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Administrative Policy and Procedures for Externally Sponsored Projects

ADMINISTRATIVE POLICY AND PROCEDURES
FOR EXTERNALLY SPONSORED PROJECTS
AT ROCHESTER INSTITUTE OF TECHNOLOGY

1.0               INTRODUCTION

All members of the RIT community, including faculty, students, and staff are expected to adhere to the highest ethical and professional standards when pursuing sponsored project activities.  Involvement with externally sponsored projects elevates these expectations to obligations because sponsors impose significant statutory and regulatory administrative requirements in connection with funding provided for these projects.  This document explains RIT's commitment to the legal and ethical administration of externally sponsored projects; provides administrative guidance to ensure compliance with the necessarily dynamic policies associated with such projects, and enables the Principal Investigators (PIs) and their operational units, Sponsored Research Services (SRS), and Sponsored Program Accounting (SPA) to facilitate the orderly administration of such externally sponsored projects.    

2.0               EFFECTIVE DATE

This Policy will be Effective on October 1, 2011 ("Effective Date").  It will apply to all divisions, academic units and departments of RIT as well as Enterprise and Research Centers/Laboratories, as applicable.

3.0               GENERAL PROVISIONS

3.1               Policy

All RIT community members engaged in externally sponsored projects shall comply with the legal, regulatory, contractual, and ethical requirements established by RIT, regulatory agencies, federal and state authorities, and the funding source.  At RIT, the Principal Investigator (PI) has overall responsibility for the technical and fiscal management of a sponsored project.

3.2               Definition of Terms

3.2.1         Agreement means any contract or grant for any project between an external funding source and RIT that is managed by Sponsored Research Services (SRS).

3.2.2         Classified Information is any information or material that has been determined by the US Government to require protection against unauthorized disclosure for reasons of national security, and is labeled accordingly.

3.2.3         Research Center/Laboratories are programs with a well-defined focus involving multiple Externally Sponsored- Projects from multiple PIs and support and/or research staff, some of whom are entirely supported by soft money funding (i.e., salaries paid from externally funded grants & contracts) and laboratory equipment that requires ongoing support through technicians and/or service contracts.  The list of current RIT authorized Research Centers/Laboratories is available from the SRS website.

3.2.4         Enterprise Activity   An Enterprise Activity is a set of externally sponsored projects that are similar enough that a single scope of work or job description applies accurately to the whole set.  Usually the work involves routine analysis, evaluation, or non-credit training.  In addition, the number of such projects is usually sufficiently great that it become much more efficient to prepare a single scope of work or job description than a series of separate Notice of Awards (NOAs). Anyone desiring an updated list of units which conduct Enterprise Activities can consult the SRS website at: http://www.rit.edu/research/srs/compliance/roc

3.2.5         Externally Sponsored Projects are studies, services, and research performed by Agreement with RIT involving non-Institute funds and reported to SRS.

3.2.6         Proposal Routing Form (PRF) is the key transmittal document required for internal RIT approvals of every externally sponsored research project.  It includes an abstract of the externally sponsored project, identifies the RIT faculty and staff working on the project, reflects the finalized project budget totals, and contains the approvals of the applicable faculty, staff, and their Operational Unit's Department Head or Dean, as well as the approval of the Vice President for Research.

3.2.7         Operational Unit is the academic department, administrative department, or research center/laboratory having responsibility for oversight of the PI working on the research project.

3.2.8         RIT Proprietary Information is information identified, described, designated or marked at or near the time of creation or disclosure as proprietary to the Rochester Institute of Technology. Such information is recorded information, regardless of the media upon which it resides, of a scientific or technical nature and specifically includes, but is not limited to, technical data, computer software and software documentation developed in whole or in part by RIT, and all forms of intellectual property (such as trade secrets, patents, copyrights, and trademarks).  RIT personnel should always label RIT Proprietary Information before sharing it with any external party.

3.3               Responsible Parties.  In general, PI's and their Operational Units, SRS, and SPA each play a key role in ensuring proper compliance with all RIT, regulatory, legal, and sponsor requirements on Externally Sponsored Projects. 

3.3.1         Principal Investigator (PI).  The PI has overall responsibility for the technical and fiscal management of his or her sponsored project. With this responsibility comes the obligation to (i) plan, manage and perform each project with care and diligence; (ii) adhere to all terms and conditions of the award; (iii) make programmatic progress;  (iv) communicate with sponsors regarding programmatic progress; and (v) ensure that only those costs that are appropriate and required for fulfillment of the project's objectives are charged.  A PI is responsible for completion of the project's substantive work and also has primary responsibility for the financial and other administrative aspects of the award.  See the SRS website for a listing of additional responsibilities: http://www.rit.edu/research/srs/grantsmgmt/pi.html   Throughout the entire Project, the PI shall work with the SRS staff on non-financial award administration and SPA staff on financial award administration matters. 

3.3.1.a.     PI Eligibility Limitations.  The following employees are typically ineligible to function in the role of PI: Post Doctoral Associates, Lecturers (as defined in Institute Policy E6.0), Visiting Faculty, Adjunct Faculty, and Emeritus Faculty. 

In certain instances, exceptions for the individuals listed above may be granted.  This exception request must be stated in the notes section of the PRF and approved by the Department Head, Dean, and Vice President for Research.

3.3.2         Sponsored Research Services (SRS).  SRS reports to the Office of the Vice President for Research.  SRS is responsible for the pre-award and post award non-financial administration and coordinating compliance issues that arise in connection with Externally Sponsored Projects.  In addition, within SRS are Senior Research Administrators (SRA), who are assigned to each Operational Unit and responsible for assisting PIs in navigating the pre-award process. See http://www.rit.edu/research/srs/about for a detailed account of the support SRS provides PIs.

3.3.3         Sponsored Program Accounting (SPA).  SPA is a department within the Controller's Office hierarchically reporting through the Sr. Vice President for Finance and Administration.  SPA is responsible for the fiscal administration of Externally Sponsored Projects. SPA assists primarily with post award financial compliance duties, which include financial reporting, invoicing, effort reporting, cash management requirements, and financial audit coordination of sponsored projects. See http://finweb.rit.edu/controller/sponsored for a detailed account of the support SPA provides.

3.3.4         Research Advisory Members.  This informal group consists of faculty representatives from across the Colleges, directed by the RIT Vice President for Research, that provides feedback and comment on the strategic vision and implementation challenges of RIT's research goals.  

3.3.5         Oversight Committee For Externally Sponsored Projects (OCESP).  The OCESP is created by RIT Policy C1.0 for the limited purpose of implementing and administering the Oversight Policy for Externally Sponsored Projects and balancing RIT's commitment to openness in scholarship with competing requirements of the sponsors of externally funded projects at RIT. See http://www.rit.edu/academicaffairs/policiesmanual/sectionC/C1.html Pursuant to RIT Policy C.10 the OCESP is responsible for conducting review of certain externally funded research projects (as set forth in Section 3.5.2) prior to their execution when there are particular limits on open scholarship.

3.3.6         Vice President for Research (VPR). The Office of the Vice President for Research is responsible for university-wide research and research administration.  The VPR collaborates with all deans and research center directors and works closely with other university administrators to develop and carry out RIT's strategic research agenda in compliance with applicable laws and regulations.  The Vice President for Research oversees and approves changes to this policy for pre-award and post award non-financial processes.

3.3.7         Sr. Vice President for Finance and Administration The Finance and Administration (F&A) division is organized and operated to provide service to the university in the stewardship of its human, physical, financial, and informational resources. The Sr. Vice President for Finance and Administration oversees this policy and approves substantive changes for post award financial processes.

3.4               Pre-Award Process. RIT's pre-award processes are the steps necessary for the acquisition of a grant or contract by a PI. The process includes the actions leading up to the notice of award or announcement of funding.  The pre-award process is visually depicted on the first page of the following chart: http://www.rit.edu/research/srs/proposalprep/procedures.html

3.4.1         Preparation of technical proposal and budget.  The PI shall consult with its designated SRA, as needed, in order to prepare the technical proposal and an appropriate budget for the research project that takes into account the administrative and substantive needs of the project.  The budget creation should be performed simultaneously with completion of the PRF.  During this pre-award process it should be determined whether any approvals (as set forth in Section 3.4.3) must be obtained prior to submission of the PRF and proposal application, receipt of the notice of funding, award or execution of the agreement itself.  SRS must approve the finalized budget prior to submission of the proposal to the sponsor. For details regarding preparation of the budget see http://finweb.rit.edu/controller/accounting/docs/manual/04.pdf

3.4.2         Preparation of the PRF.  A fully completed and approved PRF by all applicable RIT signatories noted below (and in section 3.4.3) that are required before RIT can commit any resources noted in the PI's proposal, and before any proposal can be sent to an external sponsor.  The PI is responsible for completing and routing a PRF with assistance of the SRA, to obtain all department and administrative approvals required for the project and its technical and budget circumstances in order to submit the proposal to the sponsor and commit RIT resources to the project.  The completed PRF will reflect the specific approvals of the PI and his/her operational units, Department Head, Dean, the SRA themselves, and ultimately the Vice President for Research on every PRF.  The fully completed and approved PRF provides the approval to the PI to proceed on the research project, if awarded, under the scope of work, budget, percentage of effort, with any F&A sharing or any cost sharing proposed by the PI, all as reflected in the PRF.  Any changes of 10% or more of the total budget amount during the proposal or award process will require the re-routing and re-approval of the revised PRF to ensure that proper RIT supervisors of the PI, and the research, approve the revised commitment of RIT resources to the proposal.

3.4.3         Prior approvals required for specific proposal characteristics.  Prior to submission of the proposal, if the following specific features are a part of the proposal, then additional approvals are required as set forth below and in the PRF.  The approval is a representation that the proposal is in full compliance with RIT's policies and necessary to meet business objectives.

3.4.3.1     Cost Sharing.  Cost sharing should not be included in a research proposal unless required by the external sponsor.  If any cost sharing is involved in a proposal, approval from the VPR, Dean and/or Department Head affected shall  be obtained on the cost sharing approval form, which is part of the PRF.  The PI will be responsible for initiating and seeking Department and Dean approval for cost sharing..  The VPR may consult SPA and approval will be consistent with OMB Circular A-110.C.23.

3.4.3.2      Reduction of RIT's approved Facilities and Administrative (F&A) rate.  No reduction in RIT's approved F&A rate should be included in a proposal unless it is required by the sponsor.  If there is such a requirement by the sponsor then the appropriate party (PI and/or Department Head, and Dean) should provide a written justification and seek prior approval in writing from the VPR.  The VPR may consult SPA and approval shall be consistent with OMB Circular A-110.C.23.

3.4.3.3    Tuition Remission. If student tuition remission will be used to meet a cost share commitment, the department responsible for providing funding must provide approval on the cost sharing approval form, which is part of the PRF .   

3.4.4    Signatory Approvals for Proposals and PRF. If a proposal will be funded with federal, state, or local government funds then SRS approval and VPR approval is required for the PRF and proposal prior to submission to the sponsor no matter the dollar amount.  (a) If the project is under $5,000 and not federal, state, or local government sponsored, no SRS or VPR approval is required prior to submission of the proposal.  (b)  If the project budget is greater than $5,000 and $50,000 or less, and does not involve federal, state, or local government monies, the research project requires SRS approval of the PRF and the proposal may be submitted to the sponsor after approval of the Director of Sponsored Research Services.   (c) However, the Director of CIMS may approve non-government proposals of $50,000 or less provided the PRF for the project is approved by SRS.   (d)  All projects over $50,000 require proposal and PRF approval of SRS and the VPR. 

3.4.5.   Pre-Award Compliance Issues    SRS shall work with the PI to become aware of any compliance issues that arise at the pre-award stage.  The PI shall be responsible to designate any relevant project compliance issues on the PRF, and SRS shall assist the PI in coordinating with the applicable RIT office to plan for project compliance in these areas (e.g., use of human subjects, use of animals, hazardous materials, etc.).  See also section 3.9.  In addition, SRS shall review the proposals for compliance with the Procurement Integrity Act, and will work with SPA to coordinate compliance with any additional sponsor legal and regulatory requirements, and RIT procedures as necessary.

3.4.6    Submission of Proposal to Sponsor.  Each PI is responsible for preparing a complete proposal and PRF in time for PRF approval, and submission of the proposal to the sponsor.  The PI shall work with the SRA and SRS representatives to submit proposals in accordance with sponsor instructions and requirements. All proposals submitted through SRS are logged in an SRS database. 

3.5               Award Process.  These are the steps followed after a communication from a sponsor that an award will be made.  The process is described visually on the second page of the following chart: http://www.rit.edu/research/srs/proposalprep/procedures.html

3.5.1         Negotiation of Agreement. SRS representatives negotiate the contract terms with the sponsor, not the PI. If there are non-standard terms of the contract, SRS confers as applicable with Academic Units and the PI, Development, Risk Management, SPA, the Office of Legal Affairs,  the Intellectual Property Management Office (IPMO), and/or any other relevant Operational Unit of the RIT.

3.5.2         Prior Review Required by the OCESP.  If SRS identifies research agreement terms that (i) request a limited level of disclosure of RIT Policy 1.0 required project Pertinent Details; (ii) if the project includes a publication review delay  beyond the accepted 90-day period, or a publication approval; or (iii) if the project creates or makes use of Classified Information; then SRS will work with the PI to prepare a prior review request and present it to OCESP for approval pursuant to RIT Policy C1.0 (http://www.rit.edu/academicaffairs/policiesmanual/sectionC/C1.html ) and OCESP procedures (http://www.rit.edu/research/srs/compliance/roc/oversight_policy_procedur... ).

3.5.3         Conflicts of Interest Review.   As part of the Project Initiation Meeting (see 3.6.1) SRS shall direct each PI to ensure they have updated their disclosure to remain in compliance with the RIT Individual Conflict of Interest and Commitment Policy as a condition of accepting the terms of the award.  If any conflict of interest concerns are raised by the PI, any supervisor or administrator of the RIT Conflict of Interest Policy, or any other source, SRS shall coordinate with the Office of Legal Affairs (or any Administrator of RIT's Individual Conflict of Interest and Commitment Policy)  for an expanded conflict of interest review prior to RIT's commencement of the research project.

3.5.4         Export Control Review.  The PI shall consult with SRS and the Office of Legal Affairs to complete all required documentation, export review checklists, and comply with the RIT Export Control Compliance Program, and assist in the review of the proposal's implications for export controls (e.g., foreign nationals involved in the Project) in accordance with the RIT Export Control Compliance Program. See http://finweb.rit.edu/grms/compliance/export_compliance.html

3.5.5         SRS Processing of Award. SRS is responsible for obtaining final approval and authorization on project agreements from the Vice President of Research consistent with RIT's Signature Authority Policy.  Upon complete acceptance of an award, SRS shall update its electronic database as funded, and then send an account request to SPA if a project is sponsored by a federal, state or local government entity, or the project is valued at $5,000 or more, in preparation for the Project Initiation Meeting (PIM) (discussed in Section 3.6.1).  However, separate project accounts are not required for Enterprise Activity that is non-government and $5,000 or more.  The PI will receive notification the account request has occurred.  At this time, the PI will automatically receive electronic notification of their obligations under RIT Policy C1.0 and the NOA process discussed in 3.6.2. 

3.5.6         SPA Financial Account Established.  SPA sets up a new sponsored project account in the Oracle general ledger to record the financial transactions for the award. SPA will review the account request from SRS, may seek further information from the PI or SRS, prior to setting up a new project number in the Oracle general ledger.  Upon completion of project set-up, SPA will send to the PI a letter with the established account information.

3.6               Post-Award Process.  RIT's post award process sets forth the steps to follow after the execution of the final agreement and during the administration of the award.  During this time, the PI will commence the substantive research required by the Project as specified in the award agreement.  In addition, the PI shall work with SPA to facilitate the appropriate and compliant administration of the agreement in accordance with sponsor and RIT's policies and procedures.

3.6.1         Project Initiation Meeting (PIM).  After an award notice is received by RIT and the financial account is established for the sponsored project, SRS is responsible for holding a PIM with the PI, his/her project administrator, SPA representative and others as appropriate. The purpose of the PIM is to review the award terms and conditions as well as the legal, regulatory, sponsor, financial  and compliance requirements associated with the administration of the award.  Specific topics discussed during the PIM include the reporting requirements, sponsor terms and conditions, utilization of personnel, RIT procedures on use of project accounts, budget and cost share, and the Notice of Award (NOA) process.   At the conclusion of the meeting, the PI  signs the Terms and Conditions document to confirm in writing that he/she had an opportunity to review the information in detail and ask questions.  The signed Terms and Conditions document is retained by SRS in the project file.

3.6.2         Notice of Award (NOA) Form.  Within 28 days of an account request made to SPA, the PI and all project participants shall complete  an electronic acknowledgement of project pertinent details  within the RIT Rapid database and set forth on the OCESP portion of the SRS website at  http://www.rit.edu/research/srs/compliance/roc .  SRS shall use electronic media to inform all persons working on the project, whether paid or unpaid, of the pertinent details of funded projects.  Once submitted, SRS receives automatic notification and regularly provides the NOA summary information to the OCESP for review.

3.6.3         Reporting Effort / Changes in Effort.  PIs and project participants shall take diligent steps to ensure accurate reporting of effort in accordance with federal regulations (OMB Circular A-21 - Cost Principles for Educational Institutions) and other award requirements.  PIs and project participants shall promptly notify SRS if a significant change in the corresponding work activity is expected to occur.  OMB Circular A-21 defines significant changes as three months of no effort or a 25% differential from what was reported to the Sponsor.  However, individual sponsors may have more stringent or specific requirements.  PI's are required to review and certify a Quarterly Monitored Workload Report (QMWR) for each RIT employee whose salary or wage costs are charged to a federal grant or contract during the reporting period.  The effort report certification provides after-the-fact confirmation of employee activity allocable to each Federal award as required by OMB Circular A-21. If during review the PI determines that adjustments are needed, he/she is responsible for contacting Sponsored Programs Accounting so corrected effort reports can be prepared

3.6.4         Equipment Procurement and Monitoring.  Principal investigators may purchase equipment by completing a purchase requisition as described in the Procurement Manual - Requisition Process of Capital Equipment found in the Procurement Services website: http://finweb.rit.edu/purchasing/policies/manual.html#requisition6 . If the project is funded by a government entity the procurement process will comply with the regulatory requirements outlined in OMB Circular A-110 - Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations and any additional sponsor and program-specific requirements.

The Fixed Assets Department in the Controller's Office is responsible for maintaining accurate equipment records in the Oracle Fixed Assets module that contain identifier information, such as description of the equipment, serial number, source of equipment, whether title vests with the federal government, acquisition date, location, and payment source.

Annually, the PI or designee shall complete the University's fixed asset physical inventory by verifying the existence, location and continued need for the equipment.  The results of the inventory shall be reconciled to the information contained in the University's fixed asset system and the inventory reports returned to the Fixed Asset Analyst with appropriate notations of changes in location and retirements.  The Fixed Asset Analyst will follow-up on any discrepancies noted between the University's records and the physical inventory, as required.

3.6.5         Invention Disclosure.  As discussed at every PIM, if during the course of the project, a PI believes that he / she has invented something, information pertaining to that potential invention needs to be promptly disclosed to RIT's Intellectual Property Management Office using the RIT Invention Disclosure Form.  The form will be used to start the patent decision process and determine any required notifications arising inventions to sponsors and funding agencies.  The disclosure form and information pertaining to RIT's Intellectual Property Policies are available at http://www.rit.edu/research/ipmo/internal/forms.php .

3.6.6         Sub-recipient / Vendor Determination. If a PI seeks to subcontract with a sub-recipient, the PI shall work with SRS to analyze the potential subcontract. If a PI wishes to secure goods or services from a vendor, he/she should follow procurement procedures as outlined in the Purchasing Manual. If the PI needs assistance in determining if a outside party is a subawardee or a vendor, he/she should work with SRS and SPA staff and they will assist the PI to make the appropriate determination and develop a procurement method, i.e. a subaward or purchase requisition.

3.6.7         Technical Reporting.  The PI is responsible for timely submission of all technical reports and deliverables on a research project.  The PI will receive e-mail reminders from SRS in advance of known report due dates.  In the event that SRS becomes aware that a sponsor technical report is overdue, a series of escalating reminders and notifications will be sent to the PI, and eventually, his/her department chairs and/or supervisors, and ultimately the Vice President for Research as well as the Provost.

3.7               Close Out Process.  The PI shall manage the close out of the project with respect to the technical/substantive requirements, including the final report to the sponsor.  SPA is responsible for working with the PI to process all financial requirements for the close out of the project and any financial reporting.  All other non-technical reports or documentation required by the sponsor are coordinated with SRS, IPMO, and the PI.

3.7.1         Notification of Project End Date.  The PI shall receive a reminder notice from SPA ninety days prior to the end of the award.  The letter shall confirm the end date and inform the PI of any actions that may be required to expedite the close-out phase of the project and to ensure compliance with applicable sponsor and regulatory requirements.

3.7.2         Final Financial Report.  SPA shall also send a Final Grant Statement to the PI, which reflects the expenditures that have been recorded for the grant in the University's financial system. The PI is required to certify that the expenses are appropriate and in accordance with the provisions of the award.

3.7.3         Final Invoice. Once all final expenses have been processed, SPA shall send a final invoice to the sponsor, if one is required.

3.7.4         Return of Facilities & Administrative Cost Recovery Funds.  When final payment has been received from the sponsor and all certifications are complete, SPA shall  distribute the recovered F&A received from the sponsor according to the RIT procedure regarding return of Recovered F&A Costs: http://www.rit.edu/research/srs/grantsmgmt/Recovered_FA_Return.htm

3.7.5         Fixed Price Contracts.  If there is a surplus balance remaining on the project after all charges including the budgeted F&A costs have been posted, that is 10% of the modified total direct costs (MTDC) or $5,000 whichever is greater, SPA will request verification from the PI that all deliverables have been met and an explanation for the variance from the proposed budget.  If all deliverables have been met and the PI certifies the variance is a result of prudent cost management, SPA will retain the documentation in the project files and return the surplus to the PI's discretionary account.  If deliverables have not been met, SPA will ask the PI to work with SRS to negotiate a contract extension.

3.8               Compliance Considerations for a Federally-Sponsored Project.  PIs, project participants, SRS, and SPA shall be aware that if a project is federally-funded, additional laws, regulations, and guidelines are applicable, beyond RIT policies, that restrict how the funds are expended.  The implications for violating these regulatory and legal requirements are serious and are addressed in the training offered by SPA and SRS. 

3.8.1         Acceptance / Giving of Gifts.  All members of the RIT community associated with a sponsored research project shall refrain from giving or accepting any gift that is provided for the purpose of influencing a decision in connection with any federally sponsored grant or contract.  Such a gift may be viewed as bribery or an illegal kickback in violation of 41 U.S.C. § 53.  The term "gift" includes anything having monetary value, a gratuity, favor, discount, entertainment, hospitality, loan, or forbearance. 

Subject to the foregoing, members of the RIT Community associated with a federally sponsored research project may offer or accept a non-monetary gift or entertainment from the sponsor if the individual gift or entertainment has a value equal to or less than $20, with a limit of $50 in the aggregate for any calendar year.  Such non-monetary gift shall be permissible provided that it is reported to and approved by the Office of Legal Affairs and are related to a legitimate and identifiable business purpose. 

3.8.2         Accuracy in Reporting.  All members of the RIT Community associated with the reporting of expenditures to a government agency or to a sponsor shall make efforts to ensure the reported information is accurate.  The government places serious emphasis on accurate reporting, and the knowing or reckless disregard of a false submission for payment may be viewed as a violation the civil False Claims Act, 31 U.S.C. § 3729.  

3.8.3         Anti-Lobbying. All members of the RIT community who have access to government appropriated funds shall not utilize such funds to lobby any government employee or agency.  Such activity may be viewed as violating the Anti-Lobbying Act, 18 U.S.C. § 1913. 

3.8.4         Wage and Hour Determinations.  RIT  staff tasked with formulating wage and hour determinations shall ensure that their guidance and instructions relating to sponsored research construction projects is consistent with the Davis-Bacon Act,  29 C.F.R. §§ 1.5 and 1.6(b).

3.8.5         Allowability of Costs.  The PIs, his/her designee, and/or any other project personnel who expends or allocates costs on a sponsored project has ready access to training and other reference materials on OMB Circular A-21 available on the SPA website.  A-21 establishes principles for determining the allowability of costs applicable to grants, contracts, and other cooperative agreements with educational institutions.  The cost principles are intended to ensure that each party to the agreement bears its fair share of costs determined in accordance with generally accepted accounting principles, and as otherwise affected by law.  See http://www.whitehouse.gov/sites/default/files/omb/assets/omb/circulars/a...

For example, the costs of alcohol, RIT alumni activities, fund-raising activities and entertainment are "prohibited by law" and may not be included in the direct costs that are charged to the grant for reimbursement.

Principal investigators and grant and contract administrators are encouraged to attend training and made aware of the reference materials available through regular communications from the SPA department, including but not limited to, Project Initiation meetings, quarterly financial review meetings, individual outreach efforts, e-mail communications, memorandums, and newsletters.

3.8.6         Administration of Grants.  The PIs, his/her designee, and/or any other project personnel tasked with administrative or reporting obligations related to a sponsored project have access to training and other reference materials relating to compliance with OMB Circular A-110 available on the SPA and SRS websites.  A-110 sets forth standards for obtaining consistency and uniformity among Federal agencies in the administration of grants to, and agreements with, institutions of higher education, hospitals, and other non-profit organizations.  See http://www.whitehouse.gov/sites/default/files/omb/assets/omb/circulars/a... Examples of "grant administration" are A-110's requirement that RIT establish codes of conduct (which cover such topics as conflicts of interest and gratuities) and mechanisms for research performance reports and financial reports related to the grant.

Principal investigators and grant and contract administrators are encouraged to attend training and made aware of the reference materials available through regular communications from the SPA and SRS departments, including but not limited to, Project Initiation meetings, quarterly financial review meetings, individual outreach efforts, e-mail communications, memorandums, and newsletters, and formal PI Institute and SPARC training programs for PIs and project staff.

3.8.7         Auditing Standards.  University personnel responsible for the annual A-133 audit should be knowledgeable of the requirements prescribed by OMB Circular A-133. A-133 sets forth standards for obtaining consistency and uniformity among Federal agencies for the audit of States, local governments, and non-profit organizations expending Federal awards.  OMB Circular A-133 may be found at http://www.whitehouse.gov/omb/circulars/al33/al33.html and the A-133 Compliance Supplement is available at http://www.whitehouse.gov/omb/circulars_a133_compliance_09toc .

3.9               Compliance with RIT's Policies and Procedures.  All PIs and project participants are responsible for adhering to RIT's policies and procedures, including those listed below that relate to the administration of their award or agreement.  A PI may seek further assistance on these issues from SPA or SRS staff as applicable. Listed below are links to the sponsored research related policies and guidance that PIs and project participants are responsible for complying with while working on their project. These policies are in addition to any sponsor, federal, and/or state regulations which may also be applicable to the project, such as those referenced in Section 3.8.

3.9.1         RIT Compliance Policy and Code of Ethical Conduct - Refer to RIT's Policies and Procedures Manual to obtain this Policy:  http://www.rit.edu/academicaffairs/policiesmanual/sectionC/C0.html

3.9.2         Responsible and Ethical Conduct in Research guidance - Refer to the SRS website for detailed information about this:  http://www.rit.edu/research/srs/compliance/rcr and http://www.rit.edu/research/srs/compliance/rcr/rcrinfo.html

3.9.3         Oversight Policy for Externally Sponsored Projects Refer to RIT's Policies and Procedures Manual to obtain this Policy: http://www.rit.edu/academicaffairs/policiesmanual/sectionC/C1.html

3.9.4         Export Control Compliance Program - Refer to the Finance and Administration web site for detailed information about the Program: http://finweb.rit.edu/grms/compliance/export_compliance.html

3.9.5         Individual Conflicts of Interest Policy - Refer to RIT's Policies and Procedures Manual to obtain this Policy: http://finweb.rit.edu/grms/conflictsofinterest.html

3.9.6         Intellectual Property Policy - Refer to RIT's Policies and Procedures Manual to obtain this Policy: http://www.rit.edu/academicaffairs/policiesmanual/sectionC/C3.html

3.9.7         Non-Discrimination Policy - Refer to RIT's Policies and Procedures Manual to obtain this Policy: http://www.rit.edu/academicaffairs/policiesmanual/sectionC/C6.html

3.9.8         Misconduct in Research and Scholarship Policy - Refer to RIT's Policies and Procedures Manual to obtain this Policy:  http://www.rit.edu/academicaffairs/policiesmanual/sectionC/C2.html

3.9.9         Policy for Protecting Human Subjects in Research - Refer  to RIT's Policies and Procedures Manual to obtain this Policy: http://www.rit.edu/academicaffairs/policiesmanual/sectionC/C5.html Institutional Review Board (IRB) guidance - Refer to the Office of Human Subject Research web site for detailed information about the IRB: http://www.rit.edu/research/hsro/about_committees.php and http://www.rit.edu/research/hsro/forms.php

3.9.10     Policy for Gifts and Gratuities and Gifts in Kind - Refer to RIT's Purchasing Manual to obtain this Policy:  http://finweb.rit.edu/purchasing/policies/manual.html#general7

3.9.11     Hazardous Waste and Laser Safety Policy - Refer to the SRS website for this guidance:  http://www.rit.edu/research/srs/compliance/hazard_safety.html

3.9.12     Practice and Procedure for Processing Cost Transfers - Refer to SPA website to understand cost transfers: http://finweb.rit.edu/controller/sponsored/docs/costtransfers.pdf

3.9.13     Accounting for Grants and Contracts - Refer to RIT's Accounting Practices and Procedures Manual to obtain this: http://finweb.rit.edu/controller/accounting/docs/manual/13.pdf

3.9.14     American Recovery and Reinvestment Act of 2009 Process and Reporting Guidance - Refer to SPA for RIT procedures.

3.10           Training.  SRS and SPA provide workshops and training opportunities on an on-going basis for PIs and project administrators. The training reviews PI project oversight responsibilities including quarterly monitored work load reports, effort reporting, cost accounting, equipment accounting, conflicts of interest, the approval of expenditures, and applicable legal requirements set forth in Section 3.8.

PIs and research administrators are strongly encouraged to attend training workshops offered by SRS (the PI Institute) and SPA (SPARC training) throughout the year to familiarize themselves with issues and topics related to sponsor funding and research administration.  Offerings for prospective and current PIs are available at http://finweb.rit.edu/cpd as well as http://finweb.rit.edu/controller/training/sparc . Information on PI Institutes and Previously offered PI Institute session are available on http://www.rit.edu/research/srs/about/pi_institute .

3.11           Monitoring.  Within SRS, the Director, Associate Director, and the Compliance Specialist, assisted by the Office of Legal Affairs and other applicable departments, are responsible for examining and monitoring non-financial compliance issues and tracking any non-financial reports on sponsored projects.  SPA is responsible for examining and monitoring financial related compliance issues as well as financial-related reports on sponsored projects.  As part of this process, SPA shall monitor the effort reports and financial certifications submitted by the PI.

The review by SRS and SPA shall include an assessment of evolving and changing risks associated with the sponsored projects.  To the extent that risks are identified, recommendations shall be made to the appropriate Vice President to address the risk.

3.12           Auditing.  RIT's internal audit department shall use its regular schedule of audits of research issues to audit financial accounts and oversight procedures, as applicable, to ensure that  Externally Sponsored Projects follow RIT policy. 

4.0               REPORTING POTENTIAL NON-COMPLIANCE INCIDENTS 

All members of the RIT community are expected to raise any questions and report to the PI any potential or perceived violations of this Policy, or any federal, state, local law, or regulation.  If unresolved, or the matter is a complaint that involves the PI, then the question or concern shall be forwarded to the Vice President of Research.  Violations of this Policy or any federal, state, local law, or regulation must be reported pursuant to RIT Policy C0.0: http://www.rit.edu/academicaffairs/policiesmanual/sectionC/C0.html

If credible evidence of a violation of a federal criminal law involving fraud, bribery or gratuities, false claims or a conflict of interest exists and such violation is in connection with a federal grant or contract, then this evidence of a violation shall be reported to the applicable agency. 

5.0               AMENDMENTS  TO POLICY

Substantive changes to this Policy shall be made by the appropriate Vice President and reported in other appropriate vehicles to ensure full knowledge by the RIT Community. 

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