Sponsored Projects Policy
Western New Mexico University
Sponsored Projects Procedure
This document concerns the rights and obligations of faculty, staff and students pertaining to privately and governmentally sponsored projects (i.e., grant and contract funded) at WNMU.
1. The University recognizes the right of faculty, staff and students to solicit, conduct, or participate in privately and governmentally sponsored research, whether such research is classified or not, so long as it is within the limits of existing WNMU policies as detailed in the faculty, staff and student handbooks.
2. Sponsored work at WNMU is justified when it is derived from the WNMU mission, contributes toward the professional development of the faculty or staff, or provides opportunities for enriching students' educational experience.
3. The President has designated the Director of Grants and Contracts as the reviewing and coordinating officer for all sponsored project proposals submitted to outside agencies. The Office of Grants and Contracts provides access to grant materials, helps locate sources of potential funding, advises and assists with proposal presentation and University administrative procedures, and reviews the work plan, commitments and budget. The Director of Grants and Contracts, in conjunction with the Grants Accountant, will also coordinate negotiations between the sponsoring agency and the University.
4. The President has designated the Vice Presidents (according to the nature of the proposal and the identity of the Project Director or Principal Investigator) as the University's certifying officers for all sponsored project proposals submitted to outside agencies.
5. The University has established supplemental procedures (Procedures for Sponsored Projects), available from the Office of Grants and Contracts, to ensure the effective implementation of the University's policy concerning sponsored work.
6. The Grants Accountant is designated the prior fiscal approval authority for the University. In this capacity, the Grants Accountant will coordinate closely with the Project Director or Principal Investigator and Director of Grants and Contracts. The Grants Accountant will ensure that modification of grant and contract budgets in force and prior approval requirements are in accordance with the regulations of the sponsoring agency. The Grants Accountant is also responsible for all fiscal billing for sponsored projects.
7. Final authority for accepting and signing contracts and grants is vested in the President of the University, who may designate such responsibility to the certifying officer (i.e., appropriate Vice President).
8. A faculty member (during the regular academic year) or staff person (year round) whose salary is paid in full by the University may not engage in sponsored projects for extra remuneration except under specific conditions and when deemed by the administration to be in the best interests of the University and the individual involved. Conditions that must be met for extra compensation are:
a. Funds must be provided in the grant or contract to compensate the specific responsibilities to be assumed by the faculty or staff person; and
b. The sponsored project responsibilities are clearly above and beyond the individual's current responsibilities and will be conducted largely outside the individual's regular work hours, as determined by the employee, his/her supervisor and the appropriate Vice President; and
Adopted November 6, 1997
c. Such exceptions require written approval of the dean, chairperson or department director and the appropriate Vice President, in coordination with the Human Resources Department.
9. When the contract or grant calls for faculty release time from regular University duties during the regular academic year, the basic nine‑month salary from the instructional budget will be reduced proportionally. The reassigned time will be compensated from contract or grant funds at the basic salary rate. Conditions that must be met for reassigned time are:
a. Funds must be provided in the grant or contract to compensate the faculty member for his/her reassigned time, freeing instructional budget funds to pay alternate instructor(s) to teach those course(s); and
b. The faculty member seeking reassigned time and his/her department must assist in identifying and recruiting appropriate instructor(s) for the course(s); and
The written approval of the dean or department chairperson and the Vice President for Academic Affairs is required.
10. Any and all income and expenses generated by a sponsored project shall be assigned specific accounts established through the Grants Accountant. Use and allocation of income shall be determined by applicable regulations of the sponsoring agency and/or an agreement between the Project Director or Principal Investigator, the Grants and Contracts Director and the certifying officer for the project. All expenditures of project income must be approved by the Grants Accountant.
11. Any and all equipment purchased with external funds is the property of Western New Mexico University unless otherwise specified by the sponsoring agency. Upon request, the Grants and Contracts Director will negotiate equipment ownership issues with sponsoring agencies.
12. The Project Director or Principal Investigator must conform to all sponsor imposed policies and procedures as well as applicable University policies and procedures in the management of the project, with special emphasis on the Procedures for Sponsored Projects, Procurement and Reimbursement Policy, the Travel Policy and Procedures, the Procurement Procedures and the Reimbursement Procedures.
13. For the purposes of this policy, sponsored projects shall be construed to include sponsored research, service and training projects, and other categories of awards for all except basic capital construction and maintenance projects. Sponsored projects refers only to those grants and contracts entered into by the University. Grants and contracts involving WNMU personnel that do not involve University resources and do not contractually bind the University are exempt from this policy.
14. This policy, in whole or in any part, is subject to review, update and change.
Project Directors/Principal Investigators preparing proposals should also contact the Director of Grants and Contracts for information if any of the following are applicable to a proposal:
- Classified research
- Patent and revenue sharing
- Human beings as subjects in research
- Use of animals in education and research
- Conflict of interest
Adopted November 6, 1997
Procedures for Sponsored Projects--Western New Mexico University
The following procedures were established to ensure the implementation of the University's policy concerning sponsored (grant and contract funded) projects.
- Grant and contract proposals must be reviewed by the Office of Grants and Contracts (OGC) prior to submission to the funding agency. OGC will perform the following review functions:
- Review potential contracts for Federal Acquisition Regulations or other requirements or regulations that are incompatible with WNMU's policies, procedures or regulations.
- In conjunction with the Grants Accountant, review proposal budget for accuracy (i.e., do the numbers add up), permissibility (i.e., are the costs in the budget permissible according to sponsor's regulations), and cost sharing requirements and commitments.
- Review proposals for completeness and conformance to sponsor's instructions.
- In preparing a proposal, the Principal Investigator or Project Director (PI/PD) must:
- Identify in the proposal and on the University's Grant and Contract Approval Form (available from OGC) all University resources that will be used in the project, including:
- Full responsibility for or sharing of salaries.
- Equipment, especially new equipment to be purchased for the project.
- Both the physical and financial aspects of space/facilities required to carry out any activities associated with the grant or contract.
- All required computer services support including hardware, software, programming and training.
- Other expenditures requiring University funds or contributions in kind.
- Determine whether any other University department or division is directly affected by the proposal. If so, the dean, chair or director of the affected department should formally acknowledge concurrence, with evidence of such concurrence reflected in or submitted with the Grant and Contract Approval Form.
- Determine whether the proposed project or program involves extra compensation for a University employee or faculty release time. If so, the PI/PD must brief the Grants and Contracts Director regarding the request at or by the time the Grant and Contract Approval Form is submitted to OGC. The PI/PD must also meet the conditions for extra compensation or release time specified in the Sponsored Project Policy before the University will certify a proposal that includes extra compensation or release time.
- Grant and contract proposals must be approved by the PI/PD's dean, chairperson or department director, the Director of Grants and Contracts, the Grants Accountant, the Vice President for Business Affairs, and the appropriate Vice President(s). Approval must be indicated by signature on a completed Grant and Contract Approval Form. OGC will obtain all signatures except the dean/chair/department director signature on behalf of the PI/PD (Adopted November 6, 1997--VP, Business Affairs Chris Casey.)
- The PI/PD will insure that all deliverables required under the terms and conditions of a grant are provided to the funding agency. Upon notification by the PI/PD that all deliverables have been submitted, OGC will request a letter from the granting agency confirming that the project has been completed to its satisfaction. This documentation will be filed to minimize the liability of incomplete projects to both the University and the PI/PD.
- PI/PDs must conform to all policies and procedures regarding the purchase of and billing for supplies and services that may be needed as part of a sponsored project. PI/PDs are encouraged to contact Purchasing and the Grants Accountant to discuss or clarify internal purchasing and billing policies and procedures.
- PI/PDs must conform to WNMU policies and procedures for travel. Travel related reimbursements (e. mileage, per diem) to individuals will be at WNMU rates.
- PI/PDs must avoid disallowable expenditures. If a PI/PD is uncertain about the allowability of a given expenditure, they should first consult with the Grants Accountant to determine whether the purchase should proceed. If necessary, the Grants Accountant will handle all contacts with agencies to determine allowability of proposed expenditures. The Grants Accountant must also sign all purchase order requisitions, contracts, and employment contracts affecting grant funds.
- The Grants Accountant will review and sign (or disapprove) all purchase order requisitions, contracts, and employment contracts affecting grant funds and requiring his/her signature within four working days of receipt. Purchase order requisitions must be completed prior to purchase; requisitions submitted after the purchase will be disallowed.
- The Grants Accountant is responsible for all required financial reporting. PI/PDs must provide the Grants Accountant anv documentation needed to prepare financial reports. The Grants Accountant will provide PI/`PDs with summary statements of expenditures for each project upon request. OGC will require a mandatory meeting with the PI/PD and Grants Accountant at the time that 80 percent of project funds are expended to insure that the project is nearing completion and will be completed within allotted project funds.
- The Business Office will maintain records for sponsored projects following successful completion of a project in the event that an audit is required. The Business Office will provide all storage (both electronic and paper) of fiscal records for each project as required under project specific regulations and under State of New Mexico archive requirements. OGC will maintain a file containing the request for proposals, proposal, contract, progress reports and related documentation.
- In the event that project expenditures are audited, the Business Office will provide fiscal records for audit. Further, the Business Office and OGC will be available to answer questions and provide materials for external or internal audits. The PI/PD must provide any information or assistance needed by Business Office or OGC staff to respond to questions by auditors (Adopted November 6, 1997.)
- The PI/PD must submit a completed Grant and Contract Approval Form signed by their dean, chairperson or director along with all of the sponsoring agency's signature forms to OGC at least eight working days prior to the date that the proposal is due.
- The Office of Grants and Contracts is responsible for submitting all grant and contract proposals to the sponsoring agency. OGC will provide duplication services to the PI/PD to insure that the requisite number of copies of each proposal is submitted to the agency. To assure sufficient time to perform duplication services, OGC must receive proposals at least four days before the date that the proposal is due at an agency. OGC will also coordinate all mailing, whether by conventional mail or overnight express, needed to insure that proposals are received by the agency according to deadlines specified in the Request for Proposals. If PI/PDs choose to prepare the number of copies needed by the agency themselves; they are still required to submit the entire proposal package (including all copies) to OGC at least three days prior to the date that the proposal is due at the agency. The Vice President overseeing the PI/PD's department will certify the proposal, on behalf of the University, by signing the sponsoring agency's signature page(s) and returning them to the OGC for official submittal to the prospective sponsoring agency.
- Any contract negotiations between the University and a funding agency must involve both the University administration and the PI/PD, as coordinated by OGC. Final contracts must be reviewed by both the PI/PD and the certifying officer (i.e., the appropriate Vice President). Signatures on a contract will be obtained by OGC, who will provide the original to the Grants Accountant, file a copy, and provide a copy to the PI/PD.
- Any modifications to a grant or contract award requiring the sponsor's prior approval must be processed in accordance with the foregoing procedures. In addition, all revisions of the budget for a sponsored project, regardless of magnitude, require the PI/PD to submit an internal
budget revision form to the Grants Accountant.
- The responsibilities of PI/PDs during the post award include:
- Upon award, PI/PDs are to undertake a full faith effort to successfully complete the project according to the terms and conditions of the contract. In the event that a PI/PD cannot complete a project, regardless of cause, the University reserves the right to either: terminate the contract with the granting agency without approval of the PI/PD or, pending granting agency approval, place a new PI/PD in charge of the project.
- In the event that a PI/PD should decide to leave the university in the midst of a project, they must provide OGC and the Grants Accountant with immediate written notification of their intent to leave and the date on which they will leave. In such a case, the University will exercise at its discretion one of two options. First, with agency approval, WNMU may choose to make arrangements with the agency so that the PI/PD can take the contract with them to their new station. Alternatively, with agency approval, the University may seek to replace the PI/PD with a new PI/PD and continue the project at WNMU.
- PI/PDs will complete all progress reports required by granting agencies under the terms and conditions of the contract. The PI/PD must send copies of progress reports to OGC to facilitate project monitoring. This enables OGC to verify that milestones in the project are being met. If milestones are not being met, progress reports will alert OGC that there may be difficulties with the project and remedial actions can be undertaken to resolve the problem. Approaches to resolving problems will be discussed between OGC, the Grants Accountant, the PI/PD and other WNMU staff as needed (Approved: November 6, 1997)
Approved By: The Policy Committee