following the end of the month in which the contribution took place. Donated time from non-University personnel is allowable, however this time and the value of it must be documented by the volunteer. (Additional information on PARs is included in Section V.)
• State budgeted funds expended on supplies, equipment, or other services which are used to directly benefit the sponsored project. These expenditures must be documented on the Report of Non-Salary Cost Contribution for Sponsored Projects. (Additional information on cost share documentation is included in Section V.)
• Related non-federal funds in other divisions of the University, i.e., development funds, gifts, etc.

Cost sharing requirements vary widely among the federal agencies and other possible sources of support. The agency's program guidelines or application procedures will usually detail any such requirement and should be consulted when preparing a proposal budget. Specific agency requirements may be available in the Office of Research or the staff will obtain this information.

University contributions used to satisfy a cost sharing requirement must be documented by the University and are subject to audit. Every effort should be made to maintain the contributions at the lowest level possible. Questions concerning cost sharing and whether or not it is required should be directed to the Office of Research. See Exhibit A for an example of how to include cost sharing in the proposal budget.

When a specific level of effort or dollar amount is included as cost share in the budget of a proposal which is subsequently awarded, that cost sharing of direct costs must be accounted for and auditable documentation must be contained in the University's accounting records. If cost sharing is not required by the sponsoring agency, but the proposer wishes to show cost share to strengthen the proposal, a general statement in the budget narrative which does not quantify the cost share may be more desirable from the record keeping aspect. If cost share is included in the proposed budget and listed as such on the greensheet, appropriate documentation will be required on all awards.

Discussion of the University's contribution to a proposed project with the proposer's department head, dean, and the Vice President for Research should be initiated early in the concept stage of the proposal if the University's contribution to the project exceeds the resources available to the proposer. A commitment of funds to be used for cost share must be determined prior to the submission of the proposal and the source of the cost share funds must be identified on the greensheet. Appropriate letters of commitment should accompany the proposal.

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 SECTION V. ADMINISTRATION OF THE SPONSORED PROJECT

When notification of award for a sponsored project is received by the University, certain administrative and reporting requirements become the responsibility of the University and the principal investigator/project director. This section will familiarize principal investigators, department secretaries, and bookkeepers with some of the most important of these responsibilities. Each sponsor has regulations which must be followed and state and university regulations for expenditure of funds must also be followed. It is essential that the principal investigator read and adhere to the terms and conditions of their project award.

Establishing an Account

Sponsored projects will be assigned an account number upon written notification of an award from the sponsoring agency. No obligations or expenditures will be allowed on a project until such notification is received by the Office of Research and an account number for the project is assigned by Contracts and Grants Accounting. Greensheets, proposals, contracts, agreements, and all documentation related to an award is forwarded to the Contracts and Grants Accounting and becomes a part of the project file. Contracts and Grants Accounting notifies the principal investigator/project director, the department head, and the dean of the project account number and other pertinent project information.

From this point on, Contracts and Grants Accounting, with the assistance of the principal investigator and the responsible bookkeeper, will conduct and oversee all of the accounting functions for the sponsored project. Principal investigators should contact Contracts and Grants Accounting (766-3131) for assistance with administrative and financial problems that may arise during the grant period. Policy questions should be referred to the Office of Research (766-5320).

Policy for Establishing an Account Prior to Official Notification of Award

When verbal approval has been received from the funding agency, for either new awards or continuation awards, an account number will be assigned only upon written authorization from the principal investigator. The request for an account must be co-signed by the department head. Any expenditures made against an account which is set up at the request of a principal investigator and department head prior to the official written notification becomes the responsibility of the department, and all funds spent on that account will have to be reimbursed by the department if an official authorized award is not made by the sponsoring agency.

If obligations or expenditures are disallowed by the sponsor because they were incurred prior to or after the official award period, they will become obligations against departmental funds.

Monitoring the Financial Status of Sponsored Projects

Each month a statement of account which documents the preceding month's financial activity is sent to the department. This report includes information about expenditures processed through accounts payable, salaries processed by Payroll, and future commitments against the project for salaries, indirect costs, and other purchases. A commitment is the official recognition of an encumbrance of funds where the payment will be made at a future date. An expenditure is the payment of a commitment, whether it has been recorded as a commitment or not. It is essential that the principal investigator closely monitor these reports to determine if the charges to the project are legitimate and to avoid overexpenditure of available funds.

Contracts and Grants Accounting invoices sponsors for reimbursement of project expenses according to the agency's requirements. Contracts and Grants Accounting is responsible for depositing funds into sponsored project accounts.

Overexpenditure of Project Funds

When project funds are overspent, alternative funding must be provided by the department responsible for the sponsored project. Principal investigators/project directors are responsible for ensuring that expenditures relate to the project and stay within the budget.

Cost Corrections

Recent federal audit reports have cited instances where grantees have transferred costs from one project to another many months after the original charges were recorded and in many cases without adequate supporting documentation to explain why the corrections were made. To alleviate this problem and avoid a cost disallowance, policies regarding cost corrections have been issued by the government and the University.

When closely related work is supported by more than one funding source, a cost correction from one project to another may be made if:

• The cost is a proper and allowable cost to the grant being charged.
• The transfer is supported by documentation which contains a full explanation and justification for the correction and a certification of the propriety of the correction by the principal investigator.
• The correction is requested within 30 days following the statement of account which showed the original charge.
• The correction is reviewed and approved by Contracts and Grants Accounting.

Cost Disallowances

When Federal requirements or contractual agreements are not followed, the result may be a disallowance of expenditure. A disallowance will require repayment by the University to the sponsor for previously billed costs. Costs disallowed by the auditors, which are a result of expenditures under the control of the principal investigator and result in reimbursement to the sponsoring agency, will be deducted from the indirect cost funds which are allocated to the department.

Personnel Activity Reports

Under Federal regulation, salary charges against a sponsored project require certification that the person actually worked on that project, and a demonstrable relationship between the indicated time or responsibility and the actual salary charge must be shown. The monthly Personnel Activity Report (PAR) (Exhibit E) must be prepared by each employee whose salary is charged to a sponsored project and approved by the principal investigator and/or department head. This report, maintained in the Payroll Office, serves as the necessary audit documentation to support the salary charges to a sponsored project. Additional information on the PAR system may be obtained from the Payroll Office, (766-6144 or 2217).

The PAR is also used to document the cost sharing of a principal investigator/project director or other appropriate employee's time spent on the sponsored project. Assistance in preparing the PAR to document cost share may be obtained from Contracts and Grants Accounting.

Purchasing

All purchases related to and charged to the sponsored project must be made according to established University purchasing policies which can be obtained by contacting the Purchasing Office (766-5233).

Travel

All travel related to and charged to the sponsored project is subject to the statutes of the State of Wyoming and related State and University rules and regulations. Information and copies of these regulations can be obtained from Accounts Payable (766-5296/5776). It should be noted that Federal agencies require that any foreign travel have prior approval from the granting agency. U.S.-flag air carriers are required for foreign travel and any exceptions must meet sponsors' conditions. Any change to travel funds approved in the award need to be discussed with Contract and Grants Accounting (766-3131).

Equipment Purchases

Under State of Wyoming regulation any item costing $150 or more and having a useful life of two years or more is classified as equipment. Federal regulation uses $500 as the basis for equipment purchase classification. This discrepancy is taken into account when Contracts and Grants Accounting bills Federal agencies; the billing will reflect only those items which cost $500 or more as equipment. Records of equipment purchases are maintained by the Property Office and identifies the title holder as either the sponsoring agency or the University. Written approval from the granting agency is generally required for purchase of equipment other than those items approved in the original proposal budget. Equipment which costs over $500 on any Department of Defense project requires approval from the Office of Naval Research, which has administrative authority over all Department of Defense projects. Please check with Contracts and Grants Accounting (766-3131) before making such purchases.

Cost Share Documentation

If cost share is included in the project budget, appropriate documentation is required. The PAR (discussed above) is use to document an employee's time spent on the sponsored project. Non-salary cost contributions must be documented on the Report of Non-Salary Cost Contribution for Sponsored Projects form (Exhibit F) and submitted to Contracts and Grants at the end of the budget period.

Consultants Paid on Sponsored Projects

Federal regulations require that payments for consultants on federally sponsored projects list the days the consultant worked, the daily or hourly rate paid, the consultant's social security number, and a justification for choosing the consultant. Reimbursement of any expenses to the consultant must be itemized. The maximum daily rate currently allowed by the federal government for consulting is $373.

General Statements of Allowable Costs on Sponsored Projects

The beginning and ending dates of the budget period set the parameters for expenditures on the project. Obligations must occur within the project award period. Expenditures and commitments made prior to the award date are not allowed nor are those made after the project expiration date, unless payment is for allowable costs incurred during the project period, such as telephone, copier billing, etc. It should be noted that any substantial purchase made just before the close of the budget period (particularly when no continuation is contemplated) may be disallowed by the auditors if it appears that the purchase could not contribute to the objective of the award in the designated period.

Remaining funds left from one project period generally cannot be carried over to another project period and expended without prior written approval from the sponsor. Any requests for carry-over of funds or no-cost extensions must be requested prior to the end of the project period and the letters of request to the sponsoring agency must be co-signed by the Associate Vice President for Research.

Entertainment expenses cannot be charged to project funds unless specifically authorized by the sponsoring agency.

Purchase of general purpose office equipment (chairs, typewriters, calculators, desks, etc.) are not allowable expenditures without specific written approval from the sponsor.

Subcontracts

All subcontracts issued under a sponsored project awarded to the University must be approved by the sponsoring agency. The formal subcontract document is initiated by the Office of Research at the direction of the principal investigator and must be approved by a University staff attorney prior to submission to the subcontractor for execution.

Faculty or staff at the University of Wyoming performing as subcontractors for another entity must submit the proposal and greensheet for approval prior to accepting a subcontract. The budget should detail the University's portion of the total project.

Reporting to the Sponsor

The main product of most University research is a written report or series of reports. Principal investigators should give their best efforts to the preparation and timely submission of required reports. It is the principal investigator/project director's responsibility to be aware of and adhere to the sponsor's reporting requirements. Copies of progress and final reports submitted to the sponsor by the principal investigator should be forwarded to Contracts and Grants Accounting to be included in the project file. Payments on a contract may be withheld by a sponsor until reports and/or other deliverables have been received by the sponsoring agency.

All financial reports required by and submitted to the sponsoring agency must be coordinated with Contracts and Grants Accounting.

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 EXHIBITS

EXHIBIT A. SAMPLE PROJECT BUDGET

1) SALARIES AND WAGES

2) EQUIPMENT

3) MATERIALS AND SUPPLIES

4) TRAVEL

5) COMPUTER, SHOP SERVICES

6) CONSULTANTS

7) OTHER DIRECT COSTS

8) INDIRECT COST [41% OF MTDC (1,3,4,5,6,7)]

TOTAL COST

EXHIBIT B. INSTITUTIONAL REVIEW BOARD FOR PROJECTS INVOLVING HUMAN SUBJECTS

INFORMATION AND GUIDELINES FOR PROPOSAL APPROVAL

Research which involves the participation of human subjects requires approval of the Institutional Review Board (IRB) prior to the initiation of the project.

Proposals for research projects which will involve human subjects should be submitted to the IRB in care of:

Institutional Review Board
Dorothy Yates, Chair
Associate Vice President for Research
Room 308, Old Main
1000 E. University Ave., Dept. 3355
Laramie, WY 82071-3355

Proposals may be submitted at any time, but at least 10 days prior to a scheduled meeting to insure inclusion on the agenda. Board meeting schedules are distributed to all faculty at the beginning of each semester. Proposals may be submitted in any format, but preferably typed on 8 1/2 x 11" white paper, and should include the following information:

1) Name, title, department, campus address, and phone number of principal investigator and co- investigators.

2) Title of research project.

3) Anticipated project duration.

4) Purpose of research project.

5) Description of human subject participation including age of subjects, how subjects will be selected, and the number of subjects involved. DHHS regulations define "human subject" as "a living individual about whom an investigator (whether professional or student) conducting research obtains (1) data through intervention or interaction with the individual, or (2) identifiable private information." The regulations extend to the use of human organs, tissues, and body fluids from individually identifiable human subjects as well as to graphic, written, or recorded information derived from individually identifiable human subjects.

6) Procedure: detailed explanation of the research procedures, including description of subjects' participation and what subjects will be expected to do, and details of what subjects will be told about the research project.

7) Statement on the extent to which subjects will be identified, directly or indirectly through codes or identifiers.

8) Description of any benefits to the subjects or to others which may reasonably be expected from the research.

9) Description of any reasonably foreseeable risks or discomforts to the subjects. All projects involve some risk to human subjects, however obvious or obscure. Proposals should state that minimal risk is involved when the proposed research is viewed as involving little or no risk to human subjects.

10) Consent form, if applicable, which includes the following information: (where information requested for the proposal is required in the consent form, a statement in the proposal which references the consent form is acceptable)

A) A statement that the study involves research, an explanation of the purpose of the research and the expected duration of the subject's participation, a description of the procedures to be followed, and identification of any procedures which are experimental.

B) A description of any reasonably foreseeable risks or discomforts to the subject. Consent form should state that minimal risk is involved when the proposed research is viewed as involving little or no risk to human subjects.

C) A description of any benefits to the subject or to others which may reasonably be expected from the research.

D) A disclosure of appropriate alternative procedures or courses of treatment, if any, that might be advantageous to the subject.

E) A statement describing the extent, if any, to which confidentiality of records identifying the subject will be maintained.

F) For research involving more than minimal risk, an explanation as to whether any compensation will be provided and an explanation as to what medical treatments will be provided if injury occurs and, if so, what they consist of, who will be responsible for medical expenses, and where further information may be obtained.

G) An explanation of whom to contact for answers to pertinent questions about the research, including a UW department, principal investigator's name and phone number.

H) A statement that participation is voluntary, refusal to participate will involve no penalty or loss of benefits to which the subject is otherwise entitled, and the subject may discontinue participation at any time without penalty or loss of benefits to which the subject is otherwise entitled. THIS STATEMENT APPLIES TO ALL TYPES OF PROJECTS AND MUST APPEAR ON THE CONSENT FORM.

The consent form must be approved by the IRB and research subjects should receive a copy of the form at the time it is signed.

Parental consent must be obtained for subjects under 19 years of age unless waived by the IRB. The IRB may require both the consent of the subject and the parent or guardian.

11) Attach copies of survey instruments, interview questions, tests, and other pertinent documentation that will be used to conduct the research. The name and phone number of an appropriate person to contact for more information about the study must appear on the survey instrument.

12) If the principal investigator is a graduate student, please submit a letter of approval from the thesis or dissertation committee chair.

Questions regarding the submission of research proposals involving human subjects may be directed to Dorothy Yates (766-5320) or the Staff Attorney (766-6236).

EXHIBIT C. ANIMAL CARE AND USE COMMITTEE PROTOCOL APPROVAL FORM

OPRR-PHS ASSURANCE #A-3216-01; EFFECTIVE: 03/01/90-02/28/95

Submit completed form to the ACUC, Office of Research, Room 308, Old Main (submit this approval form with the sponsored project "greensheet" if applicable). Research shall not begin before this form is approved.

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If you have any questions about this Web page please send comments to rparrish@uwyo.edu
Revised: April 16, 2008.