401 Administration of Sponsored Projects
Approved by President
Effective Date: June 5, 2017
Responsible Division: Academic Affairs
Responsible Office: Vice Provost for Research
Responsible Officer: Vice Provost for Research
Middle Tennessee State University (MTSU or University) is committed to excellence in instruction, research, and public service. MTSU recognizes that externally-funded instruction, research, and service are essential to fulfilling the higher education mission of creating and disseminating knowledge and innovation for the benefit of our students, faculty, and society at-large. MTSU recognizes that student engagement in mentored research and service is a best practice that improves student success at MTSU and beyond. Accordingly, MTSU encourages faculty and administrative employees to pursue extramural funding to support research, other scholarly and creative activities, training, and public service projects through grants, cooperative agreements, and contracts, collectively known as sponsored projects. Toward that end, MTSU is committed to provide administrative and technical support, across all academic and business units, necessary to ensure the success of each sponsored project.
This policy sets forth the roles and responsibilities of employees and departments, and other requirements by which MTSU pursues and administers sponsored projects. It is MTSU’s policy to comply with all applicable requirements of federal, state, and private sponsors in the pursuit and administration of sponsored projects. This policy does not apply to gifts and donations.
Implementation and maintenance of this policy are the responsibility of the Vice Provost for Research and the Office for Research Services (ORS). ORS will publish and maintain a written Guide to Sponsored Programs at MTSU which sets forth MTSU procedures and standards regarding the implementation of this University policy. See Policy 224 Employee Compensation Charged to Sponsored Projects.
A. Authorized Organizational Representative (AOR). Attests to certifications and assurances required by a sponsor at the time of proposal submission, including that the contents of the proposal are accurate and comply with University policies, and that the University will comply with the sponsor’s terms and conditions. The Director of ORS is MTSU’s AOR. This role may be identified as the signing official in some sponsors’ grant-making processes but is not synonymous with the authorized signatory or authorized official.
B. Authorized Signatory or Authorized Official. Authorized by the University to legally obligate the University to enter into a contract to receive or expend funds. The President and the Vice President for Business & Finance are MTSU’s authorized signatories.
C. Award. A general term referring to grants, cooperative agreements, and contracts by which a sponsor provides financial support to MTSU for activities carried out by MTSU.
D. Contract. Legal document by which a sponsor procures goods or services, typically pursuant to a specific scope of work, budget, and time period of work; typically resulting in a specified deliverables for the benefit of the sponsor.
E. Cooperative Agreement. An award similar to a grant, but in which the sponsor is actively involved in proposal preparation and may have substantive involvement in the funded research or service activities, for the benefit of the sponsor and the public.
F. Cost-Share. Also known as cash-match. The recipient funds support a portion of expenses of a sponsored program that is for activities carried out by the recipient on behalf of the sponsor. See also in-kind contributions and matching funds.
G. Direct Costs. Expenses that are directly and uniquely allocable to, and necessary for, the completion of a sponsored program, including, but not limited to, salaries and wages, fringe benefits, consultants, travel, equipment, supplies, and participant-support costs.
H. Federal Acquisition Regulations (FAR). Federal regulations governing the administration of federal contracts for the procurement of goods and services.
I. Fixed-Price Contract/Grant. Contract/grant by which the sponsor agrees to pay a firm predetermined price for an agreed upon scope of work, outcomes, and/or deliverables.
J. Grant. Award of financial assistance, by which the sponsor supports a program of research or public service, pursuant to a scope of work and budget, which may or may not include specific deliverables, and is performed on behalf of the sponsor for the benefit of the public.
K. In-Kind Contribution. The use of University resources to conduct a sponsored program on behalf of the sponsor without reimbursement or compensation from the sponsor. This might include the use of specialized instrumentation or facilities, graduate student tuition waivers, and faculty re-assign time away from normal duties for time spent on a sponsored program while the University continues to pay their salary and benefits. Also includes unrecovered indirect costs. See also cost-share and matching funds.
L. Indirect Costs. Also known as facility and administration (F&A) costs, or overhead, are costs that cannot be uniquely attributed to a particular sponsored program, but which are nonetheless incurred by MTSU because of the sponsored program. They include costs for shared services and facilities, such as accounting and business processes, computer network, equipment depreciation, building and facilities operation and maintenance, and library resources. Indirect costs are budgeted and charged as a percentage of each sponsored program’s direct costs.
M. Matching Funds. Financial support provided by the recipient for activities necessary to the fulfillment of a sponsored program. Matching funds may be provided as cash-match or cost-share, or in-kind contributions. Matching funds may be required by the sponsor or provided voluntarily by the recipient. If matching funds are required by the sponsor and/or enumerated in a proposal and resulting award document, the matching is considered committed match and must be accounted separately. See also cost-share and in-kind contributions.
N. Notice of Grant Award or Notice of Award or Award Notice. The legally binding document that notifies the grantee and others that an award has been made, contains or references all terms and conditions of the award, and documents the obligation of federal funds. The notice of grant award may be issued in hard-copy or electronic format. A notice of grant award may or may not require authorized signature by the recipient.
O. OMB Circular A-81 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Sets forth the underlying guidelines and principles for the administration of federal grants and cooperative agreements.
P. Principal Investigator (PI). Person responsible for the intellectual content and administrative leadership of a sponsored program. The PI accepts overall responsibility for directing the research, the financial oversight of the award's funding, as well as compliance with relevant University policies and federal regulations, as well as, sponsor terms and conditions of an award.
Q. Project Director (PD). Person responsible for the programmatic content and administrative leadership of a sponsored program. The PD accepts overall responsibility for directing the project, the financial oversight of the award, as well as, compliance with relevant MTSU policy and sponsor terms and conditions.
R. Prior Approval. Written documentation of permission to deviate from MTSU policy, award terms, and/or conditions of a sponsored program.
S. Sponsored Program. Activities carried out by MTSU employees and funded by an entity other than MTSU by way of a grant, cooperative agreement, or contract.
III. Eligibility to Serve as Principal Investigator and Project Director
Full-time faculty with the titles Professor, Associate Professor, Assistant Professor, Chair of Excellence, Clinical Faculty, or Research Scientist are eligible to serve as PI of sponsored projects. Additionally, Professors Emeriti and faculty with active-retiree status are eligible to serve as PI for sponsored projects. In addition to the aforementioned faculty, full-time, salaried administrative and professional employees, whose responsibilities include financial and personnel supervisory authority, may be eligible to serve as PD of sponsored projects, pursuant the sponsor’s description of duties for a PD.
In order to serve as PI for the submission of a proposal or acceptance of an award, an eligible employee must also be current on required trainings, certifications, and disclosures identified in the Guide to Sponsored Programs at MTSU.
Exceptions to these eligibility requirements may be requested in writing from the Vice Provost for Research and require the endorsement of the Provost and the respective supervising Department Head and Vice President.
IV. Office of Research Services
The Office of Research Services (ORS) is the coordinating department for all aspects of sponsored projects at MTSU, from the development and submission of proposals through the administration of awards. Prospective PI’s/PD’s should contact ORS at the time they decide to pursue any particular funding opportunity. ORS provides direct assistance and support to PI’s/PD’s during proposal submission and award administration and dual control to PI’s/PD’s responsibilities for compliance and project management on behalf of MTSU and the sponsor.
V. Proposal Development and Submission
A. Proposal Development. The PI/PD is responsible for the quality and accuracy of proposal content. The PI/PD is required to consult with ORS pre-award personnel sufficiently in advance of the proposal submission deadline in order to allow for ORS review of application guidelines and to provide input into the proposal preparation, including the budget. Completed proposals, including budgets, must be approved by the Director, ORS prior to submission.
B. Cost Sharing. Whenever possible, PI/PD will request the entire cost of the proposed activity from the sponsor. Waiver of this requirement may be considered under two (2) conditions: 1) the sponsor requires or encourages the recipient to share the cost of the proposed activity and/or to provide in-kind contribution, or 2) extenuating circumstances warrant the voluntary use of MTSU resources to augment the funding available from the sponsor in order to ensure successful completion of the proposed sponsored program. When proposing or requesting cost sharing, whether the cost sharing is required or voluntary, cash match or in-kind contribution, the PI/PD must secure prior to proposal submission written commitment from the persons authorized to commit the proposed cost share resources, i.e., Director ORS, Department Chair, College Dean, VPR, Provost, or third-party. ORS has limited funds available for cost share by way of the University budget and indirect cost recovery.
C. Proposal Submission. Unless otherwise required by the sponsor, proposals must be submitted by ORS on behalf of the University and PI/PD. The Director for ORS signs proposals for the University as authorized organizational representative to certify that the contents of the proposal are accurate and comply with University policies and guidelines, and that the University will comply with the sponsor’s terms and conditions and other requirements.
D. Limited Submissions and Internal Competition. In the event that a sponsor limits the number of proposals allowed from a single institution, the Director for ORS will coordinate the selection of the allowed number of proposals though a deliberative process that may involve the Provost, Vice Provost for Research, respective College Deans, ORS personnel, and faculty.
VI. Indirect Costs
A. Inclusion in Sponsored Program Budgets
It is MTSU’s policy to require the inclusion of full indirect cost recovery in all proposals for external funding, pursuant to MTSU’s federal negotiated Indirect Cost Rate Agreement in effect at the time of proposal submission. MTSU’s federal negotiated Indirect Cost Rate Agreement is available from ORS.
B. Exceptions. Budgets for sponsored projects may use indirect cost rates that are less than the federal negotiated indirect cost rate with prior approval under one (1) or more the following conditions:
1. The sponsor imposes a limit on the allowable indirect cost rate or the total indirect cost per award (requires prior approval by the Director for ORS);
2. The sponsor disallows indirect costs (requires prior approval by the Director for ORS);
3. The University voluntarily reduces or waives indirect cost rate at the request of the PI/PD as being essential to accomplishing the proposed project’s objectives within the funding limits of the award, including using waived indirect costs as sponsor-required in-kind match (requires prior approval by the Vice Provost for Research).
C. Distribution of Recovered Indirect Costs. It is MTSU’s policy to distribute recovered indirect costs across University units in order to strategically maintain and expand MTSU’s competitiveness and capacity for sponsored projects. It is the intention of this policy that recovered indirect costs will be used to support expenses including, but not limited to, the operation, maintenance, and acquisition of research instrumentation, equipment, and facilities (particularly core research facilities); personnel such as graduate research assistants, post-doctoral researchers, and visiting researchers to directly support the generation of proposals for sponsored projects; and required or voluntary matching funds to ensure the success of sponsored projects.
The practice of not returning the majority of recovered indirect costs to the operating budget represents a significant recurring investment by the University in sponsored projects.
The Vice Provost for Research, in consultation with the Provost, is responsible for the indirect cost recovery distribution pursuant to guidelines published by the Vice Provost for Research and available from ORS.
VII. Award Administration
Unless specified in the award document as a grant to an individual, all grants and contracts are awarded to MTSU.
Awards resulting from proposals should be forwarded to ORS, either directly from the sponsor or by the PI/PD, or other entity on campus which might receive them from the sponsor. ORS will review the award to ensure consistency with the proposal and proposed budget, and MTSU’s ability to comply with the award terms and conditions, including invoicing and reporting. ORS will confirm awarded scope of work and budget with the PI/PD. ORS will communicate with the sponsor to resolve discrepancies between the scope of work and/or budget as proposed versus awarded, to negotiate amendment or removal of unacceptable terms and conditions, or to seek clarification of unexpected special terms and conditions.
Many federal award notifications and some private foundation award letters do not require official acknowledgement by MTSU authorized signatories but are rendered to be in effect in the absence of rejection or request for modification of the award notice by MTSU.
For awards and contracts that require authorized signatures, ORS will forward the reviewed/amended documents (with notes regarding communication with sponsor or requested deviation for MTSU practice) to the MTSU Contract Office for further review regarding State of Tennessee and MTSU legal and business policies and practices. The Contract Office may further communicate with the PI/PD and/or sponsor to further amend or clarify the award.
ORS will forward awards that have been approved by ORS and the Contract Office to the sponsor for signature. Awards that have been signed by the sponsor will be forwarded to the PI/PD department by ORS to be routed for MTSU approval through MTSU’s workflow system.
The University President and the Vice President for Business and Finance are the University’s only authorized signatories. Except when signature by the President or CEO is required by the sponsor, the Vice President for Business and Finance shall sign awards and contracts on behalf of MTSU.
VIII. Applicable University Policies
References: Policies 80 Export Control; 137 Classification of Awards as Gifts or Grants/Contracts; 140 Intellectual Property; 211 Misconduct in Scholarly Activities and Research; 224 Employee Compensation under Sponsored Projects; 402 Protection of Human Subjects in Research; 403 Animal Care and Use in Research and Testing; 405 Oversight of Dual Use Research Concern; 665 Cost Transfers Guide for Sponsored Programs; 814 Outside Employment, Extra Compensation, and Dual Services Agreements.