2010 Sponsored Projects Handbook

100 Institute Road Worcester, MA 01609 www.wpi.edu

2010

Office of Sponsored Programs

Worcester Polytechnic Institute 20 Trowbridge Road, Worcester, MA 01609-2280

Tel: +1-508-831-5359, Fax: +1-508-831-5789

Web Site: www.wpi.edu/offices/osp.html

Effective Date: 09/04/10

Sponsored Projects Handbook


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SPONSORED PROGRAMS HANDBOOK

TABLE OF CONTENTS

Section Page

I. INTRODUCTION 6

II. SOURCES OF FUNDING 7

1. Identifying Funding Sources 7

2. Contacting Sponsors 7

3. Adherence to Proposal Guidelines 7

III. PROPOSAL ACTIVITIES 9

1. Eligibility Determination 9

2. Proposal Preparation - Components of a Proposal 9

A. Cover Page 11

B. Abstract or Project Summary 11

C. Introduction 11

D. Project Description 11

E. Bibliography 11

F. Curriculum Vitae 11

G. Budget and Justification 11

H. Current and Pending Support 13

I. Facilities and Equipment 13

J. Appendices 13

3. Proposal Submission Procedure 12

4. Required Reviews 13

5. Sponsor Review 14

6. Negotiation and Acceptance 15


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SPONSORED PROGRAMS HANDBOOK TABLE OF CONTENTS - CONTINUED

IV. AWARD ACTIVITIES 16

1. Account Creation 16

2. Interpreting Banner Financial Information 16

3. Budgets 17

4. Expenditure Processing 17

5. Prior Approvals 19

6. Cost Transfers 19

7. Time and Effort Reports 19

8. Sponsor Reporting Requirements 19

A. Financial 21

B. Programmatic 21

C. Invention 22

D. Property 22

E. Other 22

9. Award Closeout 22


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V. ISSUES IN SPONSORED PROGRAM ADMINISTRATION 23

1. Advance Accounts 23

2. Audits 24

3. Compliance 25

4. Conflict of Interest 31

5. Cost Sharing 31

6. Equipment and Property 32

7. Export Control Laws & Regulations 33

8. Freedom of Information Act (FOIA) 36

9. Incentive Funds 37

10. Indirect Costs (Facilities & Administrative Costs) 38

11. Institute Prior Approval System (IPAS) 40

12. Intellectual Property 40

13. Pre-award Costs 41


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VI. POLICIES AND PROCEDURES 42

1. Access to and Retention of Data 42

2. Alcohol and Other Drugs Policy

3. Animal Care Policy and Procedures

4. Cash Minimization Procedure 43

5. Conflict of Interest Policy 44

6. Copyright Policy

7. Cost Sharing, Policy and Procedure for Sponsored Project 50

8. Departure of Faculty Members Policy 54

9. Directly Charging Administrative Costs to Sponsored Research Policy 56

10. Eligibility Criteria for Submission of University Proposals Requesting External Sponsorship 60

11. Independent Contractor Policy and Procedures 61

12. Indirect Cost Recovery Policy 68

13. Intellectual Property Policy 39

14. Invention Disclosure Procedure 71

15. Property Management Manual

16. Sponsor Proposal Limitation Policy 72

17. Subcontracting Procedure 74

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I. INTRODUCTION

The purpose of the Sponsored Programs Handbook is to introduce faculty and staff at Worcester Polytechnic Institute (WPI) to the basic processes involved in obtaining external funding and administering the awards that result. It has been designed as a reference tool for those occasions where basic information about participating in sponsored program activities is needed by WPI employees. The Office of Sponsored Programs (OSP) is primarily responsible for assisting faculty and departmental staff in proposal submission and non-financial award administration activities. All proposals to be submitted to external sponsors should be routed through OSP. Corporate and Foundation Relations (C&FR) traditionally was responsible for non-research proposal review and maintaining relations with corporations and foundations. As of the date of this handbook, OSP is working with the newly-established Office of Corporate Engagement on projects involving the corporate and business sector, while continuing to coordinate with the Office of Foundation Giving on communication and relationships important to the submission of proposals to private foundations. Research Accounting is responsible for award set-up, budgeting, expenditure approvals, financial reporting, cash management, and other accounting functions for those sponsored programs not handled by C&FR. Suggestions to improve the services provided and the procedures utilized to provide them are encouraged, as are comments on the content of this handbook and the Sponsored Programs homepage.

OSP Contact Information:

Staff:

Kayla Carroll, Sponsored Programs Coordinator, Tel. 5359, E-mail: [email protected] Christina DeVries, Associate Director, Post-Award & Compliance, Tel. 6716, E-mail: [email protected]

Tammy Houle, Proposal Services Administrator, Tel. 5489, E-mail: [email protected] Franc Lemire, Director, Sponsored Programs, Tel. 5811, E-mail: [email protected]

Ted Russo, Associate Director, Pre-Award Services, Tel. 5586, E-mail: [email protected] Jeffrey Stokes, Proposal Services Administrator, Tel. 5235, E-mail: [email protected]

Office Location:

20 Trowbridge Road

The OSP facsimile number is 5789 and our office e-mail address is [email protected].

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II. SOURCES OF FUNDING 1. Identifying Funding Opportunities It is important to our success as a university participating in research and other sponsored endeavors that a proper match of faculty interests and funding opportunities take place. To this end, OSP makes available several resources, some of which are available by direct access via the Sponsored Programs homepage (www.wpi.edu/offices/osp.html), to assist faculty and others in identifying potential sources of funding. Visit the Funding Opportunities section of our web site to learn more about these resources, including: A. SPINPlus (Sponsored Programs Information Network), which is an online database of funding information that is updated regularly with new sponsor announcements. Contact OSP at extension 5359 to schedule a pre-search interview or to subscribe to either SMARTS (a database function to match investigator interests with funding opportunities and provide electronic notification when matches occur ) or GENIUS (a research interest database in which investigators can maintain their own profiles); B. The Grant Advisor Plus C. FEDBIZOPS (Federal Business Opportunities - Procurements) E. GrantsNet (Biomedical training opportunities) F. GRANTS.GOV G. In addition to the above resources, OSP regularly distributes funding opportunity information in either hard copy or electronic format and maintains a small library of recent funding announcements; 2. Contacting Sponsors Contacting a sponsor prior to submitting a formal proposal can be a positive step in building a relationship with that sponsor and learning about current research interests. An investigator may initiate this process by telephone, e-mail, office visit, or submission of a letter of intent or preliminary proposal (Note: Corporate and Foundation Relations may be contacted prior to making such initial contacts when the sponsor is to be a corporation or a foundation and the activity is non-research.). All contacts with sponsors by the above means are for information gathering purposes only. It is important to remember that representations that commit the University should not be made without the prior review and approval of OSP. If, as a result of an initial contact, a sponsor requests a letter of intent or a preliminary proposal, investigators should discuss these actions with department heads and/or other appropriate University officials. Letters of intent, proposal abstracts, and/or preliminary proposals can be reviewed by OSP for budgetary considerations, if such assistance is needed. An informational copy should be provided to OSP at time of submission to initiate the University's official file. 3. Adherence to Proposal Guidelines Providing potential sponsors with the information they need in the format they require is critical to the success of any proposal. Investigators should request copies of application kits and/or guidelines from these sponsors. If the sponsor does not have any specific proposal submission requirements, the proposal format in the following section can be used as a guide.


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OSP maintains a supply of guidelines for proposals to be submitted to the National Science Foundation (NSF) and the Department of Health and Human Services (DHHS). Some application kits are also available electronically by clicking on Proposal Toolkits on the Sponsored Programs homepage. Investigators should be aware that some government agencies are starting to require electronic submission of proposals, such as the National Science Foundation via the NSF FastLane website (www.fastlane.nsf.gov).


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III. PROPOSAL ACTIVITIES 1. Eligibility Determination If you are unsure whether are not you are eligible to submit proposals on behalf of WPI, please read the policy entitled, Eligibility Criteria for the Submission of Proposals for External Sponsorship, available in hard copy from OSP and on our web page. 2. Proposal Preparation - Components of a Proposal Some or all of the proposal components that follow are commonly used when a sponsor does not require a specific proposal format. Please use the appropriate sections indicated below for these situations. Templates for use in preparing certain proposal sections are available in electronic format on the Sponsored Programs homepage on the Proposal Toolkits page. If you are unsure which sections are necessary, contact OSP at extension 5359. A. Cover Page (also called Title Page) The cover page of a proposal should include the following minimum information: 1.) Title of the project 2.) Sponsor name and address 3.) Proposed project duration with start and end dates 4.) Amount Requested 5.) Submission Date 6.) Name(s), rank(s), and address(es) of the investigator(s) 7.) Signature of the investigator(s) 8.) Name, title, and contact information for the authorized WPI official 9.) Signature of the authorized WPI official B. Abstract or Project Summary The Abstract or Project Summary is used to describe the objectives, methodology, and significance of the project. It should be able to stand alone and not include references to other sections of the proposal. C. Introduction The introduction is used to reinforce the connection between sponsor and applicant interests. It should be interesting and brief and offer statistics and/or statements that support the credibility of the project area, lead logically into the problem statement, and emphasize anything unusual or unique about the research. D. Project Description The project description describes the approach to be used in the performance of the project and should convince reviewers that the methodology has been thoughtfully worked out and that success will result. A project timetable with reasonable expectations for completion of the project can also be included to support the idea that the proposal has been carefully planned.


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E. Bibliography A listing of references cited in the body of the proposal should be provided at the end of the narrative. F. Curriculum Vitae Curriculum Vitae for all key personnel should be included with every proposal to highlight their background, professional interests, research capabilities, and publications to date. G. Budget and Justification The budget included with a proposal should represent a reasonable estimate of what the costs will be during the life of the project. An annual budget should be included for each year of the project and should be supported by a budget justification that explains the need for the amounts requested. Multiple year budgets should include realistic increases for inflation of recurring expenses with the exception of fringe benefits and indirect costs. The elements of cost generally accepted in the submission of proposal budgets are indicated below. Please contact OSP for assistance in preparing budgets. 1.) Direct Costs a.) Salaries - Under this category should be shown only University personnel. For key personnel (individuals who will play a role in overseeing the project), list project roles and names. If an individual is not employed at WPI at the time the proposal is submitted, list the project role and TBN (to be named). Note that, if it is necessary to name an individual who is not yet a WPI employee, the budget must include a footnote that all appropriate Equal Employment Opportunity/Affirmative Action (EEO/AA) procedures will be followed if/when this person is hired. For faculty with regular nine month appointments, it should be stated whether the request for salary support is for the academic year or summer. Based upon 100% effort, WPI employees cannot be compensated at an amount which exceeds their currently authorized salary, plus the value of any increases during future years. Graduate students (Masters and Ph.D. candidates who will be devoting effort to the project as research assistants) are normally budgeted in accordance with the University's current stipend ranges. Undergraduate students are compensated on an hourly basis. For the latest graduate student stipend ranges, please refer to the current Proposal Preparation Reference Sheet (formerly Budget Notes) on the OSP web site. Hard copies of this document are also available in OSP. For proposals to the Federal government, secretarial/clerical/administrative support may only be requested under certain circumstances. Please contact OSP if you wish to include any of these salaries in a proposal budget or if there are any other questions regarding the inclusion of salaries in proposal budgets. b.) Fringe Benefits - Again, proposers should refer to the current Reference Sheet


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to determine the rate to use in calculating fringe benefits on the salaries of WPI faculty and staff only (fringe benefits are not charged on student stipends). c.) Materials and Supplies - This category can be defined as any consumable item, regardless of cost or any item having an acquisition cost per unit of less than $500 or any item with an estimated life expectancy of less than one (1) year. Examples include chemicals, gases, cryogenic liquids, piezo tubes, etc. that can be specifically identified with the project. Normal office supplies, such as paper, pencils, toner, CDs and the like should not be included as supplies in proposals to the Federal government. d.) Equipment - This category can be defined as any item with an estimated useful life of more than one (1) year and an acquisition cost of at least $500. Any equipment included in proposals should normally be research-specific (i.e., not general purpose equipment, such as office equipment and furnishings, refrigerators, computers, etc.). e.) Travel - Only the cost of travel for University personnel should be included as travel under this category. Identify foreign and domestic travel separately and include total estimated travel costs (e.g., airfare, registration fee, hotel, meals, etc.). Current Federal Per Diem Rates, available via the Research Administration homepage, may be used to estimate lodging, meals and other incidental expense amounts. Note: Dues or membership fees assessed as part of a conference or other meeting registration process are not travel and should be coded separately, as these are not normally allowable as a direct charge to Federal awards. f.) Consultants (Independent Contractors) - List each consultant to be engaged and the related service to be performed. Indicate the rate of reimbursement, which may include fee, travel, lodging, and other related expenses. Consultants must submit a letter of intent, which should be included in proposal submissions. A WPI Independent Contractor Policy is being developed and will soon be available via the Sponsored Programs homepage. g.) Subawards - Identify any organization that will be participating in the project and the amount of estimated cost. All prospective subawardees must submit a letter of intent, scope of work, budget, and a copy of the institutions' current indirect cost agreement. The letter of intent must be signed by an authorized official and indicate the willingness of the institution to participate in the program and negotiate an agreement with WPI. Normally, the letter of intent, scope of work, and budget will be appended to WPI's proposal. h.) Other Expenses - Any other expenses not included above should be identified in this section as necessary for the completion of the project, including tuition and health fees of graduate students, postage, publication costs, specialized service facility costs, copying, etc. 2.) Indirect Costs - WPI's policy for the submission of proposals to external sponsors provides for full reimbursement of indirect costs (now called Facilities and Administrative Costs by the federal government) using current rates as approved by the


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Federal government. Unless a sponsor limits or disallows reimbursement of indirect costs, all proposal budgets should include this item. Under the University's Negotiation Agreement with the Office of Naval Research (ONR), indirect costs can be calculated by multiplying modified total direct costs (MTDC) by the current indirect cost rate. The current indirect cost rate is included on the Proposal Preparation Reference Sheet, which is available on the OSP website. 3.) Cost Sharing or Matching - When cost sharing or matching is required by a sponsor or if it is to be voluntarily committed, commitments of expenses by WPI must be approved in advance by the Provost. Proposers should review the Policy and Procedures for Sponsored Programs Cost Sharing on our web page if there are any questions about committing cost sharing by WPI in budgets. Amounts of approved cost sharing should be indicated in the budget, if space is provided on the sponsor form, or in the budget justification section. Statements regarding cost sharing (approved or not) should not be included in the proposal Project Description where it may not be obvious to the OSP reviewer. Even if the OSP reviewer does not discover this cost sharing, the sponsor may require it if an award is made. H. Current and Pending Support Some sponsors require that investigators provide a listing for all key personnel of current (active) awards and pending support (proposals), showing the estimated level of effort devoted to each project. When this is a requirement, contact OSP for any assistance needed in preparing this page of the proposal. I. Facilities and Equipment (also called Resources and Environment) The WPI Computer Center, Gordon Library, individual investigator laboratories, and specific equipment available for a project are examples of qualified facilities and equipment that should be listed in this section when required by a sponsor. J. Appendices Each sponsor may have different policies on the inclusion of appendices with proposals. Review sponsor requirements to determine whether or not appendices are allowed, if necessary, for your proposal. 3. Proposal Submission Procedure

All proposals to be submitted to external sponsors require the prior approval of an authorized WPI official. The procedures below should always be followed to ensure adequate time for the complete review of all proposals submitted through the Office of Sponsored Programs and to avoid the possibility of missed deadlines. For proposals to be submitted to corporations and/or foundations, contact either OSP or the Corporate and Foundation Relations (C&FR) office first to determine which office is best suited to provide assistance to you. A. Timing - To ensure that your proposal is given a careful review for accuracy, completeness, and compliance with sponsor guidelines and University policies, a minimum of three (3) days


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lead time is required for all single institution hard copy and electronic proposals and a minimum of seven (7) days lead time is required for all proposals on which there is one or more collaborating institutions. Observing these lead time requirements will help ensure that your proposal can be reviewed and that any required modifications may be made in sufficient time to meet deadline dates (this is especially true for complex and/or electronically submitted proposals). B. Completeness - The more complete a proposal is before it is “delivered” to OSP for review, the quicker the review will be. Investigators should attempt to deliver proposals in a "ready to send" format to minimize the possibility that changes and/or additions to the proposal may need to be made. Faculty are encouraged to liaison with OSP prior to submitting proposals for review to discuss the proposal and bring any potential problems in completing it to light. C. Documentation - All proposals should be delivered with a completed and approved Proposal Coordination Form (PCF). This form is required so that OSP reviewers can verify departmental and other approvals, review for exceptional needs in connection with the project (e.g., hazardous wastes, use of animals or humans, support for a graduate student, etc.), and have a consistent format from which to enter data into the University's proposal database. Additional documentation (e.g., proposal cover letters/pages, conflict of interest forms for NIH and NSF proposals, institutional approval of cost sharing or matching, letters of support, subcontractor letter of intent, scope of work, and budget, etc.) should also be provided at time of proposal review to avoid any further delays in the process. D. Copies – For hard copy proposals, an original and one copy for OSP should be provided for review purposes. Often, as part of the review process, OSP staff will need to annotate various parts of the proposal. Providing a copy of the proposal facilitates the review without having to add time to the review process making copies. If the submitting department wants to receive a copy of the approved proposal, a second extra copy should be provided along with the original. When sufficient lead time in accordance with A. above has been provided and the sponsor to which a proposal is being submitted requires an original and three or less copies, OSP will offer the option of mailing the proposal. Electronic proposals should be completed and ready to review either three (3) or seven (7) days prior to the due date in accordance with A. above. E. Proposal Cover Letters - Because proposals are submitted by investigators with the approval of the University, cover letters should be created using department letterhead. If a cover or title page is not included with a proposal, the cover letter should also include a line on which the authorized official can indicate approval of the proposal on behalf of the University. F. Exceptions - Occasionally, situations will arise where the above procedures cannot be followed, usually because an initial contact with a sponsor has resulted in a request to the investigator for quick turnaround of a proposal. OSP will modify its procedures and provide the best and fastest service possible given the situation and approve a proposal provided it is complete and materially correct. Additional documentation may be required, though, after the proposal has been approved. 4. Required Reviews Federal regulations and University policies require that certain proposed activities receive the approval of University committees established for this purpose. If any of the following activities are planned, contact the appropriate University office to discuss the activity and complete the approval process:


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A. Use of Animals - Proposals involving the use of live vertebrate animals must be reviewed and approved by the Institutional Animal Care and Use Committee (IACUC). Contact with the Chair of this committee should be made prior to the submission of any proposals that include animal use. For more information on the use of animals in research, visit the IACUC web site (http://www.wpi.edu/offices/osp/iacuc.html). B. Use of Human Subjects - Proposals that include the use of human subjects must be reviewed and approved by the WPI Institutional Review Board (IRB). The approval process includes submission of a protocol to the IRB. Protocol approvals must be obtained by the earlier of 1.) the proposal submission date or 2.) the deadline date required by the sponsor. The requirement for protocol approves exists regardless of the source of funding (sponsored research, gifts, University funds, etc.). Contact should be made with the IRB Chair to review the process prior to completion and/or submission of a proposal. Please refer to the following website for more information (http://www.wpi.edu/offices/irb/). C. Bio-Safety - The Bio-Safety Committee must review all proposal and laboratory teaching efforts involving the use of recombinant DNA (which are not exempt from NIH guidelines), infectious agents, teratogens, mutagens, carcinogens, biohazards, hazardous waste, and radioactive material. Contact the Environment and Occupational Safety Manager in Plant Operations regarding the proposed use of any of these materials. For more information

regarding bio-safety issues, also visit the Environmental & Occupational Safety web site at (http://www.wpi.edu/offices/safety/).

D. Radiation Safety - Any proposals involving the purchase, use, and /or disposal of radioactive material and other sources of ionizing radiation or that involve the use of lasers and other non- ionizing sources of radiation must be reviewed by the Radiation Safety Committee. Contact the Environment and Occupational Safety Manager in Plant Operations regarding any proposed activities involving radiation. For more information regarding radiation safety

issues, also visit the Environmental & Occupational Safety web site located at (http://www.wpi.edu/offices/safety/radiation.html).

5. Sponsor Review Proposals submitted to potential sponsors that do not conform with required submission guidelines (e.g., page limitations, font characteristics, etc.) may not get past the initial sponsor screening process. It must be emphasized that sponsors are serious in their attempts to standardize the "look" of proposal submissions and a common cause of rejections is for non-compliance with these requirements. Once a proposal is determined to be eligible for programmatic review by a sponsor, it will proceed through one of the following processes, depending on the sponsor and the individual program review requirements. OSP staff can assist in determining the current status of a proposal during the review process. A. Peer Review - This type of review involves experts, generally faculty members from other institutions, in the appropriate field of study. Depending upon the size of the program, proposals may be sent to individual reviewers or the reviewers may gather to form a panel to review all proposals at the same time. B. Internal Review - The review process usually involves only program staff who work for a sponsor. Such reviews are most common in foundations and private industry.


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C. Other Reviews - Reviews may sometimes consist of site visits, administrative reviews and/or fiscal reviews, which are performed in addition to regular programmatic reviews. Such reviews can involve investigators and administrative staff of the proposing institution and contracting or program officers of the sponsor. 6. Negotiation and Acceptance Not all awards received by WPI are completely acceptable, as issued by sponsors. Frequently, it is necessary to enter into negotiations with sponsors, the purpose of which is to ensure that the University's interests are addressed. This process of negotiation commonly includes resolution of conflicts in award terms and conditions, scope of work, and budgets with the expected result being an award that is mutually acceptable to both the sponsor and WPI. If a sponsor contacts an investigator directly to discuss the program scope of work, the budget, or any other component of the project, OSP should be contacted and made aware of the discussions and any changes that need to be made. A primary negotiation point is the award amount. Should a sponsor wish to fund a program but insist that the amount of the award be reduced, consideration by the investigator needs to be given to whether or not the original scope of work can be completed with such a reduced funding level. Additionally, if a proposal included cost sharing and a sponsor recommends funding at a lower dollar amount than proposed, cost sharing should normally be reduced also. Once a negotiation is completed and an acceptable award document is received, OSP will sign the award on behalf of WPI and process it in accordance with sponsor instructions. Investigators are reminded that they are not authorized to sign agreements (contracts, grants, or cooperative agreements) of any kind on behalf of the University.


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IV. AWARD ACTIVITIES - RESEARCH ACCOUNTING 1. Account Creation Upon receipt and acceptance of an award, the Office of Sponsored Programs (OSP) notifies Research Accounting, which is responsible for assigning a fund number. OSP also forwards a copy of the award document and terms and conditions to the principal investigator (PI) and any co-PI's. Award funds are grouped by agency and type and are assigned fund numbers between 200XXX and 229XXX. The fund representing the award is established in accordance with the approved budget and sponsor terms and conditions. The approved budget is then created using account codes defined by WPI. Research Accounting sends a Notice of Award to the PI informing her/him of the fund code, organization code, and account codes used for the approved budget. It is the PI's responsibility to review this information for accuracy and to contact Research Accounting with any discrepancies or questions. The PI is also responsible for reading the terms and conditions of each award, ensuring that funds are expended in accordance with the award terms and conditions, and providing sponsor-required programmatic reports on a timely basis. 2. Interpreting Banner Financial Information - For more information, please refer to the Instructions for

Retrieving Sponsored Research Fund Balances in Banner at http://www.wpi.edu/Images/CMS/ACC/instructionsbanner.pdf.

A. How to Read a Research Fund Financial Report (FRRGITD) The Grant Inception to Date report (FRRGITD) is used to review the financial position of a Research fund for a period of time. The period of time is from the beginning of the Research Award (or 7/1/98 for awards beginning before that date) to the date specified when the report is run. It displays budget amendments, expenditures, and available balance for each line item. The columns of dollar amount on the report can be explained, as follows: The Adjusted Budget reflects the net total of the beginning budget balance plus or minus any budget changes that may have been done with the sponsor. The Current Period Activity shows by line item the current month activity of the fund. The Inception to Date Activity shows by line item the total charges and credits to the fund from the award begin date to the date specified when the report is run.

Commitments are expenses that are yet unspent for the current year. Salaries and wages scheduled to be paid to faculty and staff for the remainder of the fiscal year will appear in the column as well as the cost of benefits associated with these salaries and wages. Currently, WPI does not record purchase order or indirect costs commitments in Banner.

The Available Balance column is the difference by line item between budgeted amounts and expenses to date. The amount is calculated by taking the Adjusted Budget less Inception to Date Activity and known Commitments. If the line is a negative, this means the line has been overspent. B. How does Banner group and total account lines?


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In Banner, account lines are grouped by Revenue (codes beginning with the number 5), Labor (beginning with a 6), and Other Expenditures (beginning with a 7). The account codes used in the fund appear in the second column from the left of the report in ascending order. At the bottom of

the report are the totals for each group. (HINT: To get a total for the fund, read the revenue total line. See What is the Revenue Line? for more information.)

C. What is the Revenue Line? The Revenue line is the first account item on the report. This line does not represent the amount WPI has received or requested from the sponsor. That information is found on the Trial Balance (FGRTBAL) report for the fund. This line is a cumulative total of each line within the budget. The overall status of the fund can be seen by looking at the available balance of the Revenue Total line. If this amount is negative, then the award is overspent. D. What if my bottom line is negative? If the available balance in the Revenue Total line is negative, the award has been overspent. Steps will need to be taken to remove expenses from the fund. E. Other viewing options There are also on-line screens within Banner that display the same information. They are the Grant Inception to Date (FRIGITD) and Trial Balance (FGITBAL) screens. Each screen has key fields that must be completed for the query to run correctly. For the Grant Inception to Date screen, the required fields are Grant (code), Fund (code), and Orgn (code). For the Trial Balance screen, the required fields are Fiscal Year (FY) and Fund (code). For more information on these screens, please refer to the Banner User’s Guide at www.wpi.edu/Admin/Acc/Staff/. The information may also be obtained through a query via Banner Web for Employees. On-line help is available. A key to remember when viewing information for Research funds via the web is DO NOT check the Include Revenue box (refer to B above for explanation). 3. Budgets Financial budgets are created on the Banner system by Research Accounting in accordance with amounts awarded under sponsored programs. On awards requiring cost sharing by the University, budgets also include the amounts of funding to be provided by WPI. Principal investigators should adhere to approved budgets to the extent possible unless it has been determined under a particular award that expenditures may be made to other categories. Significant rebudgeting may constitute a change in the scope of work of a project and require prior approval of the sponsor. Please check with Research Accounting if a material change in the types of expenditures to be incurred is anticipated. 4. Expenditure Processing Recipient departments are responsible for incurring all appropriate direct cost expenditures to be charged against sponsored programs. By signing and transmitting expenditure documents to Research Accounting, the recipient department certifies that the expenditures are necessary for accomplishing award objectives and appropriate to the award being charged. A. Payment of Expenditures


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Research Accounting reviews and approves all expenditures charged to sponsored programs. It is the responsibility of Research Accounting to monitor expenditures to determine that they are allowable within sponsor guidelines, University policy, and, for Federal awards, government regulations (OMB Circular A-21, Cost Principles for Educational Institutions, Section J.). In addition, Research Accounting is responsible for verifying that sufficient funds are available and expenditures are incurred within the award period. However, it is the responsibility of the PI and recipient department to ensure that expenditures are allowable and appropriate. Questions concerning allowable costs should be directed to Research Accounting. B. Salaries, Wages, and Fringe Benefits Incurrence of expenditures for salaries and wages should be accomplished in accordance with current Human Resources policies and procedures. Payments should be processed on the

appropriate form(s), which are available either online at the Human Resources website at http://www.wpi.edu/Admin/HR.

Fringe benefits are charged as a percentage of non-student salaries based upon the currently negotiated fringe benefit rate. Current fringe benefit rate information is contained in the Proposal Preparation Reference Sheet (formerly Budget Notes), which is also available in hard copy from OSP and on our web site. C. Consultants A consultant (also known as an independent contractor) is an individual or organization capable of providing a service not available at WPI. Consultants are normally engaged for short periods of time to provide services that are not material in relation to the overall project scope of work. An Independent Contractor Policy has been developed and is in use until the policy is finalized (see draft on the OSP website at http://www.wpi.edu/Admin/OSP/Handbook/contractor.html. D. Travel There are a variety of important considerations that must be taken into account when traveling on sponsored programs, especially Federal funds, including: 1.) U.S. flag air carriers must be used for travel on Federal awards without consideration of cost, convenience, or personal preference. A Q&A that addresses exceptions to this regulation is

available at the website for the Office of Governmentwide Policy (http://policyworks.gov) by clicking on Travel Management and searching for "Fly America Act". Coach or economy class must be used in all cases.

2.) Depending on the sponsor and/or type of award (grant vs. contract), prior approval for foreign travel or changes to approved foreign travel may be required. The terms and conditions of the award to be charged should be consulted before undertaking foreign travel. 3.) Expenditures for alcoholic beverages are always unallowable as charges to Federal awards unless specifically approved in the award budget. Please refer to the WPI Business Services Manual for other issues and important procedures related to travel. When questions arise regarding travel on sponsored programs, please contact the Research Accounting office.

http://www.wpi.edu/Admin/HR�


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E. Subcontracting It is the responsibility of principal investigators to oversee subcontractor activities when subawards are made to other organizations under awards to the University. Invoices from subcontractors are forwarded for approval to principal investigators, who are in the best position to have knowledge of subcontractor progress relative to the reasonableness of invoice amounts. Questions about invoices from subawardees should be coordinated with Research Accounting. Upon approving, principal investigators should redirect subcontractor invoices to Research Accounting for final approval and payment processing. For more information please see the WPI Subcontractor Procedure located at http://www.wpi.edu/Admin/OSP/Handbook/subcontracting.html F. Indirect Costs Indirect costs (now called Facilities and Administrative Costs by the Federal government) are charged automatically on the Banner financial system based upon the appropriate base for direct costs and the awarded indirect cost rate. Questions regarding indirect costs charges on sponsored projects should be addressed to Research Accounting. G. Procurement When purchasing items (goods or services) with a total cost of at least $10,000, a WPI Purchase Order (PO) should be completed and forwarded to Research Accounting. Attached to each PO should be three (3) written bids or a sole source justification stating why a vendor has been selected in lieu of obtaining bids. This information is required under audit and ensures that procurements are made in a fair and competitive manner.

PIs and department administrative staff should contact the Property Administration Office (http://www.wpi.edu/Admin/Asset/index.html) prior to the purchase of any equipment.

H. Property Administration WPI 's Property Management Manual currently defines equipment as tangible, non-expendable personal property having a useful life of at least one (1) year and an acquisition cost of at least $500. Overall property management is achieved through the combined efforts of the principal investigator, the Property Administration office, and Research Accounting. Once received and accepted, equipment is tagged and inventoried in the property database. In accordance with OMB Circular A-110, Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, periodic physical inventories of equipment must be accomplished at least every two years. Please refer to the WPI Property Management Manual (http://www.wpi.edu/Admin/Asset/Manual/index.html) for further information. 5. Prior Approvals Often, events during the life cycle of an award can take place which require the need to request approval of a sponsor. These events can include not being able to complete the project on a timely basis, change in principal investigator, need for a significant rebudgeting of funds, and requests for supplemental funding. When such events occur, investigators should contact Sponsored Programs to determine an appropriate course of action. OSP staff are the primary contacts with sponsors for purposes of modifying awards. Depending upon the sponsor, OSP will either make the necessary contact at the sponsor or recommend that


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appropriate correspondence be sent to initiate the required action, including electronic requests via NSF's Fastlane (https://www.fastlane.nsf.gov/index.jsp). 6. Cost Transfers Cost transfers are occasionally needed to correct errors that may have occurred when the original charge was recorded. Cost transfers must be fully documented and approved by the principal investigator (PI). A department transfer form must be completed for non-payroll expenses within 90 days of the original transaction stating the reason for the transfer. This form contains the PI’s signature, the original account number, the account number to be charged, the amount, the purchase order or invoice number, and the date of original charge. Any payroll transfers must be accomplished using a Redistribution form or memo and processed through the payroll system. All cost transfers that occur more than 90 days after the original charge must also include a written justification for the delay of the transfer. The potential always exists for audit disallowance on cost transfers that are poorly documented and/or not completed in a timely manner. This should be considered when a transfer is proposed. 7. Time and Effort Reports The Federal Government requires recipients, of sponsored programs, to maintain time and effort performance reports that reflect effort levels by employees on sponsored programs. WPI has set up a semi-annual time and effort reporting system. It is the responsibility of the PI to review the percentage of effort on each report and indicate any discrepancies. The PI is required to sign the report in the space provided and return to Research Accounting. Research Accounting maintains copies of time and effort reports for use in audits of sponsored programs. 8. Sponsor Reporting Requirements All financial reports, including final financial closeout reports, are the responsibility of Research Accounting. All technical reports, including final technical reports, are the responsibility of the PI. A copy of the first page of all technical reports submitted to the sponsor should be sent to OSP and to Research Accounting. This copy should be marked with the date the report was mailed. Reports that are late in submission could lead to a potential problem with future funding and should be avoided, whenever possible. A. Financial Preparation of all financial reports, including final financial reports submitted at time of award closeout, is the responsibility of Research Accounting. Amounts included on these reports are derived from the Banner financial system based upon departmentally incurred expenses. Departments, therefore, are responsible for ensuring that amounts reported accurately reflect the expenses necessary to achieve project goals. B. Programmatic Principal investigators are responsible for the timely completion of all programmatic (technical, narrative, progress) reports required by the terms and conditions of sponsored program awards. It

should be noted that many sponsors, especially Federal sponsors, will possibly take action, up to and including curtailment of future awards and withholding payment to the University, for non-compliance with the reporting requirements of awards.


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C. Invention As periodically required by the terms and conditions of awards, Sponsored Programs will contact principal investigators to determine if any inventions were created or patents filed under specific awards. Sponsored Programs will then complete the appropriate reporting form and submit it to the sponsor. D. Property All property reports are completed by the Property Administration office in accordance with the terms and conditions of individual awards. E. Other Occasionally, additional reporting requirements will be included in sponsored program awards. In these instances, each situation will be handled on a case by case basis. 9. Award Closeout Many sponsors require that other administrative reports be submitted to officially close out an award. Research Accounting, in conjunction with Sponsored Programs, is responsible for submission of these reports (see 8. Sponsor Reporting Requirements above). These reports are generally due within 90 (ninety) days following the end date of the award. After 60 days, the fund is terminated in Banner. Once Research Accounting, along with the PI, completes the final expenditures for the award, the agency’s final report will be completed by Research Accounting and submitted by the due date.


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V. ISSUES IN SPONSORED PROGRAMS ADMINISTRATION There are many issues surrounding the administration of sponsored programs that need to be addressed on their own merit. Many of these issues are discussed. 1. Advance Accounts 2. Animals in Research 3. Audits 4. Compliance 5. Conflict of Interest 6. Cost Sharing 7. Equipment and Property 8. Export Controls 9. Freedom of Information Act (FOIA) 10. Hazardous Materials 11. Human Subjects 12. Incentive Funds 13. Independent Contractors 14. Indirect Costs (Facilities & Administrative Costs) 15. Insurance 16. Intellectual Property 17. Misconduct in Science 18. Pre-award Costs 19. Record Retention 20. Safety 21. Subrecipient Monitoring Advance Accounts Advance accounts are funds that are created on the Banner financial system prior to receipt of actual awards from external sponsors. These accounts represent a convenience to investigators for the purpose of initiating program activities. Use of advance accounts will be approved only when investigators can provide reasonable evidence from a sponsor that an award is imminent (e.g., notice from sponsor, e-mail from program officer).

Because of the additional risk involved with incurring program expenses prior to the receipt of awards, advance account requests must be approved by the appropriate department head. The Provost’s Office will determine the source of funds to be used in the event that an award does not materialize. Investigators who need to have an advance account created should use the "Institute Prior Approval System (IPAS)" form. Once completed and approved, the form containing original signatures should be forwarded to the Office of Sponsored Programs (OSP). Copies of any supporting correspondence from the sponsor should be attached to substantiate the request. Approved forms will be forwarded by OSP to Research Accounting for creation of a Banner fund and notification to both the investigator and OSP of the number created.

Questions regarding the establishment of advance accounts should be addressed to OSP.

http://www.wpi.edu/Images/CMS/ORA/IPAS_Form_Rev1.doc�


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Audits As a recipient of Federal and other sponsor funds, the University is subject to a variety of audits and reviews. the purpose of these activities is to provide evidence that proper stewardship of sponsor funds is in place. the two principal types of audits are:

1. Financial Statement Audit - this type of audit looks at the financial representations of the University's financial system and involves a thorough review of the University's official books of record, financial policies, accounting system transactions, and internal controls.

2. Compliance Audit - Office of Management and Budget (OMB) Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations, requires periodic review of the University's ability to comply with a total of fourteen different financial and other areas, as covered in various regulations. the compliance points covered under an A-133 audit are:

Issue Test(s) Performed

Activities allowed or unallowed Allocability of activities (e.g.,expenses)

Allowable costs/cost principles Allowability of expenses

Cash management Control over advances & interest income

Davis-Bacon Act Prevailing construction wage rates

Eligibility Who can participate and at what rate

Equipment and real property management Records management, inventory, and dispositions

Matching, level of effort, earmarking Achieved levels

Period of availability of Federal funds Obligations within award period

Procurement and suspension and debarment Conformance with laws, regulations, and OMB Circular A-110 standards

Program Income Adherence to usage requirements

Real property acquisition and relocation assistance

Acquisition, appraisal, negotiation, and relocation requirements followed

Reporting Timeliness, accuracy, and completeness

Subrecipient monitoring Identification, monitoring, and evaluation

Special tests and provisions Adherence to unique program requirements


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3. Other Audits and Reviews - Most sponsors reserve the right to undertake additional audits and reviews, which can include pre-award or post-award site visits covering programmatic and/or financial topics, property system reviews, small business utilization reviews, and reviews involving safety issues and animal and human subject usage.

Recipient departments often play a major or supporting role in audit activities by providing required documentation, facility tours, programmatic progress updates, etc. In the event such involvement by academic departments becomes necessary, appropriate prior contact will be made by the Office of Sponsored Programs and/or Research Accounting, whenever possible.

Compliance As a condition of accepting sponsor funds, the University must comply with a variety of award terms and, in the case of Federal funding, regulations that govern all awards. The concept of compliance begins with the presentation of a proposal and continues for as long as the University is willing to accept funding from external sources. Since all external funding must be accepted by and on behalf of the University, and not individual faculty members, it is the University's responsibility, through its faculty and other employees, to provide assurance to sponsors that all funds are accounted for and managed appropriately. Beyond the financial aspects of compliance are those that concern how the University manages its activities that are related to sponsored projects, including human subjects and animals used in research, among the many.

The subject of compliance is too complex to provide an adequate discussion of the many issues involved in this type of forum. Rather, what follows is a summary of compliance and management issues, as excerpted from Managing Externally Funded Programs at Colleges and Universities - A Guideline to Good Management Practices, published by the Council on Governmental Relations (CoGR) in May of 1998. The principles enunciated here (italicized and in bold print) highlight a variety of areas in which compliance and sound management of sponsor funds are critical to successfully discharging the University's obligations in accepting sponsored project funding. After each principle is stated, a brief summary is provided to indicate what the University must do in order to comply with the spirit of that principle.

Principle I. Fiscal Administration 1. Proposal Costing. The college or university has a proposal costing and budget administration

system which provides for consistency in preparation of proposal budgets to satisfy both internal procedures and external regulations. This principle requires that the University have written policies and procedures for proposal processing and budget administration which is disseminated at all levels of the institution and that proposals be prepared based upon consistently applied direct and indirect cost accounting practices.

2. Allowable Costs. The college or university has in place a financial control system that limits costs charged to accounts funded by a sponsor to costs allowable by that sponsor, in amounts that are properly allocable. Adherence to this principle requires written policies and procedures that define the allowability of costs in a manner consistent with the federal cost principles or other applicable standards of other sponsors. Further, the University must ensure the proper differentiation of costs allocable as either direct costs or indirect costs (now called facilities and administrative costs).


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3. Financial Accounting and Reporting. The college or university has an established financial management system that complies with federal, state, and institutional regulations and/or policies. The University must have written policies and procedures that guide its financial management of awards and an accounting system that provides for the identification and control of all extramural funding.

4. Cash Management. The college or university has a cash management system that complies with federal, internal, and, if necessary, state regulations and which provides adequate control and necessary flexibility to make timely deposits and disbursements of sponsored project funds. Critical to compliance with sound cash management practices are, a.) appropriate policies and procedures to receive and deposit all monies on a timely basis and to invest them when permitted in accordance with University policies and federal regulations and b.) policies and procedures to record the receipt of income and disbursement of cash, to invoice sponsors for receivables, and to report cash management activities to sponsors.

5. Effort Reporting and Cost Sharing. The college or university has effort reporting and cost sharing systems for personnel whose effort supports the organized research activities of the institution. These systems must comply with OMB Circulars A-21 and A-110. The University must have written policies and procedures for effort reporting and cost sharing which are consistently applied in proposing, accumulating, and reporting costs both to external sponsors and within the institution.

Principle II. Procurement The college or university has a procurement system for acquiring goods and services in a fair, competitive, and timely manner with special emphasis placed on acquisitions for research. Compliance with this principle requires, a.) a system of written policies and procedures for purchase of goods and services, b.) a written procurement system that meets the requirements of OMB Circular A-110, and contractor procurement system reviews, as applicable, c.) procedures to determine, prior to purchasing, that no unnecessarily duplicative equipment is available to meet project needs, d.) an expedited purchase option, and e.) policies and procedures for contracting and monitoring the performance of sub recipients.

Principle III. Property Management The college or university has a property management system capable of cont rolling both federal and non-federal property. Such a system must be guided by written policies and procedures that address property matters and include, a.) the ability to protect property in which the University has invested sponsored project funds, b.) a property inventory system, c.) capability to report property activities to external sponsors, and d.) capability of determining what inventory should be retained, salvaged, or disposed of.

Principle IV. Personnel The college or university has adequate staff to provide a personnel management program to enable it to accomplish its goals and objectives. This program provides safeguards to assure that the college or university complies with laws and regulations regarding recruiting, hiring, conditions and termination of employment. To effectively comply with this principle, the University must have written personnel policies and procedures that are available to all employees and which provide procedures for consistency in the


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recruiting, hiring, compensating, disciplining and terminating of employees. The University's personnel policies must also address regulatory issues, such as equal employment opportunity, nondiscrimination, prevention of sexual harassment, and drug and alcohol abuse.

Principle V. Audits The college or university has an audit management system which demonstrates that the institution is well-managed, in accordance with its own internal policies and federal regulations. The college or university's auditors and external auditors, under appropriate circumstances, have full access to the institution's records, properties, and personnel as those relate to any given subject under review. Compliance with this principle requires that the University has written policies and procedures for both its external independent audit and its internal audit responsibilities and procedures for recurring review of its finances, compliance with its administrative directives, and conformance with governmental laws and regulations. The University must also comply with government auditing requirements (e.g., (OMB Circular A-133) with respect to its federal programs.

Principle VI. Health, Safety, and Regulatory Compliance 1. Insurance (Risk Management). The college or university has risk financing mechanisms which

comply with federal and, where necessary, state regulations and provide a reasonable level of protection against unanticipated property loss and liability exposure. The University must have a system to identify and evaluate potential injury, property loss, and liability exposure and policies regarding the property loss and liability exposures that will be assumed internally and those that will be transferred. Also, the University must have a system for the management and resolution of liability claims, a record keeping system for its risk management programs, and, if self-insured, a system for responding to property loss and liability claims.

2. Human Subjects. The college or university has a system which complies with federal and, where necessary, state and local government regulations and with the requirements of non-federal sponsors to protect the rights, well-being, and personal privacy of human subjects in research. Compliance with this principle requires that:

A. the University has filed a written assurance with the Department of Health and Human Services and received approval in accordance with federal regulations;

B. the University provide for its investigators and other individuals identified in proposals as "key personnel" a formal education program in the use of human subjects in research;

C. the University has established at least one Institutional Review Board (IRB) in accordance with federal regulations to review, approve, require modifications in, or disapprove research activities involving humans as subjects;

D. if the University accepts research projects involving investigational new drugs (INDs), it has policies and mechanisms for handling such activities;

E. changes in policies and procedures are made in a timely manner and, where appropriate, communicated to the University community; and


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F. policies exist to notify appropriate personnel when emergency treatment of patients is required and to provide for such treatment, when necessary.

3. Animal Care. The college or university has a system to assure the existence of policies and procedures which comply with federal and, where necessary, state and local government regulations and with the requirements of non-federal sponsors to humanely, efficiently, effectively, and legally use live vertebrate animals in research covered by such regulations. Compliance with this principle requires that:

A. the University has filed a written assurance with the Department of Health and Human Services and received approval thereof, and has also received Department of Agriculture registration;

B. the University has established at least one Institutional Animal Care and Use Committee (IACUC) in accordance with federal regulations to review, approve, require modifications to, or disapprove activities involving animals used in research;

C. the University has programs and procedures for training and medical examination of scientists, animal technicians, and other individuals involved in animal care or use;

D. adequate systems are in place to track, report, and maintain compliance with the Animal Welfare Act and the Public Health Service (PHS) Good Laboratory Practices Guide.

4. Biohazards. The college or university has a system to assure the existence of policies and procedures which comply with federal and, where necessary, state and local government regulations and with requirements for the identification, classification, and control of biological hazards (biohazards) associated with research (including recombinant DNA). The University must have guidelines to specify the minimum training standards for personnel competence and procedures for the physical containment and proper handling of the various classes of biohazards. The University must also maintain a Biosafety Committee to establish standards, provide consultant services, review biological research proposals for compliance with standards, and recommend training and education methods for biohazard laboratory personnel. Finally, a procedure must be in place for review of sponsored project proposals prior to submission to an external sponsor or prior to project initiation when such proposals involve recombinant DNA research that is not exempt and/or include use of or exposure to potential biohazards.

5. Security. The college or university has a system to assure the existence of policies and/or programs concerning security for campus buildings, other college or university facilities, equipment and, if appropriate, classified materials. Compliance with this principle provides that the University have policies and procedures for the security of the buildings, grounds, facilities, and animals of the institution to provide protection from loss or disruption of University and/or sponsor investments in its research programs. Examples of these policies include a fire protection program, procedures for access to buildings and/or laboratories under specified conditions, and safeguarding classified and/or proprietary materials.

6. Health and Safety. The college or university is committed to providing a safe and healthy environment for its employees, faculty, students, and visitors. Evidence of compliance with this


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principle includes having written policies pertaining to institutional requirements for health and safety standards in the workplace, the ability to manage hazardous waste or radioactive material, an occupational safety and health program for faculty, staff, and students involved in research activities, and processes to evaluate, plan, and implement actions to comply with federal regulations (e.g., environmental, Americans with Disabilities Act).

Principle VII. Grant and Contract Management 1. Programmatic Performance. The college or university has a system to assure adequate

performance and reporting of performance of sponsored project activities. Compliance with this principle requires that the University have trained personnel who are knowledgeable of sponsor regulations, requirements, and procedures and policies and procedures regarding responsibility for preparation of and submission of required reports and other deliverables. Further, the University must have procedures regarding the provision notification of upcoming termination dates and other milestones for sponsored projects to appropriate academic and other internal offices and be able to assure performance and compliance with terms and conditions of its subrecipients and that subawards are appropriately closed out.

2. Prior Approvals. The college or university has a system for seeking required sponsor prior approvals and for reviewing and granting delegated prior approvals. The University must have policies and procedures by which prior approvals of sponsors may be requested, where required, and adequate records of all prior approvals requested and granted must be maintained. The University also must have procedures to provide for certification that requested cost transfers are timely, beneficial, project-related, and consistent with approved project objectives.

3. Agency Management Requirements. The college or university has a system to manage externally funded programs in accordance with the requirements of each sponsor. To comply with this principle, the University must have a system to gather appropriate sponsoring agency management requirements and to disseminate them to affected personnel. In addition, the University must have in place procedures to meet and document its cost sharing and matching requirements on awards and must communicate these procedures to appropriate institutional officials.

Principle VIII. Records Management The college or university has a records retention system for awards and related documents. The University must have procedures in place for the maintenance of records, documents, and other supporting evidence necessary to evaluate the effectiveness of management systems and internal procedures. In addition, the University must have policies regarding the retention of technical records, including data, pertaining to sponsored projects.

Principle IX. Intellectual Property The college or university has an intellectual property management system adequate to comply with terms and conditions of agreements with external sponsors and university policies, as well as with pertinent laws and regulations, including those of the federal government. To comply with this principle, the University's intellectual property management system must have the capability of properly dealing with patentable inventions, copyrightable works (including, but not limited to, scientific and technical writings, computer software, and technical data in any form), tangible research products over which control of distribution is


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maintained, and privileged data maintained as proprietary know-how, trade secrets, or confidential information, as permitted by institutional policy. Further, the University must have policies and procedures for obtaining sufficient rights in intellectual property to satisfy the requirements of agreements with external sponsors and for transferring these inventions to the marketplace.

Principle X. Research Ethics, Integrity, and Conflicts The college or university has policies that provide the means to comply with federal standards of accountability in maintaining the integrity of its research program. Such policies are made known to employees and subrecipients and set forth procedures for resolving questions concerning possible conflicts of interest, conflicts of commitment, procurement integrity and allegations of research misconduct. Compliance with this principle requires that:

A. the University must have written policies to assist employees in determining whether and to what extent outside public and private activities may conflict with their primary research and academic activities or other institutional responsibilities;

B. written policies and procedures must be in place for the purpose of identifying, managing, and resolving possible conflicts of interest;

C. the University must have written policies to guide the actions of employees involved in the preparation, submission, and negotiation of agreements with subrecipients;

D. the University must have written policies for promoting the design, conduct, and reporting of research and, where required by regulation, providing and subsequently assuring that appropriate training in ethics and research integrity is taking place; and

E. the University must have a written policy and procedure for resolving allegations of misconduct and/or fraud and abuse and protecting whistleblowers.

Principle XI. Electronic Research Administration The college or university has appropriate procedures in place to allow it to access and utilize electronic proposal, award, administrative, and financial management systems of the federal government and other sponsors. The University must have staff adequately trained to manage electronic research initiatives of the federal government and other sponsors as they are implemented and must be able to manage required financial matters electronically, when required.

Principle XII. General Management The college or university has a system to assure that it undertakes general management reviews in a timely manner and takes appropriate actions based on those reviews. Compliance with this principle requires that the University consider policies and practices related to the management of externally funded projects as a whole, i.e., integrated, rather than a series of individual, unrelated parts, and assigns priorities to these policies. The University must also perform a periodic review of its policies, practices, and procedures and make necessary revisions based upon changes in policies, rules, and regulations. Finally, the University must ensure that institutional policies and procedures are in written form and reflect the current management practices of the institution.


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Questions regarding the subject of compliance or any of the University's current policies and procedures related to sponsored projects may be addressed to the Office of Sponsored Programs (OSP).

Conflict of Interest In general, a conflict of interest exists when an academic staff member is or may be in a position to influence WPI business, research or other decisions in ways that could either lead to some type of personal gain for the academic staff member or her/his family or provide an inappropriate advantage to others to the detriment of the University. Similarly, a conflict of commitment can exist when the external or other activities of an academic staff member are so substantial or demanding of the staff member's time and attention as to interfere (or appear to interfere) with the individual's responsibilities to her/his department and/or students or to the University.

To ensure its continued commitment to the integrity of its faculty, students and staff in their conduct of research while achieving compliance with federal regulations, the University implemented the Conflict of Interest Policy in September of 1995. This policy provides, among other things, background information, definitions, and procedures for disclosure and review of real and perceived conflicts of interest. In addition, it provides for a certification process when submitting proposals to the National Science Foundation or the National Institutes of Health, as mandated by these federal agencies.

Investigators participating in research and/or other externally supported programs should familiarize themselves with the issues surrounding conflicts of interest to ensure that they understand when a conflict exists and how to eliminate or manage it.

Cost Sharing Cost sharing by colleges and universities on externally funded sponsored programs has long been a topic of discussion on many fronts. The reasons for this are many, and include, but are not limited to:

• the types of cost sharing (salaries, equipment, tuition, etc.),

• measurement of amounts (levels of effort, indirect costs associated with salary cost sharing, etc.),

• timing (expenses for cost sharing must be incurred within the awarded period of performance),

• allowability (is the cost sharing indicated on federal proposals allowable in accordance with government regulations), and

• appropriateness of cost sharing under different situations (mandatory vs. voluntary, limits, federal programs vs. corporations, etc.).

http://www.wpi.edu/Admin/OSP/Handbook/conflict.html�

http://www.wpi.edu/Admin/OSP/Handbook/conflict.html�


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WPI has developed the Policy and Procedures for Sponsored Project Cost Sharing in an effort to address some of the issues involved. Investigators are urged to review this document whenever cost sharing on a sponsored program is contemplated, either voluntarily or based on a program-specific requirement. An understanding of the issues in relation to the University's limited resources with which to support sponsored programs is critical to realistically estimating the levels of cost sharing that should be indicated on proposals to external sponsors.

Questions regarding cost sharing should be addressed to the Office of Sponsored Programs (OSP) by contacting extension 5359 or e-mailing [email protected].

Equipment and Property The procurement, use, and disposition of equipment and other property under sponsored projects is a shared responsibility between the user department and the Property Administration Office. When a WPI faculty member purchases an item of equipment, as currently defined in the University's Property Management Manual, proper accountability must be maintained throughout the useful life of this equipment so as to remain compliant with sponsor guidelines and/or Federal regulations.

As stated in the WPI Property Management Manual, the user department is responsible for completing all required property forms, maintaining accurate property status and communicating all activities (e.g., location and/or ownership changes, status changes, transfers), and maintaining copies of property inventory listings, forms, and purchase orders. Conversely, the Property Administration Office is responsible for keeping accurate records through its asset control procedures, ensuring compliance with Federal property regulations, non-Federal sponsor guidelines, and University policies, and assisting in the determination of minimum property liability insurance coverage. Through the combined efforts of user departments and the Property Administration Office, it is expected that all equipment purchased under sponsored projects will be effectively accounted for and managed.

The Research Accounting Office and the Office of Sponsored Programs (OSP) also play a role in this process. The Research Accounting Office provides information to the Property Administration Office so that a reconciliation may occur between the Banner financial system (actual equipment expenditures) and the property database (booked equipment purchases). OSP is involved by having responsibility for notifying the Property Administration Office of the requirements for equipment reporting, as required by individual award terms and conditions, sponsor guidelines, and/or Federal regulations. OSP also participates with the Property Administration Office and the Research Accounting Office in the close out of awards, which can include reporting of equipment purchased with sponsor funds and/or University cost sharing funds.

Questions regarding the allow ability of or the current amount of funds available for the purchase of equipment under sponsored projects should be addressed to the Research Accounting Office. For information on accountability (equipment tagging, inventories, and equipment reporting), contact the Property Administration Office.

http://www.wpi.edu/Admin/OSP/Handbook/costsharing.html�


http://www.wpi.edu/Admin/Asset/index.html�





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Export Control Laws & Regulations Probably by now, many of you are familiar with the term Export Controls. They are U.S. laws and regulations, implemented by three branches of the federal government. They essentially govern distribution of materials, information and technology to countries or citizens of foreign countries, including international students. These regulations apply to research and other activities regardless of the source of funding. The U.S. government considers this issue very serious and has created regulations across a broad spectrum. The exchange of technology, services and scientific information is viewed as having significant potential to disrupt U.S. foreign policy and national security.

It is important that WPI's research community understand the intent and do its best to comply with the letter and spirit of the regulations. A range of penalties and sanctions exist for individuals, and institutions, that do not comply with the regulations.

The best summary of government agencies with export control jurisdiction would include the following:

Department of State International Traffic in Arms Regulations (ITAR) regulates exchange and security of defense articles, services and related technical data determined inherently military in character and identified on the U.S. Munitions List. The very extensive list can be accessed at Directorate of Defense Trade Controls.

Department of Commerce Export Administration Regulations (EAR) regulates what are referred to as "dual use" articles, i.e., potentially commercial as well as military or security applications. (Navigation devices, information security, propulsion systems.....are just a few examples of "dual use" technologies.) Categories of such items are available at Export Administration Regulations Database. For a thorough description of Export Controls and Deemed Exports, the U.S. Department of Commerce, Bureau of Industry and Security has an excellent website which includes training modules for the Essentials of Export Control and more detail on the referenced Deemed Exports which can be found at the Bureau of Industry and Security Seminars and Training.

Department of Treasury Office of Foreign Assets Control (OFAC) administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals. These regulations are not directed at specific technologies but rather the "end user" embargo concept... certain foreign countries and suspected terrorists. Two websites relevant to the listing of targeted countries and potential terrorists are: Sanctions Program Summaries and SDN List.

Deemed Exports: Defined and Explained The Export Administration Regulations (EAR) define a deemed export as the release of technology of source code subject to the EAR to a foreign national in the United States. Such a release is deemed to be an export to the home country of the foreign national.

Any foreign national is subject to the deemed export rule except:

• A foreign national granted U.S. citizenship

• A foreign national granted permanent residence status (i.e., "Green Card" holders)

http://www.pmddtc.state.gov/�

http://www.pmddtc.state.gov/�

http://www.access.gpo.gov/bis/ear/ear_data.html�

http://www.bis.doc.gov/seminarsandtraining/seminar-training.htm�

http://www.treas.gov/offices/enforcement/ofac/programs/�

http://www.treas.gov/offices/enforcement/ofac/sdn/�


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• A foreign national granted status as a "protected individual" under 8 U.S.C. 1324b(a)(3). Protected individuals include political refugees and political asylum holders.

Treatment of Dual Citizenship is handled this way. Generally, a foreign national's most recently obtained citizenship governs the licensing requirement. For example, if an Indian foreign national becomes a citizen of the United Kingdom, but retains Indian citizenship, the most recent citizenship is with the United Kingdom and releases of technology would be viewed as releases to the United Kingdom. Permanent Residency is handled similarly, as the country of permanent residency becomes the country receiving the transfer of technology.

There are many ways that a deemed export can take place. Export controls will apply if a foreign national uses or has access to a controlled item for the following reasons: operation, installation, maintenance, repair, overhaul and refurbishing.

Situations that can involve release of U.S. technology or software include:

• Tours of laboratories

• Foreign national employees involved in certain research, development, and manufacturing activities

• Foreign students or scholars conducting research

• Hosting a foreign scientist

Researchers at Worcester Polytechnic Institute need to be aware of the implications of passing export controlled information on to a deemed export. As an institution that welcomes foreign collaboration, we must be vigilant in assuring compliance with Export Control laws and regulations. Many of the contract and grant agreements received by WPI contain specific references to the federal laws governing exports. In certain situations, foreign nationals may be precluded from participating on a research project or licensing by the Bureau of Industry and Security (BIS) may be required for participation.

Exclusions from Export Controls Public Domain Information Under both ITAR and EAR regulations, some information is automatically excluded from Export Controls. The exclusion is primarily for information (ITAR), including some forms of software (EAR) that is in the public domain and publicly accessible through:

• books, periodicals (hardcopy or electronic) and generally distributed media

• unrestricted subscriptions and websites that are free (or available for less than production/distribution costs)

• libraries

• patents or open (published) patent applications

• release at open conferences, seminars and trade shows


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Fundamental Research Research as defined below has exclusions applying to information (ITAR) and software (EAR) that:

• results from basic and applied science and engineering research conducted at an accredited institution of higher education located in the U.S.

• must be ordinarily published and shared broadly within the scientific community

• is not restricted for proprietary reasons or specific national security reasons (EAR) or subject to access and dissemination controls (ITAR)

Note: As explained in the referenced PowerPoint presentation, this exclusion is lost if a researcher inherits export controls from a sponsor and restricts participation in the research or access and disclosure of the results. Educational Information Exclusion Essentially both EAR and ITAR regulations exclude export controls for instructional content of curriculums for all students, including foreign nationals, that exists in general science, math and engineering principles commonly taught through courses, and associated teaching laboratories. Further, the courses must be listed in course catalogs of colleges and universities (ITAR/EAR). Summary Export Controls are a very extensive set of regulations. Their intent is clear and certainly their importance heightened by the political world environment since the terrorist attacks on September 11, 2001. As stated above, it is very important that WPI employees, especially its researchers, are familiar and comply as thoroughly as possible with export laws and regulations.

Resources In addition to the links to the Departments of State, Treasury and Commerce regarding ITAR and EAR regulations above, you should be aware of the following resources:

• Export Controls Training Presentation (PDF)- This training presentation provides an in-depth look at Export Controls and their role in university research. It also explores several case studies to illustrate the relevancy of Export Controls to research at WPI.

• Export Controls Decision Chart (PDF)– Use the questions in this flowchart to help you determine if your project is subject to export control regulations.

• Export Controls Compliance Review (PDF)- Answering the questions outlined here may help you determine if your project is subject to export control regulations.

• Visual Compliance Software - Accessed through ORA, this commercial software, developed by e-Customs, provides concise screening for export and deemed export countries, materials, equipment and technologies utilized in potential projects that may be subject to export control regulations. If you would like to know more about this software, please contact Christina DeVries in ORA.

• For more information about Export Controls, please contact any of the following individuals:

Export Control Laws Briefing (ppt)

http://www.wpi.edu/Images/CMS/ORA/WPI_Export_Control_Slides-web_training.pdf�

http://www.wpi.edu/Images/CMS/ORA/WPI_Export_Controls_Decision_Chart-web.pdf�

http://www.wpi.edu/Images/CMS/ORA/WPI_Export_Controls_Compliance_Review-web.pdf�

http://www.wpi.edu/Images/CMS/ORA/exportcontrollaw.pdf�


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Freedom of Information Act The Freedom of Information Act (FOIA) is a Federal regulation that provides a mechanism for interested outside parties to gain access to data created as a result of Federally funded activities. When Office of Management and Budget (OMB) Circular A-110 was revised in the October 8, 1999 issue of the Federal Register, the FOIA was incorporated such that universities, formerly exempt from the Act, are now being held more accountable to the general public.

The final version of the change to OMB Circular A-110 provides that the only data that may be requested are those that are related to findings by the Federal government in developing an agency action having the force and effect of law. The agency must have publicly and officially cited the findings in conjunction with its actions. Some types of data are specifically excluded, as follows: preliminary analyses, plans for future research, peer reviews, drafts of scientific papers, and certain communications with colleagues. Data are also excluded when their release would violate personal privacy (e.g., medical or other human subject information that could reveal an individual's identity) or commercially necessary confidentiality. The revisions to OMB Circular A-110 apply to data in connection with awards made after November 8, 1999 and to continuing awards renewed after that date.

Faculty should be aware that, as a non-governmental entity, the University is not required to respond to FOIA requests made directly by private parties. Only the Federal awarding agency may require research data and, then, only if a request for data has been made to the agency. Any requests by a Federal agency for University faculty or staff to supply research data under FOIA should be brought to the attention of the Director of Sponsored Programs, who will work with the individual faculty or staff member and the Academic Affairs Office to evaluate the request. The University's goal and only involvement in this process is to facilitate a review of the situation and inform the faculty or staff member of what obligation exists to supply the requested data while remaining compliant with the spirit of OMB Circular A-110.

The following excerpts from the October 8, 1999 Federal Register, are directly relevant to the above discussion:

.36 Intangible Property.

A. The Federal government has the right to:

1. Obtain, reproduce, publish, or otherwise use the data first produced under an award; and

2. Authorize others to receive, reproduce, publish, or otherwise use such data for Federal purposes.

B. In addition, in response to a Freedom of Information Act (FOIA) request for research data relating to published research findings produced under an award that were used by the Federal government in developing an agency action that has the force and effect of law, the Federal awarding agency shall request, and the recipient shall provide, with a reasonable time, the research data so that they can be made available to the public through the procedures established under the FOIA. If the


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Federal awarding agency obtains the research data solely in response to a FOIA request, the agency may charge the requester a reasonable fee equaling the full incremental cost of obtaining the research data. This fee should reflect costs incurred by the agency, the recipient, and applicable subrecipients. This fee is in addition to any fees the agency may assess under the FOIA (5 U.S.C. 552(a)(4)(A)).

C. The following definitions apply for purposes of paragraph (d) of this section:

1. Research data is defined as the recorded factual material commonly accepted in the scientific community as necessary to validate research findings, but not any of the following: preliminary analyses, drafts of scientific papers, plans for future research, peer reviews, or communications with colleagues. This "recorded" material excludes physical objects (e.g., laboratory samples). Research data also do not include:

A. Trade secrets, commercial information, materials necessary to be held confidential by a researcher until they are published, or similar information which is not protected under the law; and

B. Personnel and medical information and similar information, the disclosure of which would constitute a clearly unwarranted invasion of personal privacy, such as information that could be used to identify a particular person in a research study.

2. Published is defined as either when:

A. Research findings are published in a peer-reviewed scientific or technical journal; or

B. A Federal agency publicly and officially cites the research findings in support of an agency action that has the force and effect of law.

3. Used by the Federal government in developing an agency action that has the force and effect of law is defined as when an agency publicly and officially cites the research findings in support of an agency action that has the force and effect of law.

Questions regarding requests made by outside parties or Federal awarding agencies under the Freedom of Information Act should be addressed to the Office of Sponsored Programs.

Incentive Funds The term "incentive funds" describes a variety of different mechanisms used by colleges and universities to provide funding for particular institutional objectives. At Worcester Polytechnic Institute (WPI), there are currently three incentive funds available to faculty:

1. The Indirect Costs Incentive Fund provides a return to individual faculty members based upon their ability to generate sponsored project awards that include reimbursement of indirect costs. The purpose of this program is to acknowledge the successful efforts of WPI faculty by providing a


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source of additional revenue for valid research-related expenditures, both at the departmental and individual faculty member level.

2. Faculty Advancement in Research (FAR) funds are made available through an annual competition conducted by the Research Development Council (RDC). The FAR program was created to provide "seed" money to faculty members and research teams for the purpose of acquiring external funding of projects.

The Indirect Costs Incentive Fund is administered by Research Accounting, which issues credits to designated funds on a quarterly basis. The FAR funding mechanism is administered by the Office of Sponsored Programs (OSP).

More detailed information, guidelines and forms relating to these incentive programs are available by visiting the Internal Funding page of the OSP web site. Questions about the Indirect Costs Incentive Fund should be addressed to the Manager of Research Accounting, while questions regarding FAR funding may be addressed to the Director of Sponsored Programs.

Indirect Costs (Facilities & Administrative Costs) Indirect costs, now officially known as facilities and administrative costs, are those costs that are incurred by the University for common or joint objectives and which, therefore, cannot be easily or specifically identified with a particular project or objective. Examples of these costs include operation and maintenance, central administrative operations, and depreciation of buildings and equipment. These costs are all necessary and their obvious benefits flow to departments and individual sponsored projects but, because they cannot be allocated with ease or a high degree of accuracy, they are more efficiently charged as a rate based upon incurred costs on awards.

An example of the type of expenses that qualify as indirect costs is office supplies. Office supplies are used in both the administrative operations of the University and on externally funded projects. When office supply expense is incurred, it is usually impossible to determine with any degree of accuracy where these supplies will be used. Further, because of the relatively low cost of most typical office supply transactions, the effort it would take to track this expense and to allocate it among the many cost centers represented by sponsored project awards is not practical. The government has determined that this expense, along with many others, should be charged to the University's administrative cost centers as an administrative expense rather than allocating it as a direct cost to each sponsored project, except in unusual cases. The total of this expense, plus many others like it, contribute to the total amount claimed by the University in its "cost pools" (accounts used to accumulate indirect cost expenses), as illustrated later.

At Worcester Polytechnic Institute (WPI), an indirect cost calculation is normally prepared every two years to determine what the actual indirect cost rate will be. This calculation is then submitted to the Office of Naval Research (ONR) for its approval. Once a final rate is determined, ONR creates a document called a Negotiation Agreement in which it specifies what rate WPI is permitted to charge to its fully-funded Federal awards. WPI is now permitted to charge indirect costs as a percentage of modified total direct costs (MTDC) as its base, having migrated from its previous salaries and wage (S&W) base as of July 1, 2004. The MTDC

http://www.wpi.edu/Admin/OSP/Funding/internal.html�


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base is what is multiplied by WPI's indirect cost rate to determine the amount of indirect costs to be charged. It should be noted that, because the Federal government has "capped" certain expenses that comprise the indirect cost base, the University does not recover the full amount indirect costs incurred. This limitation makes it even more important to recover indirect costs at the federally approved rate on sponsored projects.

How Indirect Costs Are Calculated If the total direct costs of research at an institution covered by Office of Management and Budget (OMB) Circular A-21, Cost Principles for Educational Institutions do not exceed $10 million in a fiscal year, the Simplified Method (sometimes called the short-form method) may be used to calculate the institution's indirect cost rate. The calculation of indirect costs looks something like this:

Indirect Cost Rate =Indirect Costs of the University / MTDC Base of Direct Functions

The numerator in this calculation includes the following institutional expense categories, accumulated as "pools" of expenses:

General Administration and General Expenses - These expenses relate to the general administration and executive offices of the University. Student related costs, such as student administration, student activities, student aid, and scholarships, are excluded from this category.

Operations and Maintenance Expenses - This category includes all appropriate costs associated with WPI's physical plant and depreciation/use allowances of its assets.

Library Costs - The expenses in this category are those incurred for the University's library operations.

Departmental Administration - This expense is calculated as 20% of the salaries and expenses of academic and administrative department heads.

The denominator in this calculation includes the total of all the direct functions minus equipment, capital expenditures, patient care costs, tuition remission, rental costs, scholarships and fellowships, and the excess of any subcontract over $25,000.

The resulting indirect cost rate is a "research" rate, which should be applied to the modified total direct cost base of all research proposal and award budgets on which it is allowed. Reductions in the approved indirect cost rate should occur only when mandated by specific program restrictions or when approved in advance by the Provost.

Indirect costs is an issue that is widely misunderstood and often thought of as a tax on research when, in reality, it is simply a way that the University attempts to recover those costs that cannot readily be included in proposal and award budgets. Questions regarding the calculation of indirect costs or how they are charged to sponsored projects should be addressed to Research Accounting.


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Institute Prior Approval System (IPAS) As a recipient of federal funds, the University must have a system in place to administratively review requests for pre-award costs and no-cost extensions, when these are determined to be allowable. The “Institute Prior Approval System (IPAS)” form has been created to facilitate this process and document that a good faith effort to comply with federal requirements has been made.

Please use this form whenever there is a need for creating an advance account, incurring pre-award costs, and/or requesting additional time to complete a federally funded program.

Questions about the IPAS system should be addressed to OSP.

Intellectual Property Establishing rights to intellectual property (IP), such as inventions and copyrights, is important both to the University and the inventing party, regardless of whether the inventor is a faculty member, staff member, or student. The WPI Intellectual Property Policy was developed for the purpose of setting forth the rights and obligations of the University and its employees when intellectual property is created.

When the Office of Sponsored Programs (OSP) engages in negotiations with potential sponsors, the starting point for discussions is that WPI will own all intellectual property created under sponsored agreements. The basic reason for this position is that the University must retain control over the IP in order to ensure its continued use for research and educational purposes and maximize the potential financial return for both WPI and the inventor in accordance with the University's Intellectual Property Policy.

The University's rights to the intellectual property it creates is protected by law under most federally sponsored agreements. Such is not the case when dealing with industry. Many companies insist on owning any inventions created with the funds they provide because their sponsorship is viewed as a fee for service arrangement. When this happens, negotiations can become difficult and often result in either a lengthy delay in finalizing an agreement or having to decline funding all together. At a minimum, the University will insist on maintaining the ability to use the intellectual property for internal research and educational purposes, while retaining some financial interest in any royalties that may result.

If you are involved in sponsored programs, you are encouraged to familiarize yourself with the WPI Intellectual Property Policy so that you understand your rights and obligations as a University employee. The Invention Disclosure Procedure, which incorporates an online Invention Disclosure Form, should be followed whenever an invention is recognized.


http://www.wpi.edu/Pubs/Policies/intell.html�




http://www.wpi.edu/Admin/OSP/Handbook/invention.html�


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Pre-award Costs The concept of pre-award costs - allowing recipients to begin sponsored program spending prior to the receipt of an actual award - came about several years ago as a government effort to streamline the administration of its awards. The allowability of pre-award costs is determined by either 1.) Office of Management and Budget (OMB) Circular A-110 Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations (generally for grants and cooperative agreements), or 2.) individual contracting officer approvals on a case-by-case basis (federal contracts). The authorization of recipients to incur pre-award costs must be explicitly stated in the award document or incorporated by reference.

Pre-award costs provide the option to recipient institutions of not having to wait for the actual receipt of an award, which may be released later than expected for a variety of reasons. The only caveat to incurring pre-award costs is that, while pre-award may be allowed by the sponsor, the government will reimburse pre-award costs only in the event that an award is made and sufficient funding is made available. Until that time, pre-award costs are incurred at the risk of the institution. OMB Circular A-110 states in 25.(e)(1) that "All pre-award costs are incurred at the recipient's risk (i.e., the Federal awarding agency is under no obligation to reimburse such costs if for any reason the recipient does not receive an award or if the award is less than anticipated and inadequate to cover such costs)."

At Worcester Polytechnic Institute, authorization to incur pre-award costs may be requested using the "Institute Prior Approval System (IPAS)" Form. This form, when completed and authorized on behalf of the department, should be submitted to the Office of Sponsored Programs (OSP), together with available documentation supporting the expectation that an award will be forthcoming.

Questions regarding pre-award costs may be addressed to OSP.



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VI. POLICIES AND PROCEDURES Many of the following policies, procedures and forms related to sponsored programs. As more policies are completed, they will be posted. 1. Acceptance of Industrial and Other Private Support, Research Policy for 2. Access to and Retention of Data 3. Alcohol and Other Drugs, Policy on 4. Animal Care Policy and Procedures 5. Classified and Proprietary Research, Policy on 6. Conflict of Interest Procedures for Submission of Research Proposals to PHS and NSF Beginning October 1, 1995 7. Conflict of Interest Policy 8. Consulting Policy for WPI Faculty 9. Cost Sharing, Policy and Procedure for Sponsored Programs 10. Departure of Faculty Members, Policy on 11. Eligibility Criteria for Submission of University Proposals Requesting External Sponsorship 12. Fiscal Responsibility of Principal Investigators 13. Gifts Other Than Money (GOTM's), Policy on 14. Human Subjects Policy and Procedures 15. Independent Contractor Policy and Procedures 16. Indirect Cost Recovery, Policy on 17. Intellectual Property Policy 18. Materials Transfer, Policy on 19. Misconduct in Science, Policy on 20. Property Management Manual 21. Record Retention Policy 22 Responsible Conduct of Scholarship and Research, Policy on 23 Sponsor Proposal Limitation Policy 24 Subcontracting Policy 25 Travel Policy Access to and Retention of Data Background The University has a responsibility to ensure appropriate access to and required retention of research data created by its faculty, staff and students, especially data generated under externally sponsored programs. The need to effectively discharge this responsibility becomes apparent in light of recent interpretations of federal regulations and congressional inquiries regarding a variety of issues surrounding government support of research at colleges and universities, including instances of scientific misconduct.

The requirements of Section .53(a) of Office of Management and Budget (OMB) Circular A-110 (Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations) provide that financial records, supporting documents, statistical records, and all other records pertinent to an award "shall be retained by the institution". In an OMB letter dated April 11, 1994, the term "all other records pertinent to an award" is defined as encompassing all records that were produced in connection with the award, including laboratory data and primary data.


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Compliance with these requirements took on a whole new meaning with the incorporation into OMB Circular A-110 of key Freedom of Information Act (FOIA) provisions on October 8, 1999.

Definition of Data As used in this procedure, data means recorded information, regardless of form or the media in which it is recorded. The term includes computer software programs, computer databases (and documentation thereof) and data of a scientific or technical nature. The term does not include information incidental to award administration, such as financial or administrative data, cost or pricing information, or other management information. Scientific data includes, but is not limited to, materials contained in laboratory notebooks or other media, such as computer disks and machine printouts. Data also includes both intangible data (statistics, findings, conclusions, etc.) and tangible data (notebooks, printouts, etc.)

Responsibilities of Investigators Principal investigators must preserve and maintain the ability to document the results of research, both for the sake of assisting the University in meeting its scholarly and legal requirements as well as for the more traditional reasons of establishing priority for patentable items, publishing research results and manuscripts, etc. Principal investigators and other members of a research team considered to be "senior" to a project have an obligation to discuss the responsibilities for accurate data accumulation, management and retention with other members of the research team. Original data should always be maintained by the principal investigator(s), although copies of the data may be provided to student and other team members when it is feasible to do so.

When an investigator leaves the University, s/he must recognize the University's need to have access to the data. While it is not desirable for the original research records to remain with the University, departing investigators have an obligation to hold these data in trust for the University and that such data must be returned to the University upon request during the three (3) year period following submission of the final programmatic report to the sponsor of the project under which the data were collected. The only exception is when a longer retention period is required by an external sponsor.

Procedure Research data created while individuals are pursuing research activities as faculty, staff or students of Worcester Polytechnic Institute (and data created by visiting scientists utilizing the facilities of the University) are to be retained by the University for a period of three (3) years after submission of the final programmatic report on the research project for which the data were collected, unless a longer retention period is required by the sponsor.

Such original research data shall be maintained and stored in the custody of the principal (senior) investigator on behalf of the University, but must be provided to the University upon request by the Provost or Associate Provost. Such data must also be made available to representatives of external sponsors of the research project or designated governmental officials, when such access is appropriate. Data collected under government-funded projects should not be provided to non-University entities (individuals, corporations, or other organizations) requesting casual access to this data under the provisions of the Freedom of Information

http://www.wpi.edu/Admin/OSP/Handbook/freedom.html�


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Act (FOIA). Instead, requestors of data should be referred to the FOIA office of the federal sponsor that provided funding for the project.

All research data must be maintained in its original condition and must not be destroyed or altered during the time period referenced above unless such action is specifically approved in writing by the Provost of Associate Provost.

Questions For further information regarding access to and retention of data, please contact the Office of Sponsored Programs.

Procedure to Minimize the Time Between Expenditures and Receipt of Funds A. Overview

As required by OMB Circular A-110 Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, this procedure was developed to ensure that the University requests only the necessary amount of cash needed to cover actual expenditures and to do so as soon as possible after expenditures are processed. To accomplish this, the processes for expenditure recognition and requesting cash must be aligned in such a way that a minimum amount of time elapses between the date(s) on which expenditures are incurred and the date(s) of cash requests. This procedure aims to provide, within the inherent limitations of both federal sponsor systems and the University's system, a framework for meeting the cash management needs of each party.

B. Recognizing Actual Cash Needs Depending upon the sponsor type and method of payment, the Research Accounting Office reviews expenditures/cash balances at least monthly to determine which actual expenditure amounts can be invoiced. In the case of advance payments, as required under certain awards from the Air Force, estimates of minimum cash needs are made based on the projected expenditure rate information contained in the original proposal.

C. Timing of Cash Requests Worcester Polytechnic Institute invoices and/or draws down cash for awards only after expenditures have been incurred and based upon actual cash balances represented in the Banner system. The timing of cash requests is in accordance with the availability of financial data from Banner. Immediately upon receipt of accounting reports (or as soon thereafter as practicable), Research Accounting staff complete the required forms and/or electronic processes to perform the cash request function. In the case of wire transfers, Research Accounting completes cash receipt forms and enters online all cash receipts supported by bank account statements. Upon notification of receipt of hard copy payments, checks are deposited with the University Cashier's Office, in most cases, the same day as received.

http://www.wpi.edu/Admin/OSP/Services/staff.html�

http://www.wpi.edu/Admin/OSP/Services/staff.html�


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Conflict of Interest Policy Endorsed by the Faculty and Recommended for Adoption by the Board of Trustees, March 20, 2003

I have read all this, and would like to skip to the forms.

Preamble Worcester Polytechnic Institute promulgates this Conflict of Interest policy to assure its constituents of its continued commitment to the integrity of its students, faculty, staff, and associates in the conduct of research and other activities.

Universities have long recognized the importance of maintaining policies on conflict of interest. In 1964, the American Association of University Professors and the American Council on Education issued a joint statement On Preventing Conflicts of Interest in Government-Sponsored Research at Universities. This was followed in 1978 when the Association of American Universities, the ACE, and the National Association of State Universities and Land-Grant Colleges published Principles to Govern College and University Compensation: Policies for Faculty Engaged in Sponsored Research. In 1985, the AAU issued a report entitled University Policies on Conflict of Interest and Delay of Publication. Additional statements and reports have been published by the Association of American Medical Colleges, Guidelines for Dealing with Faculty Conflicts of Commitment and Conflicts of Interest in Research (1990), the AAU, Framework Document for Managing Financial Conflicts of Interest (1993), and the Association of Academic Health Centers.

Both the National Science Foundation (NSF) and the Public Health Service (PHS) require principal investigators and co-principal investigators "to certify that they have read and understood the institution's conflict of interest policy," that they have made all required financial disclosures, and that "they will comply with any conditions or restrictions imposed by the institution to manage, reduce, or eliminate actual or potential conflicts of interest." Moreover, the University's representative must certify that the University "has implemented and is enforcing a written policy on conflicts of interest," that all financial disclosures required by the conflict of interest policy were made, and that actual or potential conflicts of interests, if any, were, or prior to expenditure of funds under the award, will be satisfactorily managed, reduced or eliminated in accordance with the institution's conflict of interest policy, or disclosed to PHS or NSF.

In its Notice No. 117 dated June 30, 1994 and updated in its Notice No. 118 dated July 13, 1995 on the subject of Investigator Financial Disclosure Policy, the National Science Foundation requires that all grantee institutions employing more than fifty persons have in effect on October 1, 1995 a written and enforced conflict of interest policy. In addition, the Department of Health and Human Services published its final rule on "Objectivity in Research" on July 11, 1995 in the Federal Register (60 Fed. Reg. 35820) to coincide in effective date and requirements with NSF's Financial Disclosure Policy. As the NSF Notice states:

http://www.wpi.edu/Admin/OSP/Handbook/conflict.html#bottom�


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The National Science Foundation encourages the increased involvement of academic researchers and educators with industry and private entrepreneurial ventures. But NSF recognizes that such interactions carry with them an increased risk of conflict of interests. The Public Health Service (PHS) wishes to assure the public that its support to researchers will follow standards and procedures

to ensure that the design, conduct, or reporting of research funded under ...[its] grants, cooperative agreements or contracts will not be biased by any conflicting financial interest of those investigators responsible for the research. Policy Rationale Funding sources and personal gain represent two aspects about which investigators must be ever mindful, because without clear guidelines there is a possibility for conflict of interest issues to arise. Donors, for example, providing grants to conduct research may sometimes possess a vested or proprietary interest in the research results. Professors themselves may hold equity positions or policy making authority in an enterprise from which they would benefit personally by research sponsored by the enterprise, a government, or other private agency, and that is conducted using university facilities, equipment, or personnel.

In addition, there are large numbers of other types of funded and unfunded interactions between WPI faculty members and government, industry and other non-University organizations through research, projects and consulting.

With the increased national emphasis on technology transfer and economic competitiveness, it is particularly timely for Worcester Polytechnic Institute to articulate a new conflict of interest policy to protect the integrity of the University, its faculty, and the research process, to encourage the free flow of knowledge and ideas, and to ensure that public and institutional resources are used appropriately.

WPI's conflict of interest policy now requires annual disclosure by all faculty and other personnel associated with the university (listed in Appendix D).

Disclosure Rationale and Procedure For all University personnel to maintain public trust, disclosure of all conflicts and potential conflicts of interest is appropriate practice. Based upon the traditions of university life there are two pillars on which to construct a conflict of interest policy.

One pillar of the academy is peer review. Some matters of peer review are handled confidentially; for example, senior faculty routinely review junior colleagues for appointment, re-appointment, promotion, and tenure. Other peer reviews are more open. Faculty committees review courses to be included in the college curriculum, and pass on degree requirements and other issues of academic policy. Peer review is essential, then, for a conflict of interest policy. Another pillar of the academy is disclosure of discoveries and other scholarly accomplishments. Indeed, peer review cannot occur without prior disclosure. When faculty publish their research, they are disclosing their findings to peers not only within the University, but to all scholars throughout the world. Disclosure is also essential for a conflict of interest policy. Indeed, NSF's


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Investigator Financial Disclosure Policy requires "a) limited and targeted financial disclosure, b) designation of a person(s) to review the disclosures and resolve actual or potential problems revealed, c) enforcement mechanisms, and d) arrangements for informing NSF of conflict issues that are not resolved to the satisfaction of the institution."

In addition, NSF and PHS require that an institution's policy provide for disclosure prior to submitting a proposal, and that all actual or potential conflicts be satisfactorily managed, reduced, or eliminated prior to the time funds from an award are expended, or disclosed to NSF or PHS. In addition, both NSF and PHS require that, during the period of any award, the University obtain updated financial disclosures from investigators either on an annual basis or as investigators obtain new reportable financial interests.

Disclosure Process How and to whom should the significant financial interest(s) of a faculty member and/or investigator be disclosed?

On or before October 1 annually or within sixty (60) days of appointment, each faculty member and other individuals identified in Appendix D shall complete and submit a Conflict of Interest Disclosure Form to his/her Department Head.

WPI policy requires Principal Investigators to complete a Proposal Coordination Form (see Appendix A) at the time the Principal Investigator submits the proposal for review and authorization by the Office of Sponsored Programs. This form includes check boxes in which the respondent shall indicate whether or not a conflict of interest exists or is likely to exist in connection with the proposal being submitted. Co-investigators and any other individuals who are expected to participate in the design, conduct, and/or reporting of the research also must complete a Conflict of Interest Disclosure Form (see Conflict of Interest Disclosure for NSF and PHS Submissions, Appendix B) concurrent with submission of the Proposal Coordination Form by the Principal Investigator, unless they have done so as a required annual disclosure. Principal Investigators will have filed the Annual Conflict of Interest Disclosure Form, Appendix C, as required.

Investigators submitting a human subjects protocol for Institutional Review Board (IRB) review must file or have on file a Conflict of Interest Disclosure Form, Appendix B, at that time.

Any Disclosure Statements, whether submitted in satisfaction of the NSF or PHS proposal submission requirement or in fulfillment of the WPI annual disclosure requirement or IRB disclosure requirement, must be updated when a new reportable Significant Financial Interest or potential conflict of interest exists.

Annual Review Process All faculty members and other individuals, identified in Appendix D, who have not, within the last year, completed the Conflict of Interest Disclosure Form for funded research associated with an NSF or PHS submission (Appendix B) must file the Annual Conflict of Interest Disclosure Statement contained in Appendix C with his/her Department Head annually by October 1 and as any significant changes occur.


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Department Heads will file their Annual Disclosure Statements with the Vice President for Research. The individual shall, to the best of his/her knowledge, include in his/her Disclosure Statement the same information for his/her family, as defined by this Policy. Department Heads and members of the Cabinet will file with the Vice President of Research. The Vice President of Research will file his/her Annual Conflict of Interest Disclosure Form with the Provost.

Upon receipt of each annual or updated Disclosure Statement, the Department Head or his/her designee will make a review for adequacy, requesting additional information, as necessary. If the answers to the four questions on Part I of the Disclosure Statement are "no," then no further review is required. The Disclosure Statement should be transmitted to the Office of Sponsored Programs, the central repository for all Disclosure Statements. No additional action will be required of the faculty member or other submitter unless a significant change occurs prior to the next annual due date. If the answer to any of the four questions on Part I of the Annual Conflict of Interest Disclosure Form is "yes", the Department Head will determine if a real or apparent conflict appears to be significant. If so, the Department Head will forward the disclosure to the Vice President for Research with a copy to the Office of Sponsored Programs. The Vice President for Research will gather further information and supporting documentation from the individual and will bring the Disclosure Statement to the attention of the Conflict Management Committee for resolution. All such documentation and subsequent discussions will be confidential. The individual will have an opportunity to meet with the Conflict Management Committee to explain the financial documentation and to discuss options for management of the conflict. Should the findings indicate significant potential conflict of interest, the Conflict Management Committee will consult with the faculty member or other submitter to devise a plan to effectively eliminate, reduce, or otherwise manage the conflict. If the Committee cannot come to an agreement with the individual and concludes that a significant conflict of interest to WPI's interests appears to remain, the Committee will refer the matter to the Office of the Provost and so inform the individual.

Review Process for NSF and PHS Proposals Should a disclosure associated with any NSF or PHS submission indicate a potential or actual conflict of interest, the Director of Sponsored Programs will advise the Vice President for Research. The Vice President for Research will gather further information and supporting documentation from the investigator and take the matter to the Conflict Management Committee for resolution. All such documentation and subsequent discussions will be confidential. The investigator will have an opportunity to meet with the Conflict Management Committee to explain the financial documentation and to discuss possible conditions or restrictions. Should the findings indicate significant financial interest, the Conflict Management Committee will impose conditions or restrictions to effectively manage, reduce, or eliminate the conflicts. The Conflict Management Committee will use as guidelines this policy statement including the definitions of significant financial interest and conditions or restrictions found in the section of Definitions.

If the Conflict Management Committee determines that imposing conditions or restrictions would be either ineffective or inequitable, and that the potential negative impacts that may arise from a significant financial interest are outweighed by interests of scientific progress, technology transfer, or the public health and welfare, then the Conflict Management Committee may recommend to the Vice President for Research that


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the research be permitted to go forward without imposing such conditions or restrictions. In such cases, the conflict of interest of the investigator(s) will be disclosed to the government agency as required.

Appeal Process for NSF and PHS Proposals Should the faculty member or other individual (as defined in Appendix D) not agree with the Conflict Management Committee's conditions or restrictions, he/she can appeal in writing to the Provost within ten (10) days after receipt of notification from the Vice President for Research, spelling out why such conditions and restrictions are inappropriate. The Provost will then consult with the Conflict Management Committee; it is possible that a modification of the conditions and restrictions will be agreeable to all parties. However, the decision of the Provost is final.

Human Subject Protocols Disclosures associated with the submissions of protocols for IRB review will be reviewed following the same process as for NSF and PHS proposals. Protocols will not be approved until all conflicts are resolved.

Definitions Conflict of Interest

A conflict of interest may take various forms but arises when an individual is or may be in a position to influence University business, research, or other decisions in ways that could lead to any form of personal gain for the individual or his/her family, or give improper advantage to others. A real or perceived conflict of interest may also arise when someone engages in an action or decision that compromises the integrity of teaching, research, advising, or scholarship.

Family The family of a faculty member means spouse, minor children, and other persons financially dependent upon the faculty member.

Investigator The term investigator means the principal investigator, co-principal investigators, and any other person at the institution who is responsible for the design, conduct, or reporting of research or educational activities.

Relationships which can give rise to conflicts of interest Relationships as used in this policy include relationships with others which can give rise to real or perceived conflicts of interest. These include, among others, personal relationships created by kinship, friendship, or professional contacts, and financial relationships created by contracts, shared property rights, or state or Federal law. Though a domestic partnership may create a real or perceived conflict of interest, this policy is not meant to force disclosure of one's sexual orientation. By policy, WPI does not discriminate on the basis of sexual orientation.

Significant Financial Interest The term significant financial interest means anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interests (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights) when related to the subject matter of the individual's research and/or scholarly activities, including teaching and advising. The term does not include:

• salary, royalties or other remuneration from the University;


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• income from service on advisory committees or review panels for public or nonprofit entities;

• financial interests in business enterprises or entities if the value of such interests does not exceed $10,000 or does not represent more than a 5% ownership interest for any one enterprise or entity when aggregated for the investigator and the investigator's family;

• royalties or other payments that, when aggregated for the investigator, and the investigator's family, are not expected to exceed $10,000 during the next twelve-month period;

• income from self-authored textbooks, software, etc. that are used for your teaching purposes; or

• project fees solicited from sponsors of MQP's and IQP's that are returned to Faculty professional development accounts.

A significant financial interest becomes a conflict of interest if it could result in personal gain, advantage to others to the detriment of WPI, or influence the outcomes of research.

Conditions or Restrictions Examples of conditions or restrictions that might be imposed to manage, reduce or eliminate actual or potential conflicts of interest include:

• public disclosure of significant financial interests; • monitoring of funded research by independent reviewers; • modification of the funded research plan; • disqualification from participation in the portion of the NSF-or PHS-funded research that

would be affected by the significant financial interests; • divestiture of significant financial interests; or • severance of relationships that create actual or potential conflicts.

Institutional Review Board (IRB) Any boards established or contracted to review protocols for human subjects research whether federally funded or not.

Conflict Management Committee Conflict Management Committee membership shall consist of a faculty member selected annually by the Committee on Governance (COG) to chair the committee, the Chair of the Committee on Graduate Studies and Research, an additional member selected by CGSR, the Vice President for Research, and the Director of Sponsored Programs. COG shall also annually appoint an alternate to the Committee to serve in the event of the recusal or absence of one of the other appointed faculty members. In the event that more than one alternate is needed, COG shall appoint additional alternates as necessary. Recusal shall be required when it appears that a member of the Conflict Management Committee will be unable to fairly judge a potential conflict raised by a disclosure statement. All such potential conflicts of interest of committee members must be disclosed to the committee in advance of the proceedings, and the committee will vote to determine whether recusal is required. To prevent the appearance of bias in judgment, the committee shall follow the practices that the Committee on Tenure and Academic Freedom uses to determine whether tenure committee members are able to fairly judge candidates for tenure.


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Instructions To comply with this policy regarding the submission of an annual Disclosure Statement, each Faculty Member must complete the Disclosure form and any updates on or before October 1 of each year and forward it to his/her department head.

In addition, to comply with this policy regarding authorization for the submission of a proposal for funded research to the NSF and/or PHS, a principal investigator will

1. in accordance with the Explanation and Instructions, complete and sign the front side of the Proposal Coordination Form and require any co-investigators and/or other key personnel to complete and submit a Conflict of Interest Disclosure Form for funded research, Appendix B, (unless already submitted).

2. ask his/her department head to review and complete the Proposal Coordination Form and any accompanying Conflict of Interest Disclosure Forms and sign them.

3. submit the Proposal Coordination Form and accompanying Conflict of Interest Disclosure Form together with the NSF or PHS proposal to the Office of Sponsored Programs when requesting submission authorization.

(Revised January 30, 2003)

Appendices • Appendix A - WPI Proposal Coordination Form (PDF)

• Appendix B - Conflict of Interest Disclosure for NSF and PHS Submissions (PDF)

• Appendix C - Annual Conflict of Interest Disclosure (PDF)

• Appendix D - Individuals Who Must Sign Disclosure

Policy and Procedures for Sponsored Program Cost Sharing Summary WPI will consider cost sharing requests if and only if cost sharing is a mandatory requirement of the program announcement. Requests will be considered in the context of the overall direction in which WPI wants to grow. PI's must request and justify cost sharing needs with a detailed budget indicating the yearly cost sharing request, a matriculation schedule if graduate student support is involved, and a statement from the Department Head or Center Director that the proposed work is in an important area for WPI support. Departments should show their support by committing discretionary department resources from restricted accounts whenever possible. Every effort should be made to meet cost sharing requests using in-kind contributions. Cost sharing commitments require the written approval of the Provost and requests must be submitted at least one week prior to the proposal due date.

Introduction The efforts of Worcester Polytechnic Institute (WPI) faculty to obtain external funding for their research and other scholarly efforts are supported and encouraged by the University. Typically, cost sharing has been

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encouraged as a means to increase the chances of having a proposal funded by showing a financial commitment by the institution towards the project. More recently, sponsors are requiring institutional cost sharing so that limited available funds may be allocated to a broader recipient base.

It is critical that the impact on the institution of cost sharing be understood because the incurrence of cost sharing expenditures increases the overall cost of research and other activities, thus reducing the availability of University funds for other worthwhile initiatives. Cost sharing commitments mandated by external sponsors will be approved only when it is in the best interest of the University to do so (i.e., when the University would consider investing in a program or project even if no external support were available). In the case of cost sharing that is "volunteered," (i.e., not required by a potential sponsor), approval will be granted on an exception basis only, after a compelling argument has been made in favor of making such a commitment. In this document, the policy of WPI regarding cost sharing and procedures for securing cost sharing approval by the institution will be explained for all types of cost sharing.

Definitions Cost Sharing

Cost sharing is defined by the Federal Government in OMB Circular A-110, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, as follows: "Cost sharing or matching means that portion of project or program costs not borne by the Federal Government." There are two forms of cost sharing which can be defined, as follows:

Mandatory required contribution by the institution in response to a requirement stated in a program announcement or solicitation (e.g., Request for Proposal) and/or which is specifically communicated to the institution via the award instrument used by a sponsor;

Voluntary a contribution by the institution in support of a research or other program that is not otherwise required by the sponsor.

Matching Matching is most commonly defined as being an institutional contribution for equipment programs, specialized research centers, or when the institution is required to "match" sponsor funding in a specific dollar proportion (e.g., one-for-one). The definition of matching is often expanded to include funds contributed to the project by external sources (third party). Normally, a sponsor will state in its program literature what it considers to be considered appropriate funding for matching purposes.

In-Kind Contributions (non-cash) In-kind contributions are those that involve the value of equipment, services, or other costs, which are "donated" to the project free of charge. Examples could include the time donated by volunteers working on a project or a computer donated by either the institution or an external organization. The value connected with these in-kind contributions normally will be the fair market as of the date a proposal is submitted.


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Cost Sharing Considerations The following generally accepted guidelines for providing cost sharing for sponsored programs should be followed in the completion of proposals and the subsequent administration of awards:

1. When mandatory cost sharing is not specified in the application package as being required, WPI should not offer cost sharing in the budget or the text of the proposal.

2. Unless restricted by sponsor guidelines, cost sharing can include the devotion of effort (as converted to salary equivalents), fringe benefits, equipment, other direct costs (including tuition), indirect costs, or in-kind contributions (See Cost Sharing Expenditure Types below);

3. On Federal proposals, cost sharing expenses must be allowable in accordance with section J. of OMB Circular A-21, Cost Principles for Educational Institutions and specific program restrictions, if any, and directly related to the project for which the expenses are to be claimed;

4. The inclusion of cost sharing commitments in a proposal must have appropriate University approval prior to proposal review and approval by Sponsored Programs and proposal submission to sponsors;

5. All voluntary cost sharing commitments must be approved by the Provost after completing and submitting a Voluntary Cost Sharing Commitment Request (Policy Revision) (60 KB PDF file) form to the Office of Sponsored Programs at least two weeks prior to the anticipated proposal submission date;

6. Cost sharing expenses must be incurred within the same period as the award period of performance;

7. Cost sharing expenses for one project may not be claimed as cost sharing expenses for any other project;

8. Federal funds may not be used as cost sharing for another federal project unless approved in writing by the federal sponsor;

9. All cost sharing expenditures must be documented at the academic department level and made available in the event of audit;

10. When awards resulting from proposals, including those that involve cost sharing, are reduced by the sponsor, an appropriate reduction in the amount of cost sharing and related scope of work is normally expected.

Sources of Cost Sharing Funds Cost sharing support is available from a variety of sources, as indicated below. Faculty and staff who wish to submit proposals containing a cost sharing commitment should first look to their department as a source of cost sharing funds before seeking funds via one or more of the other options below. All cost sharing approvals must be in place and indicated on the Proposal Coordination Form (PCF) at the time each proposal is submitted in advance of review and approval by the Office of Sponsored Programs.

1. Department - all normal direct project costs;

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2. Provost's Office - graduate student support (stipend and/or tuition), equipment, reduction or waiver of indirect costs when the need is justified and cost sharing is mandatory;

3. Research Development Council (RDC) - all normal direct project costs;

4. External sponsors of matching funds - all normal direct and indirect project costs;

5. In-kind contributions - appropriately approved donated services and/or property from WPI and/or external sources; and

6. Support from corporations, foundations and other non-federal organizations.

Cost Sharing Expenditure Types The following expenditure types generally qualify as allowable cost sharing when supported by appropriate documentation and unless specifically excluded or restricted by sponsor guidelines. It should be noted that mandatory cost sharing must always appear in the proposal budget and be appropriately justified. Mandatory cost sharing will normally be indicated in a sponsor award notice. Voluntary cost sharing may or may not appear in a proposal budget, but must be approved in advance by the Provost, as this will become mandatory cost sharing if an award results.

Effort The documentation requirement for mandatory cost sharing of salaries and graduate student stipends (i.e., cost sharing indicated in a proposal and required by sponsor program guidelines) takes the form of an annual certification of effort on a fiscal year basis. Fringe benefits and indirect costs on salaries only at the currently approved rates also should be included in the determination of total salary/stipend cost sharing expenditures. Voluntary cost sharing of salaries and graduate student stipends must also be certified when the space associated with such voluntary effort is classified as organized research space. Always check with Research Accounting to identify the classification of space utilized in contributing voluntary effort to a project. Again, fringe benefits and indirect costs on salaries only should be calculated as part of total voluntary cost sharing expenditures. When the cost sharing of salaries requires release time from teaching duties, the cost of hiring an adjunct instructor normally constitutes valid cost sharing expense. All arrangements for funding release time activities must be coordinated with the department head and, when necessary for additional funding beyond the department level, the Provost's Office.

Equipment The Provost's Office has funds budgeted for support of equipment cost sharing that is either mandatory or voluntary. Department budgets may also provide support for certain equipment purchases.

Other Direct Costs This category includes the costs of graduate student tuition, supplies, travel, publication costs, computing and specialized service facility costs, and any other costs not included above. The Provost's Office may provide support for these costs if it has been determined that the faculty member's department lacks sufficient funding.

Indirect Costs


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Indirect costs, now called Facilities and Administrative (F&A) costs by the federal government, are real costs that are charged to awards in the form of a federally approved rate. It is the policy of the University to recover indirect costs at the currently negotiated, research indirect cost rate. Approval of reductions or waivers of indirect costs on proposals will be granted only when 1.) the sponsor or program specifically limits indirect costs, 2.) a demonstrated need exists, or 3.) the proposed activity is not research. Approval by the Provost for voluntary cost sharing of this type must be obtained prior to the review and approval of proposals by the Office of Sponsored Programs. Mandatory reductions in indirect costs required by a sponsor will be considered for approval as part of the Office of Sponsored Programs’s review of proposals. In the future, it is hoped that the amounts of any waivers and/or reductions will be tracked to determine the cost to the University of participating in programs that do not provide full reimbursement of indirect costs.

Reporting It is the responsibility of recipient departments to accumulate, track, document, and defend all amounts of cost sharing expense incurred on behalf of sponsored programs. As part of the effort certification process, reporting of salary cost sharing will be accomplished annually on a fiscal year-to-date basis. Reporting of all other cost sharing expenditures, including salaries, will be required by Research Accounting as part of its ongoing interim and final financial reporting activities on current sponsored program awards.

Questions Questions regarding this policy or implementing procedures may be directed to the Office of Sponsored Programs [email protected].

Rev. 10/01/04 2nd Revision, 12/29/04 3rd Revision, 2/11/05

Policy on Departure of Faculty Members Introduction This policy recognizes the importance of the University's interest in preserving its assets, including laboratory space and equipment, and its intent to maintain normal operations upon the departure of faculty members. It is intended to apply to situations where WPI faculty members, for any of the reasons indicated below, become permanently disaffiliated with the University with no intention of continuing an active professional relationship after departure. Specifically, this policy is applicable when a faculty member:

1. accepts an offer of employment with another institution;

2. is terminated by the University under terms of a mutual agreement;

3. seeks to retire or otherwise leave the University for health or other reasons prior to normal retirement.

Responsibilities The following responsibilities of departing faculty members, department heads, and other University administrative offices must be performed on a timely basis upon notification by the faculty member of his/her intent to leave the University to ensure both adequate accountability and a smooth transition period.



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Departing Faculty Member Responsibilities The departing faculty member is responsible for notifying her/his academic department head that s/he will be leaving the University and for returning to the possession and control of the University all on-campus and off-campus property in her/his possession, including computers, furniture, office equipment, library books, office and laboratory keys, etc. Credit cards (American Express, phone) should be returned and any balances due should be reconciled and paid prior to departure. Lockers (athletic, library) should be cleaned out and any keys returned to the appropriate supervising office. For departures during the academic year, the departing faculty member should accomplish closure on teaching and related activities with the department head.

Department Head Responsibilities Department Heads are responsible for notifying Human Resources and other appropriate offices (e.g., Academic Affairs, Office of Sponsored Programs) when faculty members are leaving the University and for coordinating the arrangements that must be made for departing faculty members having laboratories and/or active sponsored projects.

Laboratory facility cleanup should be arranged in advance with the Environmental and Occupational Safety Office in order to comply with University safety policies regarding inspection of the laboratory and identification and disposal of materials. Laboratory clean up and disposal costs will normally be paid for by the University unless the departing faculty member's department fails to comply with this policy. In such instances, these costs will be charged against the department budget.

Close out and transfer of sponsored project funds should be coordinated with the Office of Sponsored Programs (OSP). Equipment disposition requirements should be determined and transfer of equipment purchased with external funds arranged with the Property Administration Office with procedures contained in the Property Management Manual. Note that, ordinarily, transfer of unexpended award funds cannot be accomplished until all outstanding commitments have been charged and a final accounting is completed.

Environmental and Occupational Safety Office Responsibilities The Safety Office, in conjunction with the Department Head, is responsible for ensuring the all laboratory activities of the departing faculty member are appropriately concluded. This should be accomplished by conducting an inspection of the departing faculty member's laboratory facility, accounting for all in-stock chemicals and other materials, and arranging for the disposal any materials identified as no longer needed.

Office of Sponsored Programs Responsibilities Upon notification by the departing faculty member or Department Head, the Office of Sponsored Programs (OSP) will conduct any necessary sponsor liaison activities and arrange for a final accounting of unexpended balances with Research Accounting. Where the need exists, OSP will coordinate with sponsors either the return of unexpended funds or the transfer of unexpended balances to the departing faculty member's new institution.

Property Administration Office The Property Administration Office is responsible for preparing any final property reports required as part of the transfer/close out process and arranging with the departing faculty member's new institution for the acceptance and physical transfer of any qualifying equipment.


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Policy for Directly Charging Administrative Costs to Federally Funded Sponsored Programs Purpose This statement sets forth policy for the appropriate treatment of administrative costs (salary and non-salary) incurred in support of sponsored research and other sponsored projects in compliance with Office of Management and Budget (OMB) Circular A-21, Cost Principles for Educational Institutions.

Applicability This policy applies to salary and benefit costs related to administrative and clerical staff and to certain non-salary expenses which are incurred in performance of federally funded sponsored research.

Administrative and Secretarial Salary Costs OMB Circular A-21 requires that costs related to the normal administration of sponsored programs be treated as F&A (facilities & administrative) costs and reimbursed as part of the institution's indirect cost rate. However, certain specific situations can occur which will result in such costs being more appropriately charged as a direct cost of the project.

In certain situations, specific administrative/secretarial salary costs can be directly charged. Costs which are appropriate to be charged directly to a sponsored research grant or contract must meet the definition which is detailed in OMB Circular A-21:

Direct costs are those costs that can be identified specifically with a particular sponsored project ... or that can be directly assigned to such activities relatively easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances must be treated consistently as either direct or F&A costs. Where an institution treats a particular type of cost as a direct cost of sponsored agreements, all costs incurred for the same purpose in like circumstances shall be treated as direct costs of all activities of the institution. In July 1993, Section F.6.b of the Circular was revised to reflect the following wording regarding the charging of administrative costs within academic departments and research units:

In developing the departmental administration cost pool, special care should be exercised to ensure that costs incurred for the same purpose in like circumstances are treated consistently as either direct or F&A costs. ... Direct charging of these costs may be appropriate where a major project or activity explicitly budgets for administrative or clerical services and individuals involved can be specifically identified with the project or activity. Appendix I provides the official interpretation of Section F.6.b (developed jointly by several Federal agencies).

To directly charge administrative and secretarial salary (and benefit) costs to a sponsored program, ALL of the following guidelines must apply:

• Activities of administrative staff must relate to the project directly (i.e., the project's technical mission);

• Must be measurable and identifiable (as described in the passage from OMB A-21 above);


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• Must go beyond "routine" departmental support. (Routine departmental support refers to activities which must be carried out in order to support the conduct of research generally at the university. Such activities would include typing progress reports, technical reports, and final reports; preparing periodic cost reports; answering telephones; scheduling meetings; making travel arrangements; monitoring budgets; business meetings with the principal investigator; review of accounting reports.)

• Administrative or secretarial costs devoted to a specific grant or contract totals 20% or more of an individual's allocated effort.

Another situation in which administrative and secretarial salary costs would be appropriately charged directly to a sponsored research award is where the project is considered to be major in scope. A research center may be established in such cases. These projects generally entail more complex reporting requirements, involve faculty and researchers from two or more disciplines, and may involve coordination with organizations other than WPI.

It is important that where administrative or secretarial salary costs are contemplated as direct charges to a sponsored award, such costs must be specifically itemized in the proposed budget which will be transmitted to the funding sponsor. It should be noted as well that sponsor approval does not necessarily mean that such costs will be deemed appropriate under audit. The University must be prepared to defend each budget on its own merit relative to the guidance contained in OMB Circular A-21 in the event of an audit. The Office of Sponsored Programs can assist with the development of proposal budgets and can answer questions relative to a specific proposal or award.

Administrative Non-salary Costs OMB Circular A-21 requires that certain departmental expenses related to the normal administration of sponsored programs generally be treated as F&A costs, and reimbursed as part of the institution's overhead rate. Section F.6.b. of OMB Circular A-21 states that, "items such as office supplies, postage, local telephone costs, and memberships shall normally be treated as F&A costs."

Similar to the treatment of administrative and secretarial salary costs, the intent of this regulation is to differentiate between costs that can be specifically identified as related to a specific research activity versus those that cannot be so easily documented (general purpose). WPI’s policy is to adhere to the spirit of, as well as to be in compliance with, the Federal regulations.

Direct Costs Section F.6.b.(1) of OMB Circular A-21 states further that, "special care should be exercised to ensure that costs incurred for the same purpose in like circumstances are treated consistently as either direct or F&A (indirect) costs." This section lists specific examples of the types of expenditures that shall be treated as direct costs wherever such costs are identifiable to a particular ‘cost objective’ (i.e., specific research or other award). These examples include: laboratory supplies (e.g., chemicals); telephone toll charges; animals and animal care costs; computer costs; travel costs; and specialized shop costs. It is expected that award recipients will be able to demonstrate that all direct costs are specific to the particular research or other


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award, or has in place a mechanism to distribute the costs through specially designated recharge centers or specialized service facilities.

Costs That Generally May Be Charged to Federal Awards: • Chemicals used in research • Petri dishes, test tubes, etc. • Slides for microscopes • Supply items in connection with a University-approved rate for research-related services • Tools specific to research purposes

Indirect Costs Section F.6.b.(3) states that, "Items such as office supplies, postage, local telephone costs, and memberships shall normally be treated as F&A (indirect) costs." Thus a Federal sponsor's overall approval of costs in a "supplies" budget line does not mean that general purpose supplies are actually allowable as direct costs. Such items should be charged to department funds - they may not be assigned to Federal awards:

Costs That Should Not Be Charged Directly To Federal Awards: • Binders (3-ring, notebooks, etc.) • Desk supplies (paper clips, calendars, etc.) • Electronic storage devices (CDs, DVD-Rs, etc.) • Furniture (chairs, computer desks, benches, etc.) • Gloves (laboratory) • Paper • Pencils, pens, markers • Storage containers

Exceptions The University recognizes that, under exceptional circumstances, it may be appropriate to charge to a Federal award expenses that would normally be deemed as an indirect cost. As an example, consider a research program that requires the distribution of a survey instrument via CDs to a large number of individuals or institutions external to WPI. In such a situation, the cost of the CDs as well as the postage costs associated with mailing them would be allowable direct expenses, provided that these expenses were integral to the completion of the research.

In light of the need to be flexible under circumstances such as this, the University has created a form, which should be completed whenever an item or items can be appropriately justified as an exception to the policy. When needed, this form should be submitted to Research Accounting together with attached receipts (please see Appendix II below).

Revised October 17, 2005

Appendix I Government agency interpretation of OMB Circular A-21 revisions re: charging of administrative costs directly to sponsored research grants and contracts


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OMB Circular A-21 Treatment of Administrative and Clerical Salaries Question Section F.6.b of the July 1993 revision of Circular A-21 says that the salaries of administrative and clerical staff should normally be treated as F&A costs. This section goes on to say that direct charging of these costs may be appropriate where a major project or activity explicitly budgets for administrative or clerical services and the individuals involved can be specifically identified with the project or activity. What is the intent of this provision and under what circumstances may these costs be directly charged to sponsored agreements?

Answer Answer: This provision is intended to establish the principle that the salaries of administrative and clerical staff should usually be treated as F&A costs, but that direct charging of these costs may be appropriate where the nature of the work performed under a particular project requires an extensive amount of administrative or clerical support which is significantly greater than the routine level of such services provided by academic departments. The costs would need to meet the general criteria for direct charging in Section D.1. - i.e., "be identified specifically with a particular sponsored project ... relatively easily with a high degree of accuracy," and the special circumstances requiring direct charging of the services would need to be justified to the satisfaction of the awarding agency in the grant application or contract proposal.

The following examples are illustrative of circumstances where direct charging of the salaries of administrative and clerical staff may be appropriate.

• Large, complex programs, such as General Clinical Research Centers, Primate Centers, Program Projects, environmental research centers, engineering research centers, and other grants and contracts that entail assembling and managing teams of investigators from a number of institutions.

• Projects which involve extensive data accumulation, analysis and entry, surveying, tabulation, cataloging, searching literature, and reporting, such as epidemiological studies, clinical trials, and retrospective clinical records studies.

• Projects that require making travel and meeting arrangements for large number of participants, such as conferences and seminars.

• Projects whose principal focus is the preparation and production of manuals and large reports, books and monographs (excluding routine progress and technical reports).

• Projects that are geographically inaccessible to normal departmental administrative services, such as seagoing research vessels, radio astronomy projects, and other research field sites that are remote from the campus.

• Individual projects requiring project-specific database management; individualized graphics or manuscript preparation; human or animal protocols; and multiple project-related investigator coordination and communications.


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These examples are not exhaustive nor are they intended to imply that direct charging of administrative or clerical salaries would always be appropriate for the situations illustrated in the examples. For instance, the examples would be appropriate when the costs of such activities are incurred in unlike circumstances, i.e., the actual activities charged direct are not the same as the actual activities normally included in the institution's facilities and administrative (F&A) cost pools or, if the same, the indirect activity costs are immaterial in amount. It would be inappropriate to charge the cost of such activities directly to specific sponsored agreements if, in similar circumstances, the costs of performing the same type of activity for other sponsored agreements were included as allocable costs in the institution's F&A cost pools. Application of negotiated predetermined F&A cost rates may also be inappropriate if such activity costs charged directly were not provided for in the allocation base that was used to calculate the predetermined F&A cost rates.

Appendix II Use this form to charge administrative non-salary costs to sponsored research (118KB PDF file).

Eligibility Criteria for Submission of University Proposals Requesting External Sponsorship The purpose of this policy is to clarify the criteria for being a Principal Investigator (PI) or Project Director (PD) on externally funded grants and contracts at Worcester Polytechnic Institute (WPI). A PI or PD of an externally sponsored activity assumes responsibilities and obligations for the preparation of proposals, performance of the research program when awards result, and compliance with award requirements and University policies. Since the University is the official recipient of all awards, it is responsible for overseeing compliance with the terms and conditions of accepted awards.

So that the University may fulfill this responsibility, a PI or PD must have an appropriate relationship with the University that satisfies one of the following conditions:

• be employed by the University as a faculty member (all ranks), including research faculty. Exempt staff members, including technical, administrative, and research staff, and retired faculty or staff members having emeritus status also may submit proposals with the approval of the appropriate department head and senior University officer.

It should be noted that a faculty member on leave of absence may submit proposals through the University, provided the anticipated start date is no more than one month prior to his/her return to active employee status, unless specific arrangements have been made for a co-Principal Investigator to oversee the affairs of the award (e.g., to advise students). A faculty member also may submit proposals that provide for support in anticipation of a sabbatical leave.

• be enrolled as a graduate student at the University and have the proposal approved by the department head and senior University officer (a WPI faculty member must agree to act in the capacity of mentor/advisor on behalf of the student and be the named Principal Investigator or Project Director);

• be appointed as a post doctoral fellow, research associate, research fellow, faculty fellow or equivalent. These appointments may allow for sponsorship (i.e., financial support) from other

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sources that either (1) require the involvement of the University (e.g., NIH Post Doctoral Fellowships, Intergovernmental Personnel Act agreements) or (2) do not require any University involvement (e.g., Guggenheim or Fullbright fellowships);

• have a visiting or adjunct appointment at the University which complies with the University’s policies on Affirmative Action (AA) and Equal Employment Opportunity (EEO). Exceptions to these policies may be approved by the appropriate senior University officer when an appointment is without compensation. Individuals so appointed may not receive compensation as a result of later University action without first complying with AA and EEO requirements.

In all of the above situations, there should be an expectation of a continued relationship with WPI, the PI or PD must be appropriately qualified to conduct the project, and the PI or PD must agree to fulfill all requirements and responsibilities in connection with an award. It is also expected that other University requirements for review and approval of proposals to be submitted to external sponsors will be satisfied. Please see the WPI Proposal Submission Procedures for information about these requirements.

Rev. 12/05/2006, 01/10/07

Independent Contractor Policy and Procedures (Draft as of February 4, 2008)

Policy The purpose of this document is to set forth the University policy and implementing procedures for the engagement of independent contractors (a.k.a. consultants). Because significant tax penalties may be imposed for incorrectly classifying an employee as an independent contractor and the University may be exposed to unnecessary legal liability in the contracting process, it is important that WPI address these issues by defining a common standard in the way it conducts activities with external individuals and organizations. Definitions for commonly used terminology are provided later in this policy, as are the various Responsibilities of University individuals and departments involved in the independent contracting process.

This policy is applicable in all situations in which a University department recognizes a need for supplemental services involving an individual or organization external to WPI (i.e., the required service is not available. Further, this policy applies to all activities involving independent contractors, regardless of the funding source. The procedures contained in this document must be followed prior to the performance of any services by an independent contractor.

Definitions of Terms Used in This Policy Contract - A legally binding, bilaterally executed agreement that establishes the rights and duties of the parties and provides remedies for breach

Employee - A person paid through the WPI payroll system to perform a service for the University. Typically, the University controls the work to be performed, as well as how, when, and where it will be

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performed. Employees are provided the facilities and tools necessary to perform and are not at risk for profit or loss.

Guest Speaker - A non-employee engaged by the University to lecture, present, or otherwise speak on a subject about which s/he is considered to be an expert. Examples include speakers/presenters at conferences, symposiums, or lecture/speaker series and/or guest lecturers in classes or other training events. For purposes of this policy, guest speakers are considered to be independent contractors (see definition below).

Independent Contractor - An individual or organization having no connection or relationship with the University engaged to perform a specific service not readily available from within the WPI workforce. An independent contractor (a.k.a., consultant, freelancer, etc.) is bound by contract to perform services as the master of her/his own time, with full liability for job-related actions, and responsibility for all aspects of the means and methods of the service to be performed. The University may require proof of adequate insurance from independent contractors.

Non-Resident Alien - A person who is not a citizen of the United States or is not a resident alien (i.e., someone who does not have a Green Card)

Professional Services Agreement (PSA) - A bilaterally executed contract that establishes the relationship of employer-independent contractor, such that the independent contractor is expected to provide a specified service to the University. There are three types of standard PSA's utilized at WPI, which cover the majority of transactions involving the procurement of services by independent contractors. PSA's are discussed in detail in the Procedures section of this policy.

Resident Alien - An individual who is not a United States citizen, but who either has a Green Card or meets the "substantial presence test" of the Internal Revenue Service.

Identification of Relationship to be Created Prior to the commencement of any engagement, the relationship of the parties must be identified to determine if the service provider should be classified as an employee of the University or as an independent contractor. The following procedures should be followed to make such a determination:

1. Present and former University employees

Normally, present and former employees of WPI should be paid as an employee. Contact Human Resources with any questions regarding payment of these individuals through the regular University payroll.

2. Non-resident aliens (Citizens of other countries)

Non-resident aliens are individuals who are not U.S. citizens and who do not have resident alien status. These persons may be paid under this policy providing their specific visa requirements permit compensation

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for services. Note that these individuals may be exempt from the withholding of taxes in accordance with tax treaties between their country and the United States.

3. Other individuals and organizations

In accordance with Internal Revenue Service (IRS) guidelines, a service provider must be free to determine how and when work is to be performed. In the absence of such independence, a worker should normally be classified as an employee. The IRS has developed a series of twenty questions (factors) aimed at satisfying the common law test of independence. A majority of "yes" answers to the questions indicate that a service provider is more appropriately classified as an employee, while a majority of "no" answers point toward the service provider as being an independent contractor. The IRS twenty questions are, as follows:

1. Is the individual directed by someone at WPI regarding when, where, and/or how the work is to be performed?

2. Is the University providing detailed instructions or training to enable the individual to perform the work in a certain way?

3. Can the individual perform the work without personal risk of economic loss?

4. Are the services provided by the individual an integral part of WPI's operations, such as those that are already being performed within established job classifications (e.g.,clerical, teaching, research)?

5. Must the services be performed only by the individual rather than by an employee of the individual?

6. Will WPI hire, supervise, or pay others to assist the individual?

7. Is there a continuing working relationship between the individual and the department for which the services are to be performed?

8. Is the work schedule set by someone at WPI?

9. Is the individual required to devote her/his full-time effort to the department for which the work is being performed?

10. Must the work be performed at WPI or in a place designated by WPI?

11. Is the sequence of work set by a WPI employee?

12. Are regular oral or written reports required to be submitted by the individual to the University?

13. Is the method of payment based on hourly, weekly, or monthly fees instead of on a commission basis or by the program?

14. Are business and/or travel expenses to be reimbursed?

15. Will WPI furnish the tools, equipment, and/or materials to be used by the individual?

16. Can the individual perform the work without making or having made any investment in equipment or facilities?


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17. Will the individual be performing services exclusively for WPI rather than working for a number of organizations at the same time?

18. Does the individual regularly make his/her services available to the general public or to organizations other than WPI?

19. Is the individual subject to dismissal for reasons other than nonperformance of contract specifications?

20. Can the individual terminate his/her working relationship with WPI at any time without incurring any liability for failure to complete the job (e.g., forfeit of payment previously made by WPI or due under contract or breach of contract liability)?

The IRS currently considers factors 1, 2, and 3 to be the most important in the classification of employer/employee versus independent contractor. Additionally, the existence of a formal contract between the parties will lend credence to the transaction.

If, after evaluating the answers to the above factors, the individual is determined to be an independent contractor, then this policy applies and should be followed in the creation of any transactions involving supplemental services by a non-University individual or organization. Any questions involving the determination of whether or not an employer/employee or an independent contractor situation exists should be addressed to the Accounting Office for transactions involving all funds other than sponsored programs and to Research Accounting for all sponsored program funds.

Responsibilities Department (Service Recipient)

• Read and comply with this policy

• Ensure that an appropriate professional services agreement is executed prior to the commencement of services by any independent contractor

• Communicate information about this policy and procedures to any prospective independent contractor

• Determine whether a service provider should be classified as an independent contractor or employee

• Process appropriate documentation in support of transactions involving independent contractors

Department Heads • Ensure that this policy is communicated to all departmental faculty and staff

• Ensure compliance with this policy

• Approve all appropriate professional service agreements up to $2,000


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Independent Contractor • Provide all necessary information to department for determination of status and generation of

professional services agreement

• Provide all required documentation for payment of services

• Provide completed and signed W-9 form

Accounting and Treasury Office • Review and execute all professional services agreements to be charged to University internal funds

• Create and approve all professional services agreements to be charged to University internal funds when none of the three standard agreements is appropriate for use

Accounting and Research Accounting Offices • Process all appropriate payment requests

• Ensure that professional service agreements have been completed properly, executed by both parties, and that no apparent conflict of interest exists

Sponsored Programs • Create and approve all professional services agreements under sponsored programs when none of

the three standard agreements is appropriate for use

• Approve all professional services agreements under sponsored programs when the amount is greater than $2,000

Procedures For Independent Contractors and Guest Speakers When the Total Transaction, Including Fee and Expenses, Is $2,000 or Less The Services Agreement and Payment Authorization (SAPA) (PDF:12KB) form should be used in situations where the total quoted amount to engage an independent contractor or a guest speaker, including fees and reimbursable expenses, is $2,000 or less. SAPAs should be generated by the department requiring services and approved by the department head. The SAPA form incorporates a payment request section to minimize the amount of paperwork required.

SAPAs should be completed in advance of the performance of services. This is especially important for guest speakers who expect to receive payment upon completion of their presentations and before they leave the University.

The guest speaker or independent contractor to be paid using the SAPA form will receive an IRS form 1099 after the end of the calendar year in which services were rendered. WPI travel and other related policies must be followed by the independent contractor when incurring travel and expenses. One of the three options below may be used for payment of travel and other expenses:

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• When the amount of travel and other expense is included with the fee for service on the SAPA, the guest speaker or independent contractor should retain all original receipts. The IRS form 1099 that is sent will include the total of fee and expenses.

• Travel expenses may be reimbursed using a WPI Expense Report form. Original receipts are required in accordance with the WPI Travel Policy. Any claims for reimbursement not substantiated with receipts will be reported with the fee included on the IRS form 1099 as taxable income.

• When no fee for services is to be claimed and only travel and/or other expenses are to be reimbursed, payment may be accomplished useing a WPI Expense Report form in accordance with the WPI Travel Policy.

Departments should submit completed SAPAs to Research Accounting for transactions supported by sponsored programs and to the Accounting and Treasury Office for all other transactions prior to the commencement of services. A minimum of four business days should be allowed prior to the date that payment is required.

For Independent Contractors When the Total Transaction, Including Fee and Expenses, Is Greater than $2,000 Due to the inherent differences in doing business with individuals versus corporations, two standardized professional services agreements are available which accomplish the same purpose - the Individual Professional Services Agreement (IPSA) (PDF:24KB) and the Corporate Professional Services Agreement (CPSA) (PDF:24KB). The procedures to be followed for each are the same.

When the services of an independent contractor are required that will cost the University more than $2,000, including fees and expense, the requesting department should complete one of the two standard forms above, depending on whether an individual or a company will be providing services. These forms may be used in most situations where there are no extenuating issues, such as ownership of intellectual property. The completed, unsigned form should be sent to the independent contractor prior to the commencement of services. Prior review by the Accounting and Treasury Office (for transactions to be charged to University funds) or by Sponsored Programs (for transactions involving sponsored programs) is recommended, but such review is optional (Note: departments requesting the services of independent contractors do so at their own risk in the event that funds are not available, an incorrect agreement template is used, or other problems occur).

When the independent contractor signs and returns the agreement, the requesting department should review it to determined that it has been properly executed by the independent contractor and forward it to either the Accounting and Treasury Office or Sponsored Programs for review and signature. Since the agreement templates are not numbered, it is recommended that requesting departments complete and attach a WPI Purchase Order so that the independent contractor will be able to provide a recognizable reference when submitting invoices against the agreement.

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Once the agreement is reviewed and executed by an appropriate WPI signatory, one original will be retained in the Accounting and Treasury Office. The other original will be returned to the requesting department for forwarding to the independent contractor and for making a copy for department files.

Subsequent invoices received from the independent contractor must be approved by an appropriate signatory in the requesting department and forwarded to Accounts Payable or Research Accounting (for sponsored programs) for payment processing. Requesting departments are responsible for maintaining control of the amount(s) paid so as not to exceed the currently agreed upon amount.

For Independent Contractors When Extenuating Circumstances Require the Use of an Alternative Agreement Occasionally, it may be necessary for the University to draft an independent contractor agreement to fit a unique situation. These situations are most often determined in early discussions with an independent contractor or after the requesting department completes and forwards one of the standard agreements mentioned previously. An example of this type of situation is when an independent contractor is asked to use a technology or methodology owned solely by the independent contractor, which becomes the basis for providing a service for the University. In this situation, the issue of ownership or use of the product may arise and the language contained in one of the standard independent contractor agreements may not be appropriate. When this occurs, the requesting department should contact the Accounting and Treasury Office or Sponsored Programs (for sponsored programs) and request the development of an independent contractor agreement appropriate for the circumstance. Once developed, the procedures indicated above for agreement processing activities should then be followed.

Modifying an Existing Independent Contractor Agreement Once signed, an independent contractor agreement is a legally binding document that cannot be changed without the mutual consent of the parties. In the event an independent contractor agreement requires modification, the requesting department should complete an Amendment to Professional Services Agreement (APSA) (PDF:12KB) form. After completing, the form should be sent to the independent contractor for signature. Upon return by the independent contractor, the procedures above for processing professional services agreements should be followed.

Questions Questions regarding this policy and/or the procedures contained in it should be addressed to the Accounting and Treasury Office for transactions involving University funds and to Sponsored Programs for transactions under sponsored programs.

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Indirect Costs Recovery Policy and Procedure Summary

It is the policy of the University to recover indirect costs at its currently negotiated indirect cost rate whenever possible. Exceptions to this position are covered by the WPI cost sharing policy. Recovered indirect costs are used in support of various cost functions at the University by means of an after-the-fact allocation process. This policy and procedure sets forth guidelines both for recovering indirect costs and subsequent allocation of indirect cost recoveries.

Introduction

The full costs of undertaking research and other scholarly activities are rarely ever recovered as a result of awards made to the University. This is due to a variety of factors, including costs that are not included in proposals, award reductions, limitations on what costs can be included in indirect cost rate calculations, mandatory cost sharing, etc. Thus, it is in the financial best interest of the University to adopt a full recovery policy for the indirect costs associated with proposal submissions and acceptance of awards.

As is the case when other types of cost sharing is offered to (voluntary) or prescribed by (mandatory) external sponsors, the University must absorb the difference between total and funded sponsored program costs. This difference, of course, plays out in the budgetary process and results in less funding being available for other institutional priorities. The greater majority of federal agencies that sponsor science, technology, engineering, and mathematical science research understand this shortfall and provide for full indirect cost recoveries at federally-approved rates. It is, therefore, an expectation of most federal sponsors that institutional proposals will include indirect costs in proportion to appropriately budgeted direct costs.

Understanding this is to recognize the need to recover full indirect costs with all sponsors whenever possible. To provide favorable treatment to non-federal sponsors by charging a lesser rate than that which is charged to the federal government is not only questionable from a financial perspective, but it is also illegal. OMB Circular A-21, Cost Principles for Educational Institutions, states in section G.1.a.(3), the following: "Each institution's F&A cost rate process must be appropriately designed to ensure that Federal sponsors do not in any way subsidize the F&A costs of other sponsors, specifically activities sponsored by industry and foreign governments."

This policy is intended to provide guidance in determining the amounts of indirect costs that should be recovered by the University on sponsored programs. It also prescribes the allocation of these recoveries so that they may be used to further support University cost functions and institutional priorities.

Definitions

Cost Sharing - Cost sharing is defined by the Federal Government in OMB Circular A-110, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, as follows: "Cost sharing or matching means that portion of project


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or program costs not borne by the Federal Government." Approval of reductions or waivers of indirect costs in connection with sponsored programs will be granted only when 1.) the sponsor or program specifically limits indirect costs, 2.) a demonstrated need exists, or 3.) the proposed activity is not research. Please refer to the University's Policies and Procedures for Sponsored Program Cost Sharing for additional information.

Fully-funded Award - An award is considered fully-funded when it provides for the total costs of conducting a sponsored program, including full indirect cost recovery.

Indirect Costs - Indirect costs, now called Facilities and Administrative (F&A) costs by the federal government, are real costs that are charged to awards in the form of a federally approved rate (these terms, as well as overhead, are used interchangeably throughout this document).

Indirect Costs Allocation - After recovering indirect costs on sponsored programs, the University follows a prescribed method of allocating recoveries to various cost functions. Currently, 5% of recovered indirect costs on fully-funded awards is allocated on a quarterly basis to the awardee department and, similarly, 10% is allocated to the Principal Investigator (PI).

Research - The term "research" is defined as an organized study or methodical investigation into a subject in order to discover facts (i.e., create knowledge), to establish or revise a theory, or to develop a plan of action based on the facts discovered. Recognizing for purposes of this policy the federal government's somewhat disciplinary interpretation of research, the term shall primarily include only research conducted in the scientific, technology, engineering, and mathematical sciences (STEM) disciplines. This definition will be expanded when a sponsor provides for full indirect cost recovery in other disciplines so as to maximize the University's ability to recover indirect costs at its full rate.

Policy

The University will, whenever possible, recover indirect costs at its currently negotiated, federally approved rate. Only on an specific exception basis and/or when taking into account disciplinary differences that may possibly provide for reimbursement of indirect costs at lower than the full rate to which it is entitled, will recovery at a lower rate be permitted. Specific exceptions to full indirect cost recovery at the proposal stage must be justified and approved by the Provost prior to proposal submission in accordance with the WPI Policies and Procedures for Sponsored Program Cost Sharing. Similarly, reductions or waivers of indirect costs after receipt of awards must be requested by Principal Investigators (PIs) and approved in advance of formally accepting awards.

Recoveries of indirect costs on fully-funded awards will be subject to allocation by the Research Accounting Office according to the procedures set forth below. All cost sharing commitments on awards must be met before such awards will become eligible for participation in the recovery allocation.

Procedure


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For proposal preparation and review, award acceptance, and award financial management activities, the following participating individuals/offices shall be charged with specific responsibilities that ensure that the University is able to maximize its recovery of indirect costs:

Proposal Preparation and Review

Office of Sponsored Programs (OSP)

1. Determine the allowability of indirect costs as stated in each program solicitation for which proposals are to be submitted;

2. Participate in proposal development activities, as needed, to ensure that the indirect cost rate being proposed is the maximum allowed, up to and including use of the University's currently negotiated indirect cost rate;

3. When considering a lesser rate either due to a sponsor-imposed limitation or in response to a PI request, ask the PI to complete and return a Voluntary Cost Sharing Commitment Request Form (available on the OSP web site) and forward the completed form to the Associate Provost for Research;

4. Once approved, all proposed cost sharing is reported to the Provost's Office on a monthly basis.

Principal Investigator (PI)

1. Working with OSP staff, prepare proposals in sufficient time as to allow at least two weeks for review and consideration of indirect cost and other issues;

2. Complete and return to OSP a Cost Sharing Commitment Request Form so as to allow at least one week for review by the Provost of indirect cost reduction and/or waiver requested.

Award Acceptance


1. Review awards and/or notices of intent to make awards from sponsors to determine whether there is any budgetary impact or need for submission of a revised budget;

2. Discuss with PI the implications of any impact resulting from a lower award amount than what was proposed and recommend that the PI consider reductions in direct cost categories as well as modifications to the scope of work;

3. Inform Associate Provost for Research of any need for unanticipated cost sharing resulting from awards offered at less than the amount proposed;

4. Update monthly proposal cost sharing reports for awards received and note changes from originally approved cost sharing.

Award Financial Management


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1. Communicate to Research Accounting (RA) and the PI on each award action, specifying the agreed upon indirect cost rate and base, as well as any other agreed upon cost sharing by the University;

2. State to Research Accounting (RA) and the PI that each award is either fully-funded or not fully-funded to ensure that the appropriate level of indirect cost recovery is allocated;

Research Accounting (RA)

1. Create Banner fund and document award restrictions resulting from each award that is not fully-funded;

2. Set up indirect cost allocation on fully-funded awards only;

3. Allocate indirect cost recoveries, as prescribed by the Accounting and Treasury Office;

4. Provide monthly cost sharing reports that show by Banner fund the level of cost sharing by category of expense.

Questions

Any questions regarding this policy and implementing procedures should be addressed to the Office of Sponsored Programs (OSP) by e-mail to [email protected].

Invention Disclosure Procedure One of the most important aspects of the University's business is gathering and disseminating knowledge. The process of recognizing when an invention exists and subsequently making it available for use in the service of the public is one way of accomplishing this objective. The University, therefore, encourages the inventive process and can, within the limits of its own financial resources, provide needed advice and assistance to further this activity.

An invention should normally be disclosed when it has been demonstrated to work but, in special circumstances (e.g., past or imminent public disclosure, competition, anticipated delay in reducing to practice, extensive analysis or modeling, etc.), disclosure can be made upon conception. The generally accepted rule of thumb, which is to "disclose first and publish later," is followed to prevent the potentially costly result that can occur with premature publication. Such activity can have negative legal, financial, and tactical consequences in any effort to commercialize the invention. For this reason, it is highly recommended that inventions be disclosed as soon as it is clearly conceptualized rather than waiting until it is reduced to practice. Any information supplied with an initial disclosure to the University should be supplemented by further details as they become known to the inventor. Details about the required disclosure of all inventions is contained in the University's Intellectual Property Policy.

The University has resources available to it that will assist in determining whether an invention is actually patentable, what rights inure to a sponsor or sponsor(s) of an invention, and in resolving other legal issues (See Intellectual Property Workshop [PPT]). Complete the WPI Invention Disclosure Form (available on


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the Forms page) to document all known details about the invention as soon as practicable and forward to the Associate Provost for Academic Affairs. If unsure whether or not an invention exists, contact the Associate Provost for Academic Affairs (extension 5404), the Director of Sponsored Programs (extension 5359), or the Director of Intellectual Property ([email protected], extension 5834).

Sponsor Proposal Limitation Policy Introduction Under certain programs, sponsors may limit the number of proposals that may be submitted. In situations such as this, a fair and equitable determination of who will be permitted to submit proposals must be made. This policy addresses the selection process for University investigators who wish to submit proposals to a limited submission program such that the goals of WPI are considered, as well as the likelihood of being funded.

Policy It is the policy of the University that, whenever a sponsor imposes a limitation on the number of proposals that may be submitted by an institution, an effort will be undertaken to identify investigators whose proposals:

1. most closely match the mission and current goals of the University,

2. provide the least-cost, most-return incentive on the University's investment, and

3. exhibit, to the extent determinable, the highest likelihood of resulting in an award

The review will be conducted by the Associate Provost who, at his discretion, may assemble an ad hoc review committee to assist in identifying investigator proposals that most closely match these criteria. So that investigators do not have to undertake a major proposal development effort with the possibility of not being permitted to submit, the review process will be conducted on the basis of brief proposal abstracts only, whenever possible.

It is understood that, in addition to the above criteria, any resubmission of a previously unsuccessful proposal may provide an advantage in the review process, providing such resubmission is consistent with University goals and funding priorities.

Procedure When a program with a limited submission requirement is announced by a sponsor, the Office of Sponsored Programs (OSP) will provide notification to this effect as it disseminates the announcement to department heads and other interested parties. Within the announcement or in no case later than one week of having communicated the announcement, an internal deadline will be established by which time any faculty member interested in submitting a proposal may provide a brief (1-3 pages) abstract of the project and a budget outline with accompanying narrative explanation. Project abstracts must be submitted to OSP by close of business on the deadline date to receive consideration. To this end and when sufficient time exists, OSP will send an electronic reminder of the internal deadline approximately one week prior to it.

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Note: If project abstracts are submitted to OSP after the internal deadline, investigators risk that their submissions will not be eligible for review and/or selection to proceed with a proposal submission.

Project abstracts submitted in response to an internal deadline should provide the following information:

• Investigator name, title, and department and name(s) of collaborating WPI investigators and departments

• Proposal title, expected duration, and estimated amount of request, if known

• Description of the project

• An outline of the expected budget request and brief explanation of its components

• Statement of expected benefit to WPI, including the impact on students, relevance to existing or new research areas

• Required commitment, if any, of institutional resources to complete the project

• Departmental endorsement

If the number of faculty interested in submitting proposals does not exceed the sponsor limitation, immediately after the internal deadline OSP will notify the faculty members in an e-mail that they may proceed with their proposal development and submission efforts (OSP will provide informational copies of proposal abstracts to the Provost). If, however, more faculty members wish to submit proposals than is allowed by the sponsor, OSP will forward copies of all proposal abstracts to the Provost with a request for review and determination of which proposals may be developed for submittal.

The ad hoc committee will provide a timely review and determination. If a tie results as a result of the review process, the Associate Provost will make the final decision and those researchers whose proposals have been selected for submission will be notified, with a copy to OSP in sufficient time to develop the full proposal. Investigators whose proposals have not been selected will also be notified and assigned a priority number for being permitted to submit a proposal in the event that one or more of the selected investigators decides not to submit as planned.

Questions regarding this policy and implementing procedure may be addressed to the Office of Sponsored Programs.


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Subcontracting Procedure The purpose of this procedure is to provide information for faculty and staff involved in the issuance and administration of subcontracts and other subawards by specifying when it is appropriate for these agreements to be issued and the steps to be followed at both the proposal and award stages. Also, this procedure is intended to make individuals aware of the monitoring requirements of OMB Circulars A-110 and A-133 and, thus, ensure compliance by the University. For the sake of convenience, the terms "subcontract," "subcontractor," "subaward," and "subawardee" are used interchangeably throughout this procedure.

When WPI receives an externally funded award from which some or all of the funds are to then be provided to an external organization, it is necessary to incorporate (or "flow down") the terms and conditions of the award received by the University. This process should be followed when:

• the scope of work to be performed involves/utilizes the facilities, employees and/or resources of the external organization

• the subcontractor is expected to make a substantial contribution to the scholarly or scientific conduct of the funded program as described in the scope of work

• the subcontractor principal investigator has responsibility for programmatic decision making

• the subcontractor organization has responsibility for compliance with applicable Federal or other sponsor regulations and/or guidelines and when performance is to be measured against whether the objectives of these regulations and/or guidelines are met

• the subcontractor brings a unique knowledge and expertise to the funded program and is expected to conduct the work with only general technical direction of the WPI principal investigator

• the subcontractor, as part of its primary business mission, does not provide the same goods and/or services to others and will be using WPI-provided funds to accomplish a program of the subcontractor organization, rather than providing goods or services solely to participate in a program that is of benefit to WPI (e.g., purchase, fabrication or repair of equipment, data processing, routine analytical or testing services).

A subcontract is not appropriate under the circumstances outlined below. Instead, such services should be considered a purchase of goods and services under which a purchase order is utilized to document the transaction.

• the provision of goods and/or services within normal business operations

• similar goods and/or services are made available by the other organization to many different purchasers

• the other organization competes with other entities to provide the needed goods and/or services

• the other organization is not subject to compliance with the federal regulations and/or other sponsor requirements


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• the goods and/or services to be provided are ancillary to the sponsored program.

The Proposal Stage It is normally determined as part of proposal development activities that some part of a scope of work will need to be performed by another organization. The principal investigator should decide what activities this will encompass and select an appropriate organization capable of performing the work. The principal investigator must then be prepared to justify the selection of her/his collaborating institution.

When making this selection, the requirements of Subpart C.42 of OMB Circular A-110, Uniform Administrative Requirements for Grants and Agreements for Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, must be considered (as well as the University's Conflict of Interest policy). This section, entitled Codes of Conduct, states the following:

" .42 Codes of conduct. The recipient shall maintain written standards of conduct governing the performance of its employees engaged in the award and administration of contracts. No employee, officer, or agent shall participate in the selection, award, or administration of a contract supported by Federal funds if a real or apparent conflict of interest would be involved. Such a conflict would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in the firm selected for an award. The officers, employees, and agents of the recipient shall neither solicit nor accept gratuities, favors, or anything of monetary value from contractors, or parties to subagreements. However, recipients may set standards for situations in which the financial interest is not substantial or the gift is an unsolicited item of nominal value. The standards of conduct shall provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the recipient."

Specific information from potential subawardees is required as part of the proposal submission process. This information consists of a letter of intent, a scope of work, a budget, and a copy of the subawardee's current Facilities & Administrative Costs (indirect costs) rate agreement.

• Letter of Intent - The purpose of a letter of intent in connection with subcontract proposals is to secure institutional endorsement and commitment prior to proposal submissions. This letter should reference the program title, requested duration, the amount of funds required, and a statement of intent to accomplish the work outlined in the scope of work should an award to WPI be made. All letters of intent should be signed by the subcontractor principal investigator and institutional authorized representative.

For proposals to the National Institutes of Health (NIH), letters of intent must include confirmation that the appropriate programmatic and administrative personnel at each institution are aware of the Public Health Service (PHS) consortium grant policy and are prepared to establish the necessary inter-institutional agreements consistent with this policy. Letters of intent under NIH proposals must also include a certification regarding education in the protection of human research participants, should the use of humans in the program be contemplated. Suggested language to accomplish this certification is: "All investigators and other key personnel involved in this


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subaward (list names) have completed the following course in the responsible conduct of research involving human subjects (state course title and include a brief description). If the subawardee is unable to certify to the above in the letter of intent, a certification will be required at the "just-in-time" stage and prior to the initiation of a subaward. The certification must be signed by the subcontractor principal investigator and institutional authorized official.

• Scope of Work - A scope of work for the subcontractor institution must be attached to the letter of intent to provide an outline of work to be accomplish, should an award result. Depending on the size and complexity of the program, a scope of work may be a few sentences or pages in length, but it should be sufficient in its description of the work to be performed as to allow for reasonable assessment of performance.

• Budget - The budget should consist of subawardee costs only, which may include, as appropriate, both direct and indirect (facilities and administrative) costs. If indirect costs are included in the budget, a copy of the subcontractor's most current indirect cost rate agreement must also be provided. The purpose of including this information is to facilitate a review that the indirect cost and fringe benefit rates used in the budget are correct. A justification that adequately describes and explains the need for the costs being requested should also be included with the budget.

• Facilities & Administrative Costs (Indirect Costs) Rate Agreement - A copy of this document is required in order to verify that indirect cost and fringe benefit rates included in subawardee's budgets accurately reflect currently approved rates, which will be used throughout the life of any subaward that is subsequently issued.

Should a sponsor indicate its willingness to fund a WPI proposal, but requests a revised budget (and, depending on the amount of the budget cut, a revised scope of work), this action may or may not affect the subcontractor's participation in the program to be funded. If there is an impact, the WPI principal investigator or, upon request, the Office of Sponsored Programs (OSP), must contact the subawardee to request any required revisions. Any revised documentation provided by a subcontractor must again include the subawardee's institutional authorization. This information should be forwarded to OSP for inclusion with other sponsor-required documentation.

The Award Stage At the time an accepted award is processed by creating a fund on Banner, OSP will initiate an appropriate subcontract document. Information may be required of the principal investigator during this process, especially if the award amount was cut without the submission of a revised budget.

If the proposal is funded as submitted, the subaward will be based upon the information originally provided by the subawardee. Subawards to be funded as a result of a revised budget submission by WPI and the subawardee will be budgeted at the revised amount. The principal investigator will be contacted by OSP in cases where the budget cut was unilaterally accomplished by the sponsor to ensure that an appropriate amount of funding is provided to the subcontractor (occasionally, subcontractor participation will no longer be possible if the sponsor budget cut is severe).


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Subcontracts created by OSP will be forwarded (electronically, whenever possible) to the subcontractor administrative contact for negotiation and signature by an institutional authorized representative. Subawards are executed in duplicate, with copies of fully executed subawards provided to the WPI principal investigator and Research Accounting.

Once executed, in order to comply with the requirements of OMB Circular A-133, all Federally funded subcontracts must be monitored for technical and financial compliance by the sub-recipients of these funds, as follows:

• Technical Monitoring - WPI, as the prime recipient of Federal funds, is responsible for the conduct of the program, from its beginning through completion. As a means to ensure technical compliance by subrecipients, WPI Principal Investigators should maintain documentation of all liaison activities with subcontractor organizations. Followups should include requests for progress reports at least annually, in addition to periodic electronic and telephone contact to stay abreast of the status of the subcontractor's efforts. If any technical or other performance deficiencies are discovered, the PI must notify both OSP as well as the prime sponsor's program officer. Maintaining adequate and timely records of all technical monitoring is key to achieving compliance with Federal requirements.

• Financial Monitoring - All invoices from subrecipients should be reviewed by the WPI Principal Investigator for comparison of expenditures being billed with progress achieved. Disparities should be questioned immediately by the PI. If invoices are deemed acceptable, the PI should sign "O.K. to pay," initial, date, and forward to the Research Accounting Office for additional review and approval of payment. Review by Research Accounting should include verification of F&A (indirect) rates, expenditure rates in relation to the percentage of completion of the program, mathematical accuracy, and adherence to budgetary categories of the subaward. Inconsistencies should be discussed with the WPI Principal Investigator before following up with the PI at the subcontractor institution.

Subcontract Modifications It often becomes necessary over the life of a sponsored program to modify subcontracts. The reasons for these modifications can be additional funding or a reduction in funding, extensions of the period of performance, change in subcontractor principal investigator, change in the regulations and/or guidelines under which the prime award to WPI was issued, etc. WPI principal investigators will be involved in the modification process only as needed, such as when the scope of work or the amount of increase/decrease is in question.

In the event of a needed modification, OSP will process an appropriate amendment to the subaward. Copies of modifications, once executed, will be sent to the WPI principal investigator and Research Accounting.

Questions Questions regarding any aspect of this procedure should be addressed to the Office of Sponsored Programs.

2010 Sponsored Projects Handbook

Documents

Transcript of 2010 Sponsored Projects Handbook