OLPM

UNH.IV  Financial Policies
(Note: OLPM sections on this page may be cited following the format of, for example, "UNH.IV.B.1.1". These policies may be amended at any time, do not constitute an employment contract, and are provided here only for ease of reference and without any warranty of accuracy. See OLPM Main Menu for details.)

B. Sponsored Program Administration

1.   Grants, Contracts, Other Sponsored Agreements

1.1   Definition: A grant, contract, or other sponsored agreement is a written agreement representing the voluntary transfer of money or property by a sponsor in exchange for the specifically enumerated performance of services, often including rights and access to results of this performance, and always including some formal financial and/or technical reporting by the recipient as to the actual use of money or property provided. The agreement is enforceable by law, and performance is usually to be accomplished under time and fund use constraints with the transfer of support revocable for cause.

1.2   Policy: If any one of the following indicators exists, the Sponsored Program Administration (SPA) shall have responsibility for solicitation, negotiation, receipt, and administration of the grant, contract, or other sponsored agreement (hereinafter referred to as "award") on behalf of the University of New Hampshire (University), with the exception of student financial aid awards.

1.2.1   The original source of the award is a governmental or quasi-governmental entity, the exception being the State of New Hampshire for the University's biennial and capital budgets.

1.2.2   The award is from a private sector sponsor and is characterized as follows:

1.2.2.1   The award will support the work of a specific faculty or staff member(s) and requires the use of University facilities or other resources.

1.2.2.2   The work scope and programmatic goals are defined in the proposal and/or award document.

1.2.2.3   The work is to be accomplished within a specific time and budget framework.

1.2.3   The award is a fellowship or quasi-fellowship, resulting from a competitive proposal process, for which compensation to the "fellow" is made through the University's payroll system.

1.2.4   The award is for equipment resulting from a competitive proposal process and requiring a financial, performance, or use/disposition report.

1.2.5   The sponsor places restrictions on the use of funds or property and/or retains the right to revoke the award in part or in total. Examples of restrictions include disallowance of pre-award costs, requirement of sponsor's prior approval for deviation from originally approved budget items, return of any unexpended funds to the sponsor at project period end, or restrictions on publication of data from studies supported by the award.

1.2.6   A detailed fiscal or activity report or external audit is required at intervals during and/or at the end of the project period.

1.2.7   The award supports studies to be conducted on substances, products, processes, etc., owned by the sponsor.

1.2.8   The agreement provides for either the transfer or disposition of tangible property (e.g. biological materials, equipment records, technical reports, theses or dissertations), and/or intangible property (e.g. rights in data, copyrights, inventions) which may result from the activities being sponsored. (Refer to the University's "Intellectual Property" policy.)

1.2.9   The sponsor expects to gain direct economic benefit as a result of the activity to be conducted under the agreement, and the expense is perceived by the company as a "cost of doing business" rather than a charitable gift. The award and related documents, if any, reflect this intent. (Refer to UNH Foundation, Inc., policy on "Gifts or Donations" appended for informational purposes to UNH III.C)

1.3   Procedures

1.3.1   Any proposal that would result in an award as specified above must be routed with a completed "University of New Hampshire Request for Internal Approval of Grant or Contract application to External Sponsor" form for endorsement by the appropriate department or unit head and approval by the appropriate institute/center director, college/school dean, vice president, or Provost.

1.3.2   The completed proposal and form are then routed to SPA.

1.3.3   Prior to submission to an external sponsor, the completed proposal is reviewed by SPA for compliance with University policies, prospective sponsor requirements, and all applicable laws and regulations.

1.3.4   For each proposal approved for submission to a prospective sponsor, the authorized SPA individual or the Vice President for Research and Public Service signs the routing form and all required sponsor forms on behalf of the University.

1.3.5   SPA submits the proposal package to the prospective sponsor.

1.3.6   SPA negotiates the award terms and conditions on behalf of the University.

1.3.7   If appropriate, SPA or its designee provides the sponsor with acknowledgement of the award.

1.3.8   SPA and the project director have joint responsibility for financial and administrative aspects of the award, while the project director is solely responsible for the technical requirements of the award. SPA interacts with the sponsor on behalf of the University.

1.3.9   SPA provides stewardship functions and maintains records that can be audited.

2.   Cost Transfers on Externally Sponsored Programs [ Changed. See UNH VIII.R ]

3.   Supplies Charged to Federally Sponsored Agreements [ Changed. See UNH VIII.Q ]

4.   Not-fully-executed Spending Accounts on Externally Sponsored Programs [ Changed. See UNH VIII.O ]

5.   Salaries, Wages, and Fringe Benefits Charged to Federally Sponsored Agreements

5.1   Definitions: Salaries, wages, and fringe benefits are compensation paid currently or accrued by the University for employee services rendered. Fringe benefits also include University contributions or expenses for social security, retirement plans, health and life insurance, workers' compensation, tuition, benefits administration costs, and other staff benefits.

5.2   Policy: In accordance with OMB Circulars A-21 and A-110, all salaries, wages, and related fringe benefits charged to a federally sponsored* agreement must meet all four of the following criteria in order to be allowable as direct charges:

5.2.1   Reasonable. The employee services must be necessary for the performance of the sponsored agreement. The cost must conform to all applicable government requirements and be consistent with institutional policies.

5.2.2   Allocable. The employee services are solely to advance the work of the particular sponsored agreement during its performance period. If the personal services benefit more than one program or activity, the compensation must be allocated proportionately to each one according to the degree of benefit. However, if the benefit to an individual program or activity cannot be determined due to the interrelationship of the work involved, the cost may be allocated to benefited projects on reasonable bases.

5.2.3   Consistent. The compensation must be treated consistently as either a direct or indirect cost in like circumstances throughout the institution.

5.2.4   Limitations. The compensation must conform to limitations imposed by the sponsor's policies and the agreement itself.

5.3   Categories. University employees are faculty, extension educators, librarians, professional/administrative/technical staff, clerical staff, students, and non-student labor.

5.3.1   Salaries, wages, and related fringe benefits are normally charged directly to a sponsored agreement for those employees performing the research, scholarly, or outreach activities for that agreement.

5.3.2   Charges follow the level of effort on the project and include reasonable amounts for activities contributing and closely related to work under the agreement such as conducting laboratory research, delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences.

5.4   Administrative and Clerical Compensation (business and financial staff)

5.4.1   Such compensation is normally charged indirectly to sponsored agreements through the institution's federally negotiated facilities and administrative (F&A) cost rate. However, in extraordinary circumstances, such compensation and associated fringe benefits may be charged directly to the sponsored agreement if the employee services are:

5.4.1.1   Essential to the project's programmatic or technical purpose

5.4.1.2   Explicitly identified with the project

5.4.1.3   Approved by the Sponsored Program Administration (or New Hampshire Agricultural Experiment Station or New Hampshire Cooperative Extension for USDA land grant appropriations) to meet the University consistency standard, and

5.4.1.4   Explicitly approved or not specifically disapproved by the sponsor, as reflected in the award budget.

5.4.1.4.1   Examples: It may be allowable to directly charge a sponsored agreement for a program assistant or program support assistant whose function is directly related to the purpose of the agreement, such as assisting with a conference or staffing a program administrative office.

References:
OMB Circular A-21:    C.2        Factors affecting allowability of costs
                      C.3        Reasonable costs
                      C.4        Allocable costs
                      C.7        Limitations on allowance of costs
                      C.11       Consistency in allocating costs incurred for the same purpose
                      D.1        Direct Costs, General
                      D.2        Application to sponsored agreements
                      F.6.b      Departmental administration expenses
                      J.8        Compensation for personal services

A-21 Appendix A, CAS 9905.502    Consistency in Allocating Costs Incurred for the Same Purpose by
Educational Institutions
OMB Circular A-110:  Subpart C,   .27   Allowable costs

Administrative Responsibility:  UNH Vice President for Research and Public Service

Effective date:  July 1, 1995

Issue date:  October 21, 1994, in "UNH Financial Management Compliance Policies and
Procedures for Federally Funded Grants and Contracts" 

Current revision issued and effective on December 14, 1998

6.   Cost Sharing on Externally Sponsored Programs [ Changed. See UNH VIII.M ]

7.   Facilities and Administrative Costs Waivers on Externally Sponsored Programs

7.1    Definitions. Facilities and Administrative ("F&A") costs (also known as "indirect" or "overhead" costs) are costs incurred for common or joint objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project. (See OMB Circular A-21) F&A costs include library use, student services, building operations and maintenance, building and equipment depreciation, departmental secretarial assistance, general office supplies, and administration. A waiver of F&A costs on a specific University of New Hampshire ("UNH") sponsored program or project is an agreement that UNH will charge F&A Costs at a lower rate than the applicable rate published by the UNH Sponsored Program Administration ("SPA") in its home page "Rate Schedule," a lower rate than official sponsor-imposed limitations, or a lower base against which to apply the applicable rate.

7.2   Policy

7.2.1   UNH strives at all times to recover full costs on its sponsored programs and projects, both direct and indirect (F&A). It is the program or project director's responsibility to work with the UNH SPA to structure each proposal budget to attempt to recover full costs. However, UNH recognizes that there may be circumstances in which it is not possible to fully recover all costs.

7.2.2   If there are published, sponsor-imposed policies or regulations limiting the F&A rate, amount, and/or base allowed for all applicants to a specific program to a rate, amount and/or base less than UNH's, UNH does not consider the foregone F&A costs to be waived. Information substantiating the allowable sponsor rate, amount, and/or base must be attached to the Sponsored Programs Approval Routing form ("Yellow Sheet") when routing the proposal to the dean, institute director or other Responsibility Center ("RC") unit head for approval to submit the proposal. Such information is acceptable only if issued by a fiscal officer of the sponsor.

7.2.3   There may be circumstances in which there are no published, sponsor-imposed policies or regulations limiting the F&A rate, amount, and/or base; or circumstances where published policies exist, but UNH may decide its interests are best served by waiving its rights to part or all of the applicable F&A costs on a specific program or project. For example, a sponsor might require that UNH contribute some of its own funds to the project, and UNH may determine that a waiver of F&A costs is the most economical option in lieu of direct cash contributions. Or, a successfully-conducted small seed project at a lower-than-applicable F&A rate may enable a project director to establish a sponsor relationship that results in future, larger grants at the full applicable F&A rate--a relationship that might not have been possible without the successful seed project.

7.2.4   The authority to negotiate and approve waivers of F&A costs on programs, individual projects, or classes of programs or projects rests with the Vice President for Research and Public Service ("VPR&PS"). The VPR&PS may delegate this authority in writing in part or in full to other UNH officers. Approval of an F&A costs waiver in no way negates the prerogative of the program or project director's dean/institute director/other authorized Yellow Sheet signatory from declining to approve submission to a prospective sponsor of a proposal that fails to meet other institutional criteria.

7.2.5   Approved F&A waiver forms become part of the official awarded proposal files maintained by the SPA for UNH and are available to auditors and other examiners of UNH sponsored programs records. The VPR&PS will maintain annual records of the amount of F&A foregone for those awarded proposals in which the F&A is waived in part or in full.

7.2.6   A financial balance left at the end of a fixed-price agreement will be used first to repay the F&A waiver if a waiver had been granted for the pertinent project.

 


This page last updated April 11, 2012. For information on the adoption and effective dates of policies please see explanation on the OLPM Main Menu.



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