Subject  Grants and Contracts

POLICY GUIDELINES FOR THE DEVELOPMENT AND ADMINISTRATION OF
GRANTS, CONTRACTS, AND RESTRICTED GIFTS
FOR SPONSORED PROGRAMS IN
INSTRUCTION, RESEARCH AND PUBLIC SERVICE.

Development and Administration of Grants, Contracts and Cooperative Agreements For Sponsored Program DOC.T94-034

Purpose
     These policy guidelines establish principles essential for the sound management and administration of grants, contracts, and restricted gifts for sponsored University programs in instruction, research, and public service. They provide appropriate controls for the development of proposals and applications; procedures and criteria for the acceptance of grants and contracts for sponsored programs; and prudent and effective administrative and accounting controls for grant, contract, and restricted gift administration. These guidelines assign responsibility and accountability to organizationally separated offices and individuals for each step in the administrative process.

     The University engages in and benefits from a wide variety of programs, projects, and other activities which are supported by funds from external agencies and organizations. Such programs are not part of the continuing budget process for the state appropriated funds used by the University. Funds received for such programs are held in trust by the University and are separately budgeted and accounted for. The mechanisms used by external organizations to provide support are categorized into three types: Grants, Contracts and Restricted Gifts.

     The University's management procedures for the three general mechanisms are essentially the same. Each is treated by the University as a specification of obligations which requires separate accountability for expenditures and evidence of performance consistent with the intentions of the sponsor.

Application
     These guidelines supersede existing policies and procedures for administration of sponsored programs in research , instruction and public service. They apply to all grants, restricted gifts, and contracts for such programs and to all organizational units (i.e., colleges, schools, departments, centers, institutes, trust-funded activities, and programs) of the University, wherever located.

Organization
     The office of the Vice President for Management shall have responsibility for university-wide conformance with these guidelines. The Offices of Vice Chancellors for Administration and Finance shall

Date:    10/1/90                              Page:    1.2.2

Subject  Grants and Contracts

POLICY GUIDELINES FOR THE DEVELOPMENT AND ADMINISTRATION OF
GRANTS, CONTRACTS, AND RESTRICTED GIFTS
FOR SPONSORED PROGRAMS IN
INSTRUCTION, RESEARCH AND PUBLIC SERVICE.

have responsibility for campus-wide conformance with these guidelines. The campus OGCA Directors, the campus Financial Affairs Directors or Controllers, the University Controller, and the Vice President for Management shall constitute the primary University system group which establishes practices and procedures to implement these guidelines. Each of the campuses will continue to have an Office of Grant and Contract Administration (OGCA) reporting to the Vice Chancellor for Administration and Finance, or in the case of the Medical School, to the Associate Dean for Scientific Affairs. The Directors of Grant and Contract Administration shall provide support services to campus researchers and directors of sponsored projects and, in collaboration with the Campus Financial Affairs Director/Controller, shall effect University conformance with responsible fiscal management practices.

Administrative Responsibilities
     The campus OGCA Directors and Controllers are assigned specific responsibility for pre- and post-award administration of grants, restricted gifts, and contracts. The OGCA Director at each campus is the authorized institutional official having the sole responsibility for submitting proposals and applications to funding agencies.

     Sponsored programs are essential and integral to research, instruction, and public service in the academic setting. A primary function of the OGCA therefore is to support the University's principal investigators, both in their relationships with outside funding sources and in their dealings with other University administrative units. OGCA may provide a variety of services on the campus, including but not limited to: identifying potential sources of funding, deadlines, and filing requirements, and agency priorities and programs.

     Each Office of Grant and Contract Administration is responsible for preparation of campus procedures for pre- and post-award related activities. Such procedures should be as uniform as possible for all campuses of the University but may differ to the extent called for by the differing circumstances of the campuses. The procedures must be in accord with all University-wide administrative policies which affect grant and contract management (i.e., Personnel, Purchasing, and Accounting). The OGCA Directors and Campus Controllers shall serve as the only points of contact between the campuses and funding agencies on administrative and financial matters. 

Date:    10/1/90                              Page:    1.2.3

Subject  Grants and Contracts

POLICY GUIDELINES FOR THE DEVELOPMENT AND ADMINISTRATION OF
GRANTS, CONTRACTS, AND RESTRICTED GIFTS
FOR SPONSORED PROGRAMS IN
INSTRUCTION, RESEARCH AND PUBLIC SERVICE.

     The OGCA's shall participate in the preparation of annual studies of indirect costs, cost sharing, employee benefits, and equipment matching funds. Each of these studies requires that data collection, analysis and other documentation be performed in a consistent manner at each campus. The OGCA Director shall have the responsibility for final certification of project budgets and for determining whether amendments or revisions to project budgets shall be subject to the internal review procedures required for initial projects. Requests for budget changes which require prior agency approval shall be prepared by the principal investigator and endorsed by the OGCA Director. The principal investigator for a sponsored project shall be responsible for administering the project in conformance with the approved budget. The Campus Controller shall not process disbursements on any account (except reimbursable contracts) unless funds are available or unless approval for transfer or advances has been given in accordance with the budgets and these guidelines; such approval is subject to review by the OGCA Director.

Procedures

Pre-award
     Each campus will establish internal procedures for sponsored project administration implementing these policies, maintaining consistency among the campuses to the extent possible. These procedures must include the designation of individuals for campus programmatic and budgetary review and approval of proposed projects. The programmatic aspects of proposals must be approved first by the appropriate Chairman (or equivalent) and then by the Dean of the School or College; or, in the case of the Medical School, by the Associate Dean for Scientific Affairs. This review should ensure that the proposal is consistent with the activities of the department or college and should also assess the impact of the project upon the future resources of the organization and any change in the level of institutional support which may result from the acceptance of an award. Prior to signing, the Chairman and the Dean must confirm the availability of space, major technical resources and equipment, institutional support personnel, and endorse commitments for cost sharing, matching funds, or any proposed retention of project-supported personnel after the expiration of the award. If such confirmations and endorsements cannot be made, the Chairman or Dean should refer the proposal to other appropriate campus officials for resolution.

 Date:    10/1/90                              Page:    1.2.4

Subject  Grants and Contracts

POLICY GUIDELINES FOR THE DEVELOPMENT AND ADMINISTRATION OF
GRANTS, CONTRACTS, AND RESTRICTED GIFTS
FOR SPONSORED PROGRAMS IN
INSTRUCTION, RESEARCH AND PUBLIC SERVICE. 

     Programmatic and budgetary review of proposals generated by such organizational units as Institutes, Centers, and Programs shall be performed by the administrator to whom the unit head reports. Project proposals generated by Institutes, Centers, or Programs which report to administrators of the President's Office but that involve activities at any campus of the University, shall be reviewed by appropriate officials at that Campus prior to submission to the sponsor.

     In the preparation and submission of proposals, the following provisions shall apply:

1. Proposals must conform with the policies of the Board of Trustees and of the University Administration.
   
2. The OCGA Director shall review and approve proposed contracts prior to their acceptance by the University. Legal review, when requested by the OGCA Director, shall be performed by the University Counsel or by designated Counsel.
   
3. An Internal Processing Form (IPF) shall accompany all proposals through the review process. This form shall summarize pertinent data from the proposal and provide signature lines for reviewers to register their approval.
   
4. The OGCA Directors will work directly with the Development officers to coordinate the submission of proposals and applications to funding agencies for the entire institution. The OGCA Directors, Development officers, and Controllers are to serve as the only points of contact with funding agencies for administrative and financial matters.
   
5. Proposals for projects which will have a pronounced impact upon the goals and programs of the University shall, upon completion of appropriate campus review, be reviewed by the Senior Vice President for Academic Affairs. These reviews shall be performed when the OGCA Director determines that the proposed project has one or more of the following characteristics:

Date:    10/1/90                              Page:    1.2.5

Subject  Grants and Contracts

POLICY GUIDELINES FOR THE DEVELOPMENT AND ADMINISTRATION OF
GRANTS, CONTRACTS, AND RESTRICTED GIFTS
FOR SPONSORED PROGRAMS IN
INSTRUCTION, RESEARCH AND PUBLIC SERVICE.

1. The Chancellor or his delegate shall review and approve proposals which include University commitments for new professional staff positions, matching funds in excess of $50,000, or substantial construction or renovation.
   
2. In no case shall any project proposal be transmitted to a sponsoring agency without the signature of the OGCA Director.
   
3. The new guidelines provide that only the Chancellors or their designees shall sign the cover page of all applications and proposals whether an institutional authority is required by the proposal sponsor or not.

Post-award

1. Establishing Accounts - The University Controller is the authority for establishing accounts of the University.
   
2. Request and Receipt of Payments - All University billings, letters of credit or other requests for payment under grants, restricted gifts, and contracts for sponsored projects, shall only be in the name of the University of Massachusetts followed by the address of the Campus Bursar's Office. Billings under letters of credit shall be signed by the Treasurer. Without exception, billings, letters of credit and requests for payment shall be prepaid by the campus accounting office. All payment received on account for sponsored projects shall be deposited by the appropriate campus Bursar's Office to bank accounts designated by the Treasurer of the University. No one other than the Treasurer of the University has authority to open any bank account for any monies received or held on account of the University of Massachusetts irrespective of the source of funds. Anyone receiving any monies due the University shall immediately forward them to the campus Bursar.

Date:    10/1/90                              Page:    1.2.6

Subject  Grants and Contracts

POLICY GUIDELINES FOR THE DEVELOPMENT AND ADMINISTRATION OF
GRANTS, CONTRACTS, AND RESTRICTED GIFTS
FOR SPONSORED PROGRAMS IN
INSTRUCTION, RESEARCH AND PUBLIC SERVICE.

3. Disbursements - All disbursements shall be in accordance with the University policy and procedures, including those in the Manual of Accounting Instructions. Signatures of principal investigators and other employees authorized to sign shall be placed on file in the campus Controller's Office. All personnel action forms shall have two signatures, the original signature of the principal investigator and the original signature of the Department Head or Dean. Authorizations for payments not involving personnel require only the signature of the principal investigator. In the event of absence, the names of individuals temporarily authorized to sign shall also be placed on file, but in no event shall this permit the signing of disbursement authorizations by other than those with University spending authority under the campus budget system.
   
4. Accounting and Financial Reporting - The accounting for all grants, restricted gifts, and contracts shall be by the respective campus Accounting Office. The University Controller shall issue detailed accounting instructions and procedures. The campus Controller shall issue all financial reports to the sponsoring agencies. The University financial accounting system will constitute the official record of financial transactions.
   
5. Each Chancellor shall establish the indirect cost rates applicable to projects supported by federal agencies and non-federal sponsors respectively on his/her campus. A copy of the rate agreement and the cost basis analysis shall be sent to the President annually. These rates shall not be varied or waived without prior written approval of the appropriate Office of Grants and Contracts Administration Director.
   
6. Cost Sharing - It is the policy of the University to cost share only the dollar value of contributed faculty or professional staff time during a project period, together with the associated indirect costs, which is paid from State or other non-Federal funds. In cases where a particular sponsor restricts the recovery of indirect costs by the University, the unrecovered portion of those costs may be shown in the project budget as cost sharing. In instances where the cost sharing requirements of a sponsor are such that the University cost sharing from usual sources is insufficient, the principal investigator and the OGCA Director will prepare a statement of University participation.

Date:    10/1/90                              Page:    1.2.7

Subject  Grants and Contracts

POLICY GUIDELINES FOR THE DEVELOPMENT AND ADMINISTRATION OF
GRANTS, CONTRACTS, AND RESTRICTED GIFTS
FOR SPONSORED PROGRAMS IN
INSTRUCTION, RESEARCH AND PUBLIC SERVICE.