ADMINISTRATIVE POLICY AND PROCEDURES
FOR EXTERNALLY SPONSORED PROJECTS
AT ROCHESTER INSTITUTE OF TECHNOLOGY
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.
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.
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.
3.2.1 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 Centers An Enterprise Center is a Controller’s Office approved, primarily self-supported Operational Unit on campus that conducts 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 substantial enough that it is not efficient to prepare a scope of work/job description and Proposal Review Form for each project. A list of current Enterprise Centers can be obtained from SRS..
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. The PRF is updated periodically to comply with sponsor and RIT policies. The PI is required to use the most recent version available on the SRS website at time of application. SRS reserves the right to request resubmission of the PRF if an earlier version is submitted.
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.
3.2.9 Terms & Conditions Summary (T&C) is an SRS prepared document summarizing the pertinent sponsor and RIT requirements governing the project. The document is presented and reviewed with the PI at the Project Initiation Meeting (see 3.6.1). It includes applicable compliance requirements associated with the project and a listing of the reports required by both the sponsor and RIT. The PI signs the document acknowledging that they will adhere to the terms and conditions and will be responsible for ensuring that all other project faculty, staff, and students are aware of these.
3.3 Responsible Parties. In general, PI's, Co-PIs, and Senior Personnel 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. The foregoing applies to all designated RIT Co-Principal Investigators (Co-PI).
18.104.22.168 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, Emeritus Faculty, and students.
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 Senior Personnel. Senior Personnel are responsible to fulfill their obligations as set forth in the proposal and on the project as directed by the PI. Senior Personnel and their Operational Units are required to sign the PRF.
3.3.3 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/contact for a detailed account of the support SRS provides PIs.
3.3.4 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.
3.3.5 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.
3.3.6 Research Compliance Committee (RCC). The RCC is responsible for the implementation and administration of the Externally Sponsored Projects Disclosure Policy 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/section-c-general-inst.... The RCC is responsible for conducting a 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.
3.3.7 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.
3.3.8 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/proposal-preparation
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 https://www.rit.edu/research/srs/proposalprep/howto_budget
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. Signatures are required from the PI, Co-PI(s), Senior Personnel and the associated department, college and administrative approvals. 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.
22.214.171.124 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 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.306.
126.96.36.199 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 Uniform Guidance, 2 CFR 200, Appendix III.
188.8.131.52 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.
184.108.40.206 Subaward Documentation. If a subaward is proposed on an externally funded project, a budget, scope of work, and signed letter of commitment will be required from each subrecipient before the PRF can be fully approved. SPA or SRS may require additional documentation at the pre-award stage depending the size and nature of the subaward. Due to the difficulties in documenting the rates and breakdown of expenses for audit purposes, it is unlikely that RIT would be able to issue a subaward to a single member LLC.
3.4.4 Signatory Approvals for Proposals, PRFs, and Agreements. If a proposal will be funded with federal or state 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 or state 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 or state 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 GIS and the Director of IPI may approve non-government proposals and standard agreements of $50,000 or less provided the PRF for the project is approved by SRS or the project is included in an SRS approved roll-up listing. (d) All projects over $50,000 require a proposal and PRF which must be approved by SRS and the VPR. (e) All agreements, regardless of value, involving federal or state government funding require the signature of the VPR. (f) All agreements over $5,000 that do not involve federal or state governement funding, require the signature of 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, conflict of interest, export control, recombinant DNA, 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 propos