Sponsored Research & Grants

The first step is to identify the focus of your project. Once you have a project plan, write a brief concept paper that explains your project and how you would like to complete it. Set up a meeting with your dean or division head to talk about your project.

The dean or department head will talk about how it fits the mission and strategic initiatives of MSMU and review the following questions with you:

1. Is the requested amount of the grant over $100,000?
2. Does the grant require a match or contributions that cannot be covered by Dean’s Fund for Excellence or other gift funds?
3. Does the grant require hiring a new position?
4. Does the grant include any unfunded course releases?
5. Does the grant project require lab, office or other space that cannot be accommodated internally by the dean?
6. Does the grant project impact multiple university schools (more than one school, division or university office)?
7. Does the project have budgetary implications after the grant period?

If the answer is “no” to all of the above questions and the dean is confident it matches the Mount’s strategic initiatives, you then notify the grants manager and you may proceed with the grant application.

If the answer is “yes” to any of these questions, the dean advocates with the provost on your behalf. The provost will share the grant proposal with the president’s cabinet if necessary.

Faculty members may request course release as part or all a research-related grant proposal, in accordance with sponsor guidelines. The request must be made through the Department Chair and with approval of the Chair, Dean and Provost. Approval is made on condition that the release is properly budgeted for and will only be granted if an award is made.

Different granting organizations use different methods for calculating course buyout or release rates (e.g., a fixed amount, a formula based on salary, or open-ended). From the university’s perspective, the grant is advantageous if it at least covers the cost of staffing the released course(s) at the adjunct/overload rate (plus benefits and administrative costs).

The university will work according to the expectations of granting agencies and expects that faculty will normally apply for the maximum amount allowable for release time under the terms of a grant. If the grant at least covers the minimum cost of replacing the released course-load, the university will keep the faculty member at full annual salary and benefits. If a faculty member performs work on a sponsored project in addition to his or her normal duties at the college during the academic year, he or she may draw overage compensation.

The first priority of grant funds intended for release time is to provide high-quality replacement of course instruction necessitated by reassigned faculty time. Funds equal to the cost of the adjunct or replacement instructor (salary and benefits) will be transferred from the grant to the Provost’s Office to allow for this. The second priority is to support academic research and the initiative of academic administration. Assuming the first priority is met, deans should have broad discretion to approve courses releases in accord with this policy. A third priority is responsible resource stewardship. In general, when grant rewards are intended to support faculty research, any unused funds beyond adjunct replacement costs should be transferred to “rollover” accounts under appropriate academic control and should not automatically revert to unrestricted university funds at the end of a fiscal year.

It is possible that the university may approve a course release even when grant funds provide less than the minimum (break-even) expected amount (in which case the university would be supplementing the grant). For instance, faculty requesting course buyouts as part of a larger grant proposal should be aware that their granting agency may limit the amount of salary support that can be requested (for example, the NSF allows no more than 2 months’ salary equivalent in the budget). There may be instances when the size of the overall grant and the prestige of the award (for example, the NSF-STEM award), or some other benefit of the research effort, would encourage the university to offer a faculty member a course release even if the grant is structured such that a grant fund request is not permitted at the level that fully supports a course buyout. In such cases, the faculty member should consult with his or her chair, dean, and ultimately the provost to determine how the university may support these efforts.

In special circumstances, and at dean’s discretion, a faculty member may be able to buy out release time with personal funds (i.e., not using grant funds) but because this lacks some of the tangible and intangible institutional benefits of securing outside grant funds and recognition, this is not actively encouraged by the university.

The course buyouts discussed here are distinct from other forms of supplemental faculty compensation, like summer grants/summer salary that are not addressed in this document.

At this point, you should complete the intent to seek external funding form. It’s important to keep the grants manager informed if you plan to apply for a grant. This ensures that we are not competing against each other for funding from a specific foundation. It is also critical that you discuss this with your dean or department head to know that the resources are there to support your project.

It is important to remember to write the grant specifically to what the agency or foundation wants to fund. Keep it basic and simple. It does not need to be an elaborate project to get funding. Most agencies would rather see a smaller project that is well done than to try to take on too much and have poor results to show for their investment.

Data management

NSF proposals require a data management/sharing plan as part of the proposal process. A good starting point can be found at dmptool.org. The DMPTool provides detailed guidance and links to general and institutional resources and walks a researcher through the process of generating a comprehensive plan tailored to specific DMP requirements.

Letter of Inquiry

Some foundations begin with a Letter of Inquiry (LOI) before inviting a full proposal. The LOI is essentially a “snapshot” of the full grant application, usually detailing:

• The background of the organization.
• The project for which the funding is sought.
• Timeline for completion of the project for which the grant funds will be expended.
• An explanation of why the project requires the funding of the foundation to be successful.

Many private foundations and federal agencies have strict guidelines on how their grants may be used, as well as reporting requirements to ensure that their funds are being used for the correct and agreed upon purposes.

Fellowship applications that will be paid directly to a faculty member (rather than the institution) do not require budget or proposal approval prior to submission. However, given enough advance time, the grants manager is available to help you with your proposal and budget, and happy to serve as additional readers. We would like to know about your fellowship submissions as we track pending fellowship applications internally and report awarded fellowships to the faculty and include them in our online award archives.

As the grant application nears completion, an internal routing form will be circulated with a project summary and budget attached. This is to ensure that everyone is aware and onboard with the application. The routing form requires the signature of the principal investigator (PI), the dean or department head, the vice president for business and finance and the grants manager. The most important piece of any submission is following the guidelines precisely. For all deadlines, you must allow enough time for the internal routing form to be endorsed. You cannot submit your proposal until this process is complete. Begin this process early!

An important part of the application process is developing the right budget. Nichol Feeser is a senior accounting manager in our Office of Accounting and Finance. She is responsible for the financial management of grants and can help you with developing the budget during the application process through the closing reports. Please contact her early in the process to begin developing a budget.

A PI should review the faculty grants budget guide for more details.

The grants manager is available to give your proposal a final review when you are ready for submission and all approval signatures have been obtained. Depending on funder requirements, either the PI or the Authorized Organizational Representative (grants manager) will submit the proposal. Be sure you read the guidelines carefully to know who should submit the proposal.

The grants manager is required to submit proposals that require institutional endorsement. Most proposals to government agencies and research proposals to foundations require institutional endorsement.

The grants manager will also assist faculty with proposals to other organizations that do not require institutional endorsement and are submitted by faculty as individuals (e.g., fellowships). If the grants manager should submit the proposal, you are welcome to set up a time to submit together or you can forward your completed package to our office.

The grants manager can provide the College's EIN and D-U-N-S number if necessary. You must turn in the internal routing form even if the College Authorized Organizational Representative is not required for submission.

When notification of the grant award and/or check for payment of the grant funds has been received, the notice of the award will be given to the applicant and/or department chair or dean. If the applicant is notified of the award first, he or she must notify the grants manager, who will provide the appropriate notice of the award/award letter to the grants financial administrator.

After MSMU has received the official award notification, the Grants Management Office contacts the Senior Accounting Manager to assign an account number to the grant and establish the account for the deposit of funds. All expenditures and other financial activity for the grant are tracked using this number.

Any post-award reporting requirements for compliance by the grantor (the foundation, corporation or government organization) will be the responsibility of the applicant (the grantee). The applicant may work together with the grants administrator and grants financial administrator to ensure proper reporting if needed.

After MSMU has received the official award notification, the Grants Management Office contacts Financial Services to assign an account number to the grant. All expenditures and other financial activity for the grant are tracked using this number. It is important that all funding is spent as it was originally intended and in the timetable listed in the grant application. PIs must be familiar with both the funding agency policies and MSMU policies. The funding organization’s policies take precedent over MSMU’s. Alcohol and “Fly America” are, for example, two areas where federal policies and MSMU policies differ. Please contact the grants financial administrator if you will need a no-cost extension or budget revision. For federal awards, it is especially important to be knowledgeable about the compliance section of this site.

If the grants manager is notified of a fellowship or research award, either through the PI or the awarding agency, the award will be included in the provost’s report to the board of trustees and included on this website. Please use good judgment when sharing grant applications both internally and outside of MSMU. Please only share your own work and ensure that all confidential information such as compensation is redacted. If you have any questions, please contact the grants manager.

Federal guidelines require organizations to gather documentation to substantiate that the amount of salary and wages charged to federal awards is commensurate with the effort expended. Accordingly, employees working on federal awards are required to adhere to MSMU policies and procedures on effort certification.

Time and Effort Certification Report (.pdf) >

Please refer to the Mount's policy on the responsible and ethical conduct of research.

Principal investigators on federal awards are responsible for complying with all federal regulations as well as MSMU policies laid out in the governing documents, as well as the Office of Management and Budget’s (OMB) uniform administrative requirements, cost principals, and audit requirements for federal awards.

If a principalinvestigator plans to leave MSMU during the course of a grant, he or she should contact the Office of Grants Management to discuss options and procedures. MSMU has the prerogative to:

• Nominate a replacement PI, who is subject to the funder’s approval;
• Request that the grant be terminated; or
• Transfer the grant to the principal investigator’s new organization.

Once a grant has expired, the senior accountant in the Office of Business and Finance will freeze the grant number, which prevents further activity from being charged to the grant. It is at this time that the principal investigator should conduct a final review of the financial reports, promptly report to the senior accountant any necessary corrections, and submit the final progress report to the funding organization. The senior accountant is available to assist the principal investigator with his/her final financial reporting. Typically, the final financial and program reporting is due 90 days after the award termination date. If there are grant funds remaining at the end of the project, those funds must be returned to the funder.

Many private foundations and federal agencies have strict guidelines on how their grants may be used, as well as reporting requirements, to ensure that the “grantee” (the Mount) is managing and using the funds for the correct and agreed upon purposes.The grants manager’s office is principally involved in the pre-award grant process, including the application process and submission of the grant proposal, while the grants financial administrator in the Office of Accounting and Finance helps to oversee the post-award financial process, including the establishment of accounts and disbursement of funds. Policies governing the roles of each side of the grants process (pre-award, award phase and post-award) are combined here for ease of use.

The university policy in applying for and accepting public and private sponsored support is as follows:

1. To safeguard the best interests of the university, its faculty, administrators, staff and students.
2. To ensure that all applications and potential awards are consistent with the mission and core values of the university.
3. To ensure that the university is in compliance with any applicable federal, state, local or sponsor policies and regulations concerning the grant and that the university is able to provide for the effective conduct of the project and subsequent reporting to the sponsor.
4. To ensure adequate review and approval of all applications in a timely manner prior to the submission and the commitment of university personnel, space and other financial resources that may be required in the conduct of the project. No application may be submitted and approved without a complete request for grant application/approval form (further referred to as an internal routing form) that has received the necessary review and approval.
5. To ensure that all awards are reviewed and accepted by the department chair/academic dean and the grants administrator (GA) (and applicable vice presidents for advancement, business and finance, the provost, and/or the chief of staff), no award may be accepted or financial account set up without the completion, with applicable signatures, of the grant accounting control form.

To ensure compliance with the highest humane, ethical, scientific and legal standards, all MSMU faculty members or students undertaking research on any vertebrate animal must follow the policies outlined by the IRB.

For any federally sponsored research, MSMU is obligated by federal regulations to promptly report (within two months) to the appropriate federal agency any inventions conceived or reduced to practice during the course of a government-sponsored research program. The Bayh-Dole Act permits a university, small business, or nonprofit institution to elect to pursue ownership of an invention in preference to the government.

This federal regulation, passed in the 1930s to protect American workers and reinforced by the Federal Acquisition Regulations, applies to certain federal contracts and grants above the micro-purchase threshold of $3,000 and includes flow down to sub-recipients. Awardees must certify that all articles, materials and supplies funded by these awards are American-made. Exceptions can be made in the case of:

• unreasonable cost
• unacceptable quantity or quality
• use outside the U.S. only
• conflict with the public interest
• certain trade agreements
• commercial items of information technology
• domestic manufactured products (e.g., engines), if at least 50% of components are U.S.-made

Exceptions to the act must be identified in the project specifications and justified in the documents retained with procurement records relating to small purchases. False certification may be considered fraud and can result in debarment. The government also publicizes information about noncompliant awardees, who may not participate in federally funded projects for three years from the date that they are found noncompliant. This act is not the same thing as the Buy America Act of 1983, which applies only to procurement for mass-transit projects.

Though it is unlikely that MSMU faculty or staff have any financial conflict of interest, the federal government requires the Mount to annually document this information. Please see our conflict of interest policy and fill-out the conflict of interest disclosure form. Debarment and suspension certification is designed to prevent fraudulent or improper use of government funds, applies to all grants and cooperative agreements and to most contracts. Applicants must certify that they, their principals and their researchers:

• aren’t debarred, suspended, ineligible for, or excluded from funding by any federal entity
• haven’t been convicted of fraud or a criminal offense in connection with federal agreements within the past three years
• haven’t been convicted of violating federal statutes within the past three years
• haven’t been convicted of committing any form of theft or fraud within the past three years
• haven’t been charged with any of these crimes by any government entity
• haven’t had any government agreements terminated for cause or default within the past three years

False certification could result in termination of the grant and debarment, suspension or both.

Cost must meet the following general criteria in order to be allowable under federal awards:

• Be necessary and reasonable for the performance of the federal award.
• Conform to any limitations or exclusions set forth herein or by the federal awarding agency.
• Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the institution.
• Not be included as a cost or used to meet cost sharing or matching requirements of any other federally- financed program in either the current or a prior period.

The federal government generally supplies the recipient of a federal grant or contract with the funds necessary to cover the expenditures directly associated with a project; these categories of costs are described as allowable costs. There are other expenditures, however, that the federal government deems inappropriate and will not reimburse; these categories of costs are described as unallowable costs (example: alcoholic beverages). Furthermore, there are certain categories of costs that are allowable only when pre-approved by the federal awarding agency.

In compliance with the federal Drug-Free Schools and Communities Act, MSMU is committed to providing an environment that is free from the use, sale, possession or distribution of illegal drugs or the improper or abusive use of legal drugs or alcohol on MSMU premises.

It is the policy of MSMU not to discriminate improperly against any matriculated student, employee or prospective employee on account of race, color, religion, ethnic or national origin, age, gender, sexual orientation, veteran status, disability or any other protected classification. Such policy is in compliance with the requirements of Title VII of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, the Rehabilitation Act of 1973, and all other applicable federal, state and local statutes, ordinances and regulations.

Export controls are the United States laws and regulations that regulate and restrict the release of critical technologies, technical data, software code, equipment, chemical and biological materials and other materials, and information and services to foreign nationals and foreign countries for reasons of foreign policy and national security. Export control regulations, as well as boycott programs, have the potential to impact many aspects of the freedoms typically associated with research in a university setting, including publication rights, international collaboration, sending or bringing equipment to foreign countries (including laptops and cell phones), and the sharing of research technology (verbally, in writing or visually) with persons who are not U.S. citizens or permanent residents. Most of MSMU’s activities and travel to foreign countries are either not affected by export control laws, or they are subject to an exemption. Fundamental research—basic and applied research in science and engineering, the results of which are published and shared broadly within the scientific community—generally is not subject to export controls and trade sanctions. Proprietary research and industrial development are more likely to be. Projects that involve engagement with sanctioned countries or entities also may be subject to restrictions. If you have questions or think that your research may apply, please contact the Office of Grants Management.

Generally, if a traveler is traveling on funds provided by the federal government, he/she must use a U.S. flag carrier (an airline owned by an American company), regardless of cost or convenience. If you are scheduling international travel that is federally funded, you must ensure that all flights, where possible, are scheduled on U.S. flag carriers or on foreign air carriers that code share with a U.S. flag carrier. Code sharing occurs when two or more airlines “code” the same flight as if it was their own. In other words, a U.S. airline may sell a seat on the plane of a foreign air carrier; this seat is considered the same as one on a plane operated by a U.S. flag carrier. Compliance with the Fly America Act is satisfied when the U.S. flag air carrier's designator code is present in the area next to the flight numbers on the airline ticket, boarding pass, or on the documentation for an electronic ticket (passenger receipt). For example, Delta has a codeshare agreement with Air France to Paris, France. If the boarding pass (flight coupon) or e-ticket identifies a flight as DL, the requirements of the Federal Travel Regulations would be met, even if the flight was on an Air France airplane. If however, the boarding pass (flight coupon) or e-ticket identifies the flight as an AF, then the requirements of the Federal Travel Regulations would not be met.

Exceptions to the Fly America Act

The biggest exception to the Fly America Act is the Open Skies Agreement. The United States government has entered into several air transport agreements that allow federally funded transportation services for travel and cargo movements to use foreign air carriers under certain circumstances. See the current Open Skies Agreements.

What do these Open Skies Agreements mean to you?

• European Union: When traveling to a destination serviced by a European Union airline, MSMU travelers flying on a federal grant can fly on either a U.S. carrier or an EU (European Union) carrier as long as they touch down in an EU country.
• Australia: MSMU travelers using federal dollars can use an Australian airline only if a point of origin/destination is either the U.S. or Australia and there is no city-pair contract flight between the two points (origin and destination).
• Switzerland: MSMU travelers using federal dollars can use a Swiss airline only if a point of origin/destination is either the U.S. or Switzerland and there is no city-pair contract flight between the two points (origin and destination).
• Japan: MSMU travelers using federal dollars can use a Japanese airline only if a point of origin/destination is either the U.S. or Japan and there is no city-pair contract flight between the two points (origin and destination).

MSMU faculty and students strive to advance knowledge within their respective academic disciplines. In order to accomplish this goal most effectively, the Mount community believes that adherence to strict ethical norms is essential. Values such as honesty, respect for the rights and dignity of human beings, and the humane treatment of animals are not only important for living an ethical life but are among the values that underlie excellent research. However, ethical decisions may often be complex when weighing the common good with the integrity of the study and so MSMU has established the Institutional Review Board (IRB) to ensure that Mount faculty and students have considered all relevant ethical issues when designing and conducting their research.

Purpose

The Institutional Review Board (IRB) has the responsibility of reviewing all academic and administrative research that collects data that record the biological, psychological or personal aspects of individuals under the auspices of Mount St. Mary’s University. The primary duty of the IRB is the protection of subjects from potential physical or psychological harm as outlined by the U.S. Department of Health and Human Services (HHS), and the ethical codes of appropriate organizations, and to insure that the research obeys all appropriate federal and state laws.

Membership

The IRB consists of five members, appointed by the Vice President for Academic Affairs, to serve three years. A member can be reappointed. One is appointed from the Department of Psychology; one from the other academic areas of business, social or natural science; one with ethical expertise from a department outside the business and science departments, typically from philosophy or theology; one from an administrative office; one from outside the campus, with no formal ties to Mount St. Mary’s University. Among the five members will be a person who has expertise with research with legally defined minors. A chair will be elected by the members.

Responsibilities

1. The IRB formally meets at least once a year for the purpose of learning, reviewing and updating the ethical and legal aspects of research that is likely to occur at the University. The IRB assumes that the administrators, faculty and students are familiar with the ethical guidelines of their respective research fields. However, the IRB can be solicited for guidelines in such matters, as necessary. The IRB will inform the community regarding the specific procedures for the ethical review. The IRB regularly reports its minutes to the faculty.
2. The IRB uses the HHS guidelines of three categories of subject participation research: at risk, at minimal risk, and at no risk. The IRB provides the community with the defining criteria for the three categories. “At risk” projects receive a full review in a committee meeting. Projects “at minimal risk” are given an “expedited review” by circulating a submitted standard ethics review form through campus e-mail. Any members of the IRB can request the Chair to call a meeting for full review of a project if there is “at risk” concern. “At no risk” research does not have to be reviewed. “At risk” or “at minimal risk” research data collection may not proceed until written approval is received by the researcher. When approval is denied, recommendations for re-submission may be made.
3. Research involving vertebrate animals is subject to ethical review according to standards set by appropriate organizations. The amount and nature of current animal research at Mount St. Mary's University does not justify a separate University Animal Care and Use Committee (UACUC). Therefore, the review of such work will be done by the IRB. If the IRB needs the services of an outside expert to evaluate a specific project, the University will provide for the services of a laboratory-animal veterinarian to review the proposal. The amount and nature of animal research will be monitored to justify the future implementation of an UACUC, if needed.
4. Records of all ethical proposals, approvals and disapprovals, are maintained by the IRB. An annual report is made to the faculty and Vice President for Academic Affairs. Researchers are required to keep the completed informed consent forms of subjects of approved research on file for a period of three years. In the case of student research, the faculty mentors keep the informed consents on file. Replications of research projects and follow-up research projects must submit new ethics review proposals.
5. Official HHS guidelines can be found in the Code of Federal Regulations, Title 45, Part 46 (Protection of Human Subjects).

It is MSMU policy to provide a safe and healthful environment, free from recognized hazards that may cause serious injury to students, employees and visitors. This is accomplished by maintaining a comprehensive safety, health, and environmental program that involves all employees. MSMU will conduct all of its activities in compliance with applicable standards, codes, regulations and laws. Every person at the institution understands that safety and health are not additional job responsibilities, but are an integral part of every task.

All faculty members in science areas funded by the National Institutes of Health (NIH) and the National Science Foundation (NSF) should be familiar with “Procedures for Dealing with and Reporting Possible Misconduct in Science.” These procedures cover cases of fabrication, falsification, plagiarism, and other serious deviation from accepted practices of proposing, carrying out, or reporting results for research. They also cover material failure to comply with federal requirements for protection of research, human subjects, or the public; for ensuring the welfare of laboratory animals; or failure to meet other material legal requirements governing research.

MSMU may only charge to the federal award allowable costs incurred during the period of performance.

All procurement transactions must be in compliance with existing MSMU policies. Beyond MSMU policies, there are additional restrictions that must be followed relating to the expenditure of federally awarded funds. These additional restrictions and requirements are found under Procurement Standards of the Uniform Guidance sections 200.317 – 326. All purchases made with federal funding are subject to audit by federal awarding agencies.

All procurement transactions must be conducted in a manner providing full and open competition consistent with the standards noted below. In order to ensure objective contractor performance and eliminate an unfair competitive advantage, contractors that develop or draft specifications, requirements, statements of work, or invitations for bids or requests for proposals must be excluded from competing for such procurements. Some of the situations considered to be restrictive of competition include but are not limited to:

1. Placing unreasonable requirements on firms in order for them to qualify to do business;
2. Requiring unnecessary experience and excessive bonding;
3. Noncompetitive pricing practices between firms or between affiliated companies;
4. Noncompetitive contracts to consultants that are on retainer contracts;
5. Organizational conflicts of interest;
6. Specifying only a “brand name product instead of allowing “an equal” product to be offered;
7. Any arbitrary action in the procurement process.

MSMU will conduct procurements in a manner that prohibits the use of statutorily or administratively imposed state and local preferences in the evaluation of bids or proposals, except in those cases where applicable federal statutes expressly mandate or encourage geographic preference.

The PI must use one of the following methods of procurement whenever purchasing goods or services with federal funding. The thresholds listed below are per the OMB issued memorandum M-18-18, “Implementing Statutory Changes to the Micro-Purchase and Simplified Acquisition Threshold for Financial Assistance” which was effective as of June 20, 2018.

1. Micro Purchasing Method: Procurement by micro-purchase is the acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold of $10,000. To the extent practicable, the PI will distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive quotations if the PI considers the price to be reasonable.
2. Small Purchase Method: Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies or other property that do not cost more than the defined Simplified Acquisition Threshold of $250,000. Price or rate quotations must be obtained from at least two suppliers. The PI is responsible for documenting suppliers reviewed, quotes received and reason for selection of supplier. Quotes can be obtained from suppliers or from public websites and included as backup documentation for the purchase. For purchases of $25,000 or more, the PI, before engaging a supplier, must search the System for Award Management (SAM) for the vendor by name, tax identification number, or another characteristic to make sure the person or entity hasn’t been suspended or debarred from performing federally funded work.
3. Sole Source Method: Procurement by noncompetitive proposal is procurement through solicitation of a proposal from only one source and may be used only when one or more of the following circumstances apply:
   • The item is available only from a single source;
   • The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation;
   • The federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-federal entity; or
   • After solicitation of a number of sources, competition is determined inadequate.

The Uniform Guidance recognizes that researchers need to acquire items from a sole/selected source for scientific/technical reasons (for example when a service or items is only available with the required quality from one source or only one source can provide the items or service in the time frame required). This “sole/selected source” option is available at all dollar amounts and the justification must be documented and maintained by the PI. Instances, when sole/selected source purchasing may be applicable, would include, but not limited to, the following:

1. The equipment, supplies and/or service provider are required by the funding agency (specifically named in an awarded grant or contract) and therefore deemed essential to the project. Please note: just naming a supplier in a proposal does not justify their use as a sole source supplier – justification still needs to be documented.
2. Specific materials or supplies are required to maintain critical experimental continuity.
3. Property and services can be obtained only from a specific supplier (i.e. real estate, utility services, one of a kind items, etc).
4. Competitive sourcing is precluded because of the existence of patents, copyrights, secret processes, control of raw materials by suppliers or similar circumstances that limit competition.
5. Procurement of replacement or upgrade components for equipment manufactured by a specific original equipment manufacturer (OEM) if OEM parts are required in order to not void the warranty.
6. Purchasing of support services in connection with the assembly, installation or servicing of equipment or software of a highly technical or specialized nature.
7. Purchasing of compatible additions to existing equipment where a different manufacturer’s equipment would be impractical for the specific need.
8. The project/work has a firm schedule requirement which only one supplier has the capability of meeting. Failure to meet the schedule requirement would seriously impact the project/work.
9. Purchasing where only a single supplier in a relevant market is licensed or authorized to service or sell a specific product line and related services.
10. Software / Subscription renewal or equipment services / maintenance agreement.

Required for any construction projects greater than $250,000. Bids are publicly solicited and a firm-fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming to all the material terms and conditions of the invitation for bids, is the lowest price. In order for sealed bidding to be feasible, the following conditions should be present:

1. A complete, adequate and realistic specification or purchase description is available;
2. Two or more responsible bidders are willing and able to compete effectively for the business; and
3. The procurement lends itself to a firm-fixed-price contract and the selection of the successful bidder can be made principally on the basis of price.

Required for any non-construction purchases greater than $250,000. Competitive selection is normally conducted with more than one source submitting an offer, and either a fixed-price or cost reimbursement type contract is awarded. It is generally used when conditions are not appropriate for the use of sealed bids. If this method is used, the following requirements apply:

1. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Any response to publicized requests for proposals must be considered to the maximum extent practical;
2. Proposals must be solicited from an adequate number of qualified sources;
3. The PI must have a written method for conducting technical evaluations of the proposals received and for selecting recipients;
4. Contracts must be awarded to the responsible firm whose proposal is most advantageous to the program, with price and other factors considered; and
5. The PI will use competitive proposal procedures for qualifications-based procurement of architectural/engineering (A/E) professional services whereby competitors’ qualifications are evaluated and the most qualified competitor is selected, subject to negotiation of fair and reasonable compensation.

Financial records, supporting documents, statistical records, and all other MSMU records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the federal awarding agency or pass-through entity in the case of a sub-recipient. The only exceptions are the following:

1. If any litigation, claim or audit is started before the expiration of the three-year period, the records must be retained until all litigation, claims or audit findings involving the records have been resolved and final action is taken.
2. When MSMU is notified in writing by the federal awarding agency, cognizant agency for audit, oversight agency for audit, cognizant agency for indirect costs, or pass-through entity to extend the retention period.
3. Records for real property and equipment acquired with federal funds must be retained for three years after final disposition.
4. When records are transferred to or maintained by the federal awarding agency or pass-through entity, the three-year retention requirement is not applicable to MSMU.

Beginning in January 2010, many federal grantmaking agencies – including the National Science Foundation and the National Institutes of Health – required grantees to certify that they provided appropriate training and oversight in the responsible and ethical conduct of research.

During the course of a sponsored project, unexpected circumstances may arise that may not have been previously anticipated. As a result, the PI/PD may need to request changes to his/her project. Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from federal awarding agencies when:

• Change in scope of the objective of the project or program.
• Change in a key person.
• Disengagement from the project for more than three months or a 25% reduction in time devoted.
• The transfer of funds budgeted for participant support costs.
• The sub-awarding or transferring out of any work not previously described.
• Changes in the amount of cost-sharing or matching.

This law (Public Law 100.463, Section 8136) is intended to give the federal government public credit for federally funded programs and projects. It requires federal grant recipients to include funding information on all publications related to projects that use federal funds, including statements, press releases, signs at construction sites, requests for proposals, bid solicitations, and other documents that describe projects or programs funded in whole or in part with federal money. The information must state clearly the total cost of the program and the dollar amount of federal funds used.

This law applies to grants and cooperative agreements but not to contracts. It does not apply to subcontracts, but it may apply to sub-awards. Academic publications (peer-reviewed journals, presentations to professional groups) resulting from the project research are not required to include this information.

Although no sanctions are specified for noncompliance, failure to comply could be considered a breach of responsibilities and may result in termination, suspension or debarment.

MSMU is responsible for ensuring that all sub-award agreements it issues comply with federal regulations. Prior to a sub-award being issued, MSMU must take certain steps to ensure the appropriate use of federal funds by the sub-recipient. MSMU will use our sub-award agreement for compliance. The principal investigator (PI) / project director (PD), with support from the grants manager and the Office of Accounting and Finance, is responsible for monitoring the activities of the sub-recipient as necessary to ensure that the sub-award is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the sub-award; and those sub-award performance goals are achieved.

The PI/PD is responsible for tracking and monitoring the progress of the sub-recipient to ensure the efforts outlined in the scope of work are being met and reimbursements are being made in relation to programmatic progress. To this end, the PI/PD monitoring activities shall include:

• Providing sub-recipients with guidance, technical assistance and training (if necessary) on program-related matters.
• Reviewing financial and programmatic reports as required in the sub-agreement, supplemented by informal communications with the sub-recipient, to ensure progress on performance goals.
• If deemed necessary, perform on-site reviews of the sub-recipient’s program operations.
• Approve all the sub-recipient’s invoices for payment by the Office of Accounting and Finance. In approving the invoice, the PI/PD is certifying the expenditure was incurred during the period of performance of the sub-award, is for authorized activities of the sub-award, and that progress towards performance goals are being achieved.
• Special attention should be given to budgeted purchases by the sub-recipient in excess of $3,000. The sub-recipient should be providing documentation substantiating it complied with MSMU’s price or rate quotation requirements.
• Notifying the grants manager of any instances of non-compliance with the terms and conditions of the sub-award or failure to make progress with programmatic goals by the sub-recipient.

It is the responsibility of the grants manager to identify potential funding sources for faculty and administrators, to guide them in searching for prospective foundations and government agencies from which to seek grant funding, and to assist in writing grant proposals for institutional projects or programs. The grants manager maintains contact with foundations and assists in setting up or brokering meetings between PIs and foundations or agencies. The grants manager reviews to ensure there is no conflict of interest concerning the funding agency and to ensure he or she will be able to provide the documentation and resources needed to submit the final proposal. The grants manager assists the project leader in meeting post-award requirements.

MSMU may terminate a federal award to a sub-recipient in whole or part because the sub-recipient fails to comply with the terms and conditions of a federal award. Upon sending the sub-recipient a written notification setting forth the reasons for such termination, the effective date, and in the case of partial termination, the portion to be terminated. The notification will also state that the termination decision may be considered in evaluating future applications received from the sub-recipient. In accordance with requirements of the federal awarding agency, MSMU must provide the sub-recipient an opportunity to object and provide information and documentation challenging the termination.

In accordance with federal requirements (§200.430) prescribed by the Office of Management and Budget (OMB), charges to federal awards for salaries and wages must be based on records that provide reasonable assurance that the charges are accurate, allowable and properly allocated. In order to receive and maintain eligibility for funding, sponsoring agencies require organizations to gather documentation to substantiate that the level of salary or wages charged to federal awards is commensurate with the effort expended. This certification is completed for the following two purposes:

1. To verify that the percentage of effort placed on a federal award is not less than the percentage of salary charged to the federal award.
2. To capture any voluntary cost sharing by indicating any excess percentage of effort as compared to the percentage of salary.

Time and Effort Certification (.pdf) >

MSMU utilizes an “after-the-fact” reporting system to comply with the federal effort certification requirement. Under an after-the-fact system, distribution of salaries and wages for employees working on externally-funded projects will be supported by effort certification reports. Charges are made initially on the basis of estimates made before the services are performed. Effort certification reports will reflect an after-the-fact reporting of the actual percentage distribution of activity of employees. If significant (>10%) differences between the charges and actual distribution, the charges will be promptly adjusted to reflect actual activity.

Employees working on federal awards are required to adhere to following procedures on effort certification:

• Faculty and exempt employees will be asked to report the percent effort for all federally sponsored activity and curricular activities (i.e., instruction, administration, advising, etc.). Note: Hourly employees and student workers are not required to complete a report as their time is certified via Workday.
• Effort certification reports will reasonably reflect the percentage distribution of effort by faculty and exempt employees charged to federally funded projects. Effort is not determined based on a 40-hour week but rather as a percentage of total employment activities. 100% effort is an employee’s total hours actually spent on work within the scope of his/her employment activities. The activities for which you are being compensated, include sponsored and non-sponsored activities, for a given time period. The purpose of the report is to certify the level of effort expended on these activities.
• Employees should provide an account of all effort expended on a sponsored activity, even if the sponsor did not compensate the employee for that activity, which constitutes “cost sharing.” This can occur on a mandatory or voluntary basis. Mandatory cost sharing occurs when it is required by the sponsor at the time of application. Voluntary cost sharing represents additional effort expended on a project that is not required by the sponsor. Although it is MSMU’s practice to minimize voluntary cost sharing, the principal investigator must record all effort expended on their projects regardless of the source of compensation.
• Faculty and exempt employees will complete and sign the effort certification report. Principal investigators (PI) / project directors (PD) are required to verify the accuracy of information provided by employees working on the grant. Certification reports of the PI/PD are to be verified by the department chair or dean.
• Effort certification reports are required annually and at the completion of a grant. The grants financial administrator will distribute the reports to PI/PDs in September of each year and when closing out a grant. Completed forms must be returned to the grants financial administrator by 30 days after a request. The PI/PD is responsible for sending the form to any other faculty or administrative employees working on the grant and ensuring the forms are completed.
• Completed employee effort certification reports will be filed in the Office of the Grants Financial Administrator.

Subject to the following obligations and conditions, equipment acquired under a federal award will vest in MSMU upon acquisition:

• The equipment is used for authorized purposes of the project, and MSMU will also make the equipment available for the use on other projects supported by the federal government, provided such use will not interfere with the work on the project it was originally acquired.
• MSMU will not encumber the property without approval of the federal awarding agency.
• When no longer needed for the original program or project, the equipment may be used in other activities supported by the federal awarding agency, in the following order of priority:
  
  
  1. For activities under an award from the federal agency which funded the original program or project.
  2. For activities under an award from other federal agencies.
• When acquiring replacement equipment, MSMU may use the equipment to be replaced as a trade-in or sell the property and use the proceeds to offset the cost of the replacement property.

Management Requirements

Procedures for managing equipment, until disposition takes place, will meet the following requirements:

• MSMU will maintain adequate property records, which include a description of the property, serial or identification number, the source of funding for the property, who holds the title, the acquisition date, original cost, the location, and any disposition data.
• MSMU will take a physical inventory of the property and the results reconciled with the property records at least once every two years.
• MSMU will maintain a system of control to ensure adequate safeguards to prevent loss, damage or theft, and to keep the property in good condition.
• If there is a residual inventory of unused equipment:
• Valued at $5,000 or less: MSMU may retain, sell or dispose of the equipment with no further obligation to the federal awarding agency.
• Valued at $5,001 or more: Upon termination or completion of the project or program and the equipment is not needed for any other federal award, MSMU must retain the equipment for use on other activities or sell them, but must, in either case, compensate the federal government for its share. MSMU will contact the federal awarding agency for instructions on the disposition instructions and determining the amount of compensation.

Supplies acquired under a federal award will vest in MSMU upon acquisition. If there is a residual inventory of unused supplies:

• Valued at $5,000 or less: MSMU may retain, sell or dispose of the supplies with no further obligation to the federal awarding agency.
• Valued at $5,001 or more: Upon termination or completion of the project or program and the supplies are not needed for any other federal award, MSMU must retain the supplies for use on other activities or sell them, but must, in either case, compensate the federal government for its share. MSMU will contact the federal awarding agency for instructions on the disposition instructions and determining the amount of compensation.

Typically the PI is the actual writer of the grant proposal. He or she will be directing the project or program for which the grant funding is sought. It is the responsibility of the PI to create a budget for the grant and ensure that the proposal meets all the guidelines of the foundation. The PI is also responsible for any follow-up reporting due to the foundation on the progress or status of the grant funds/program. Please note the PI may also be the department chair/dean.

The department head or director has the responsibility to review the grant application and discuss with the PI how the proposed grant will affect the department and/or PI’s workload and other academic responsibilities. The department head/director will need to review the grant’s budget, especially if additional institutional resources are required to complete the grant from department funds.

For grants involving faculty from a particular department within a school or college, the primary role of the academic dean is to review the PI’s grant with special attention to any requests for matching funds or institutional resources which would be required from the school or college budget lines. Extraordinary requests for support, such as building renovation, hiring of additional personnel, or substantial faculty course release time, would need to be approved by the PI’s academic dean.

It is the responsibility of the grants manager to identify potential funding sources for faculty and administrators, to guide them in searching for prospective foundations and government agencies from which to seek grant funding, and to assist in writing grant proposals for institutional projects or programs. The grants manager maintains contact with foundations and assists in setting up or brokering meetings between PIs and foundations or agencies. The grants manager reviews to ensure there is no conflict of interest concerning the funding agency and to ensure he or she will be able to provide the documentation and resources needed to submit the final proposal. The grants manager assists the project leader in meeting post-award requirements.

The grants financial administrator (GFA) reviews the grant application for budgetary concerns. Where commitment of university funds is involved, the GFA will check the department, school or college, or applicable university budget lines to ensure there are sufficient funds to devote to the PI’s grant request. The GFA also authorizes payment of federal grant funds through ACM$ and reviews the general ledger of the PI for accuracy and completeness.

As the head of academics for the university, the provost must be informed of the grant requests going out from the academic divisions which he or she oversees. Any requests for resources requiring vice presidential approval above the department or school-level need to be signed by the provost. On some applications, the provost may be called upon to sign the application.

The vice president for university advancement ensures that there is no conflict of interest between the proposed grant and other outstanding fundraising requests to the foundation or related individuals, and that the grants administrator has the resources necessary to fulfill his or her function of the grants application process. On grants where previous foundation contact has been established or with which the Mount already has a working relationship, the vice president may be needed to make a visit to the foundation or host foundation representatives at the Mount. On some applications, the vice president for advancement may be called upon to sign the application.

The vice president for business and finance ensures that the budgetary review work of the grants financial administrator (GFA) is in keeping with the University’s established financial policies and that there are no financial issues of which the GFA is unaware. For large or complex budgets, the vice president for business and finance should be informed of how managing the grant post-award will impact the GFA or other accounting staff or if additional resources from his or her division are required to ensure reporting is timely and accurate.

In the case of institutional grants outside of academics or which fall under student life, the vice president may be required to sign or approve the grant application should the project ultimately fall to staff under his or her division. Examples of institutional grants could include renovations, infrastructure, building initiatives, specific scholarship programs and other non-academic programs.

Occasionally, the president is needed to attend visits with foundations or when foundation representatives visit the Mount. On some applications, the CEO or head of the organization is required to sign the grant application. The president would fulfill this role.

The scope of the project/program in the grant requires additional staff support, such as an administrative assistant.

The project or program requires a building or site to either be constructed or renovated in order to accommodate the needs of the grant and the scope of the program.

If this is a collaborative project/program, these are the persons working on the grant/project/program with you.

A faculty member needs funding to cover the time where they will not be teaching a course, but will be researching or directing the project/program the grant is funding. This could include coverage for the faculty member selected to take over the PI’s workload. Please refer to the Course Release information in the Pre-Award section of this page.

The foundation from which you are seeking funding.

MSMU has a federally negotiated Indirect Cost Rate agreement. If possible, this rate should be used in a proposal. Private foundations often do not allow the full negotiated rate to be used. Indirect cost rate discussions will be a part of the budgeting process for your proposal.

Also known as facilities and administration (F&A), indirect costs are used for the benefit of the institution to recover costs not directly included in the grant itself. For example, indirect costs can reimburse the cost of time, labor, or material associated with writing the grant proposal and carrying out the project for the university, the PI, the academic dean, department, school, the provost and also the grants administrator and grants financial administrator.

For projects where other university resources are required to fully fund the project or program. These could include hiring additional staff members, faculty course release time, building or space renovations, IT or technical support or other costs. These are detailed on the back of the internal routing form.

The project/program involves research or testing which includes human/animal subjects. This can range from using a survey to gather data and results to performing experiments or research on human or animal subjects.

The project or program requires IT or technical support on the part of the university outside of what is already in place.

Occasionally, the grant requested requires the University to match funding at a specified ration in order for the grant to be funded. Matching funds will be discussed in the budgeting process.

Equipment purchased as part of the grant will incur general upkeep and maintenance out of the university’s funds in order for it to remain operational.

Any other possible costs which would not be covered under the grant funds.

The overall program within which your project is included (if applicable).

Person writing the grant and who will be working on/overseeing the project. Typically at the academic level, this is the professor.

The date your project/program will begin and the anticipated ending date.

The date the proposal is due to the funding agency and the date by which you can reasonably expect to receive a decision.

For a project spanning multiple years, this refers to the total funding to be expended in the first year.