The purpose of this policy is to provide a framework for the process of pursuing externally funded sponsored programs while ensuring the University’s compliance with federal and state laws; CSU Executive Orders and policies; collective bargaining agreements; sponsoring agency requirements; SSU policies; and other applicable laws, regulations and requirements.
Sonoma State University (SSU) recognizes that sponsored programs (defined at SSU as government and restricted private foundation grants) are a means for campus personnel to pursue scholastic, research, and creative/educational activities that will enable them to:
- remain current in their disciplines
- enrich their teaching
- further their professional development
- contribute knowledge to their fields
- obtain resources for the University or the local community
The guidelines and procedures set forth in this policy are in fulfillment of California State University Executive Orders No. 890, 1000 and applicable Integrated California State University Administrative Manual (ICSUAM) policies.
This policy is applicable to all Sonoma State University units and its related auxiliary corporations. Applicability to the auxiliaries is for adoption of process and responsibility only and is not to be construed as a transfer of liability or risk.
Jointly the Chief Research Officer and the Senior Director for Sponsored Projects Administration are responsible for reviewing this policy during January, 2004 and bi-annually thereafter, to ensure the policy is current, and to update and revise as appropriate.
- Roles and Responsibilities
- Office of Research and Sponsored Programs.
The Chief Research Officer has been delegated responsibility for pre-awarding activities by the President under the authority of CSU Executive Order 168. [Letter of delegated authority on file at ORSP] Responsibilities include but are not limited to:
- Review and approve the overall campus academic aspects of grant and contract proposals.
- Approve the proposal budgets and narrative summaries of proposals or requests for funding of research or other special educational projects to sponsoring federal or state agencies, public or private corporations, private foundations or individuals prior to submission.
- Coordinate the routing of sponsored program proposals to assist the principal investigator in complying with applicable CSU and SSU policies and regulations prior to the proposal being submitted to the receiving agency.
- Advise the SSU academic community of sponsored program opportunities.
- Assist faculty in the development of sponsored program proposals including editing of the proposal narrative, preparing the budget, completing required agency forms, and fulfilling the prospective sponsor’s requirements and pre-award compliance issues.
- Division of Administration and Finance.
The Senior Director for Sponsored Projects Administration has been delegated responsibility for post-award activities by the Vice President for Administration and Finance and Chief Financial Officer under the authority of CSU Executive Order 890. Responsibilities include but are not limited to:
- Review and approval of the overall campus fiscal, human resource, logistical, facility maintenance, and technology aspects of sponsored program proposals.
- Serves in the capacity of SSU’s Authorizing Official (authorized organizational representative) for providing sponsoring agency assurances such as drug-free workplace, lobbying, vendor debarment, equal opportunity, and other related documents required by granting agencies following the grant award.
- Providing contractual, procurement, and fiscal services including disbursement, billing and reporting.
- Assurances - certifications of compliance with federal or state regulations that include such issues as the use of humans in research, maintenance of a drug-free workplace, and disclosure of scientific misconduct. Such assurances are often required when applying for government funding and must be signed by the University’s Authorizing Official.
- Budget - the financial plan or cost assessment for the grant proposal or contract, reflecting all costs associated with implementation of the project in compliance with sponsor guidelines, government regulations, and CSU and SSU2 policies.
- Contract - a legally enforceable commitment to deliver a product, usually goods or services, by a certain date. Contracts are subject to an extensive body of law and regulations; authorization to sign a contract is limited to key University personnel.
- Cost-Sharing - the University’s support of a project through either cash or in-kind services. Cost sharing requirements vary but generally represent a percentage of the total project cost. Refer to the University’s policy on cost sharing
- Direct Costs - all costs that can be directly attributed to the conduct of the project and are specified in the proposal budget, excluding overhead or other indirect costs.
- Grant - provision of property or funds in support of an activity outlined in a proposal describing project goals, objectives, activities, personnel, and budget. Grants are usually from federal, state, local, foundation, or corporate entities.
- Grantee - the entity that receives a grant and assumes legal and financial responsibility and accountability both for the awarded funds and for the performance of the grant-supported activity. For purposes of this policy, the grantee is Sonoma State University.
- Indirect Costs (IDC) – Also known as Facilities and Administrative costs (F&A) - costs incurred by an institution in supporting projects funded by grants and contracts from outside agencies. These costs include general and departmental support and the use of University services such as libraries, laboratories, classroom facilities, computer centers, and utilities. They also include essential administrative services including accounting, personnel, payroll, accounts payable, accounts receivable, specialized insurance coverage, compliance and regulatory monitoring, independent audits, and legal services.
- Project Director (PD)/Principal Investigator (PI) - the designated tenured, tenure-track faculty, or MPP (Management Personnel Plan) designated employee who is responsible for a funded project. Faculty on FERP may apply for or serve as sole Principal Investigators on grants only where the grant can be accomplished during their period of employment under FERP and within the FERP appointment. Appointment in addition to the FERP appointment to accomplish the work of a grant is prohibited in accordance with the provisions of the collective bargaining agreement covering faculty.
- Proposal - a written statement establishing the objectives, need, methodology, qualifications of investigator, and budget plan for a project.
- Indirect Costs
Sonoma State University has an Indirect Cost Rate Agreement with the federal government which is negotiated every three years. This agreement specifies indirect cost rates to be applied to awards from federal and non-federal sponsors.
Exceptions to these rates occur when a funding agency places a cap on the indirect cost rate. In this case, the Office of Research and Sponsored Programs must have written guidelines from the funding agency stating that there is a limit on indirect costs.
Any variation from rates described above must be approved by the Chief Research Officer and the Senior Director for Sponsored Projects Administration.
- Proposal Approval and Submission
- Review and Approval
All proposals for externally funded projects that will be conducted under the auspices of Sonoma State University must undergo administrative review prior to submission, including:
- Approval by the appropriate schools dean(s) or unit division executive at the recommendation of the Principal Investigator and the appropriate department chair(s).
- Information Technology Department review of the proposal’s impact on campus technology infrastructure.
- Office of Faculty Affairs/SSU Human Resource Department review of proposed personnel staffing, collective bargaining, campus recruiting, compensation and hiring policies and practices.
- Approval by the Chief Financial Officer and the President or their designees.
- Other departmental and/or administrative approvals as deemed necessary (including but not limited to Facilities Management, Environmental Health & Safety, Police Services and Procurement).
Refer to Sonoma State University’s Grants and Contracts Procedure Manual
These procedures do not apply to scholarships, fellowships, or other external funding that is awarded directly to an individual and for which the University has no financial, performance or administrative responsibilities. Approvals for post-award modifications to award agreements require varying levels of approval based on the significance of the modification. Post-award modifications are managed by Sponsored Programs Administration.
- Principal Investigator (PI Responsibilities)
- The Principal Investigator (PI) is responsible for the development of proposals in compliance with CSU, SSU and funding agency policies, procedures and requirements. The PI is required to follow SSU's policies and procedures related to conflict of interest reporting.
- Principal Investigators’ proposing multi-Institutional sponsored programs shall ensure receipt of completed and authorized proposals from proposed sub recipients prior to their inclusion in proposal submission.
- In the case of the incumbent Principal Investigator’s resignation, incapacitation, or failure or refusal to perform the duties adequately, the Dean or appropriate administrator shall reassign the PI’s responsibilities.
- Authorized Signatures
Any Institutional assurances required by granting and contracting agencies must be signed by the University’s designated Authorizing Official or the Authorizing Official’s designee.
- Approval of the Use of Humans as Subjects in Research
All projects entailing the use of humans as subjects in research—including interviews, questionnaires, surveys, observations, educational tests, and secondary analysis of previously collected data—must be reviewed and approved by the University’s Institutional Review Board prior to initiation of the project. Depending upon the perception of potential risk, and/or sponsor requirements, initiation of the approval process may be required prior to submission of the proposal. Refer to Sonoma State University’s policy on the Use of Human Subjects in Research
- Animal Welfare
All projects entailing the use of animals as subjects in research must be reviewed and approved by the University’s Institutional Animal Care and Use Committee (IACUC) prior to initiation of the project. Depending upon sponsor requirements, initiation of the approval process may be required prior to submission of the proposal. Refer to Sonoma State University’s policy on Animal Care and Use
- Health and Safety
All projects requiring the use of hazardous materials and/or equipment requiring special safety measures or training must be reviewed and approved by the University’s Director of Environmental Health and Safety.
- Review and Approval
- Administration of Grants and Contracts
- Acceptance of Awards
In the administration of sponsored programs, SSU is obligated to conform and comply with all relevant federal and state statutes and regulations and all directives issued by the California State University (CSU) Board of Trustees and the Office of the Chancellor. In order to meet these obligations, only specific individuals authorized by the President to act on behalf of Sonoma State University (SSU) may accept grants and contracts awarded by federal, state, local government and private agencies. SSU is the contracting agency subject to audit and review by these granting agencies and is, therefore, responsible for the proper expenditure of funds and submission of timely and accurate financial reports.
Prior to the acceptance of an award on behalf of Sonoma State University, Sponsored Projects Administration must ensure that a signed Confirmation of Understanding for the award’s Principle Investigator/Project Director is on file with Sponsored Programs Administration. The Confirmation of Understanding outlines the responsibilities and expectations for Principle Investigators/Project Directors for awards administered by Sonoma State University.
- Ownership, Custody and Retention of Sponsored Program Records
Unless the Contract or Grant specifies to the contrary, Sonoma State University shall own the records relating to the sponsored program. Any contract or grant that provides for ownership by or license to any person or entity other than the University shall provide the University the right to access and use those records for purposes consistent with the educational mission of the University.
- Record Retention
Unless the Contract of Grant specifies to the contrary, Sonoma State University is subject to the record retention policies and procedures noted in Executive Order 1031 The Office of Research and Sponsored Programs (ORSP) shall retain, at a minimum, custody of the following records in compliance with Executive Order 1031:
- Original copies of Institutional Approval Forms, submitted proposal summaries and related documentation until such time as a funding decision is made. If the proposal is funded, the original copies shall be transferred to the Division of Administration and Finance and a copy is retained in ORSP. If the proposal is not funded, the original copy shall be returned to the Principal Investigator and a copy shall be retained by ORSP.
- Conflict of interest forms for governmental agencies shall be retained by ORSP.
- All records related to the Rights of Human Subjects in Research including but not limited to completed applications, minutes of Institutional Review Board Meetings, and all documentation filed with the Department of Health and Human Services Federalwide Assurance of Protection for Human Subjects filings shall be retained by ORSP.
- Post Award Custody and Retention
The Division of Administration and Finance shall retain custody of the grant and contract business documents; contracts, invoices, agency funding reports, etc.,in compliance with Executive Order 1031.
- Retention Extension
Records shall be kept for a period longer than Sonoma State University’s record retention policy when:
- Specific directions are set forth in the contract or grant requiring a longer period of time. Sonoma State University will retain and allow access to all financial records, supporting documentation, statistical records, and evaluation and program performance data for the time specified by the Grantor.
- The records are the subject of a pending audit or litigation.
- Principal Investigator (PI) Responsibilities
The Principal Investigator (PI) is responsible for meeting the program and financial goals and objectives of the grant as well as the technical reporting requirements of the grant or contract. The PI is required to follow Sonoma State University’s policies and procedures related to conflict of interest reporting.
- Fiscal Administration
- Budget: Each accepted grant/contract award must have an approved project budget, which includes direct and indirect costs as well as cost-sharing costs if applicable. Changes in a project’s budget must be approved by SSU and may also, in some cases, require prior consent of the funding source.
- Direct Expenditures: All grant and contract expenditures must be in compliance with federal, state, and local government laws, rules, and regulations as well as CSU and SSU policy and procedures. When there is a variance between any agency and SSU guidelines, the agency or SSU regulation, whichever is more restrictive, shall govern.
- Recruitment and Appointment: All recruitment and appointment activities must adhere to CSU and SSU policies and procedures. Salaries and fringe benefits will be compliant with the appropriate CSU unit bargaining agreement. Salary for administrators and students must meet the CSU and SSU policies and conform to the funding agency’s guidelines. Refer to SSU Human Resources
- Procurement: Disbursements and acquisition of contractual services, supplies and equipment must follow CSU and SSU procurement policies and procedures as well as any specific requirements of the granting agency. Refer to SSU Finance website
- Travel: Travel and reimbursement for travel that is authorized and funded by a sponsored project will follow all SSU travel policies and procedures. Refer to SSU Travel Policy
- Cost Sharing: All sponsor-required cost sharing must be accounted for and documented in the same detailed manner as sponsor-funded costs. Refer to SSU Cost Sharing Policy
- Acceptance of Awards
Updated July 23, 2014 by SSU.firstname.lastname@example.org