University of Missouri System

Business Policy Manual

Finance and Accounting

BPM-210 Sponsored Programs

Revised October 18, 2007

The University will seek and accept support of sponsored projects related to the normal programs and recognized objectives of the University.

Definition of Key Terms:

   Proposal

A proposal is a description of the work University personnel propose to complete on a sponsored project. The details included in a proposal depend on the project's scope and who will read the document. Ideally, the proposal will persuade readers to support the proposed project. Proposals are usually discipline and funding-source specific.

   Sponsored Project

The characteristics of a sponsored project are:

• activities relating to a proposal funded by an entity outside the University,
   
• funded for a specific purpose,
   
• an exchange transaction where the sponsor receives value in return for the funding provided to the University,
   
• executed by an award, contract, cooperative agreement, memorandum of understanding, or other formal mechanism,
   
• for the purpose of supporting any research, scholarly, instructional or public service activity,
   
• the sponsor may retain some claim (option or otherwise) to intellectual property that may be developed as a result of a sponsored project,
   
• the sponsor may have a direct interest in the development and ownership of the intellectual property resulting from the activity, and
   
• the project may have restrictions requiring regulatory compliance.

   Student Loan Activity

Funding resulting from student loans guaranteed by the federal government with federal audit requirements such as OMB A-133.

Processing Requests

All awards are sought in the name of The Curators of the University of Missouri.

A Proposal Signature Routing Sheet (PSRS) must be signed by the Principal Investigator and processed through campus channels (department, unit, school/college) for approval by the Chancellor, Vice President, or designee prior to the submission of any application or proposal to a prospective sponsor, which includes any technical and cost information and may result in an award of any sponsored project to the University. Projects involving multi-campus programs and personnel must receive approval from all participants at each of the campuses involved.

   Submitting Proposals

After review and approval by the appropriate campus Sponsored Programs Office (SPO), proposals are submitted to the sponsor except for proposals which:

• Involve multi-campus programs and personnel when the award is to be centrally administered by the UM System. Such proposals are processed by the Columbia SPO acting on behalf of UM System.
   
• Involve classified contracts (security). Such proposals are reviewed and approved by the campus Facility Security Officer (FSO), sent to the System FSO for review and approval, and submitted to the sponsor by the System FSO acting on behalf of UM System.
   
• Require legal review, or are legally binding at the time of submission, including Quotations and Bids. Campus SPO will forward proposals requiring legal review to the Office of the General Counsel.
   
• Waive any rights in data (publication, patent, copyright). Campus SPO will forward these proposals to the campus office responsible for intellectual property for review and approval.

   Proposals Providing for Extra Compensation

Proposals for grants providing compensation in addition to an employee's regular salary must clearly state this fact and must have final approval of the Chancellor or designee (President or designee for UM System) prior to submission to the prospective sponsor.

REFERENCE: HR 214 Extra Compensation

Negotiation and Acceptance

   Sponsor Negotiation

Technical/programmatic negotiations with the sponsor are the responsibility of the Project Director/Principal Investigator.

Fiscal/business/legal negotiations with the sponsor are the responsibility of the SPO of each campus (Columbia SPO for UM System).

 

   Authority to Determine Acceptability

Decisions concerning the acceptability of a specific sponsored project under the terms of an award are made by the President, or authorized designee.

 

   Accepting or Executing Award

All awards are accepted or executed by the campus except multi-campus awards to the UM System administration in which case they are accepted and executed by the Columbia SPO on behalf of UM System.

All awards must be made in the name of The Curators of the University of Missouri.

   Notification of Acceptance of Award

The SPO of each campus will advise the Project Director and other interested persons of the acceptance of a grant.

   Security Responsibilities

Requirements set by the FSO on each campus must be met for all awards requiring the use of classified matter. Receipt of classified matter and the procurement of security clearances must be discussed with the System FSO.

NOTE: The University is cleared for Secret, Confidential and Restricted but not Top Secret material.

Receipt of classified matter and the procurement of security clearances must be discussed with the UM System Government Security Office (Office of Vice Chancellor for Administrative Services for UMR).

   Publicity Regarding Awards

All publicity regarding an award must be authorized or cleared by the campus public information office (University Communications for UM System).

   Expending Funds

All expenditures of funds received from an award must be made in accordance with standard University policies governing the expenditure of funds, and/or sponsor requirements.

Financial commitments or expenditures are normally not to be made before an award is officially accepted. Pre-award expenditure arrangements can be made under certain circumstances if the expenditures are backed by a commitment of funds from the manager of a currently existing source, and such pre-award expenditures are allowable under the terms of the anticipated award. Expenditures may not be made after an award has terminated.

REFERENCE: APM-60.35 Establishing an Award

   Property and Equipment Associated with External Sponsors

All property or equipment obtained from or purchased with funds from external sponsors shall receive the same care and safeguards as all other University property.

Property purchased or constructed with external funding or provided by an external sponsor must be inventoried, tracked and disposed of in accordance with the terms and conditions of the external sponsor´s requirements.

REFERENCE: APM-60.65 Reconciliation of Federally Funded Assets

The Campus Procurement Service Center must be consulted prior to the disposition of any non-expendable sponsor-owned property and/or equipment.

REFERENCE: BPM-407 Inventory

   Submitting Required Reports/Billings

Where required, each campus SPO will prepare and submit necessary expenditure reports and/or billings to sponsors. When appropriate, copies of these documents (or files) will be provided to University administrators for review and approval prior to submission to sponsors.

The official University files pertaining to sponsored projects will be maintained on each campus.

REFERENCE: BP 1001 Records Retention Summaries

Responsibilities

   Principal Investigator:

• Technical/programmatic negotiations with sponsors.
   
• All expenditures made against a sponsored project.
   
• Knowing and adhering to the specific limitations and restrictions of the sponsor and of the award documents.
   
• Knowing and adhering to all administrative and financial compliance requirements of sponsors, regulators, and the University.
   
• Knowing and adhering to all technical reporting and deliverable requirements.
   
• Complying with Federal, State and University policies relating to human subjects, animal welfare, human use of radioisotopes, Conflict of Interest (COI), and other similar policies as appropriate.

   Campus Sponsored Programs Office:

• Fiscal/business/legal negotiations with sponsors.
   
• Perform all project-specific sponsored program functions, to include proposal review and approval, award negotiation and acceptance, and all post-award administration except for those activities for which UM System has retained responsibility as defined elsewhere in this document. Overall administration of multi-campus awards will be the responsibility of the lead campus. For this purpose, lead campus is defined as that campus which submitted the proposal and accepted the award. The exception will be those multi-campus sponsored projects awarded to UM System units, for which Columbia SPO will retain this responsibility. Each campus will be responsible for the normal oversight of funds awarded to them under a multi-campus sponsored project.
   
• Provide assurance that all sponsored projects are administered in accordance with OMB Circulars A-21, A-110, and A-133 Compliance Supplement, and with any other general or specific regulations issued by Federal, State or other sponsors.
   
• Maintain official files to include award, correspondence, accounting reports, invoices and financial or other types of non-technical/non-programmatic reports submitted to sponsors, and any other documents generated in the administration of sponsored projects and required for the purpose of reviews to be conducted by external or internal auditors. Retain all documents for periods specified by sponsoring agency regulations or University policy.
   
• Provide auditors with any information they require in their review of sponsored projects. Provide the Office of the Controller with a copy of all resulting audit reports issued to the campuses. Prepare responses to all auditor findings and recommendations and submit them to or review them with the Office of the Controller prior to their submission to the auditors.
   
• Ensure that the PeopleSoft Grants module is maintained to appropriately and accurately calculate and record all Facilities and Administrative costs and cost sharing in the financial system for sponsored projects.
   
• Promptly deposit all receipts pertaining to sponsored projects other than those funded by letter of credit.
   
• Provide all required documents necessary for letter of credit management to the Office of the Controller.
   
• Enter data pertaining to proposals and awards into the PeopleSoft Grants Module. Each campus will also be responsible for the integrity of its data.
   
• Submit contractual documents to the Office of the General Counsel for legal review and approval as set forth in the Collected Rules and Regulations of the University of Missouri.
   
• Submit materials to other university offices (e.g., Research and Economic Development, Environmental Health and Safety, Procurement Services) as appropriate for their use in the review of proposals and awards.
   
• Gather and provide to the Office of the Controller all information necessary for the development and negotiation of Facilities and Administrative cost rates.
   
• The Columbia SPO will also be responsible for all project-specific activities as defined elsewhere in this document for sponsored projects awarded to UM System units except for those awards for which UM System will retain responsibility as described elsewhere in this document.
   
• SPO on each campus will advise the Principal Investigator and other interested persons of the acceptance of a sponsored project.
   
• The campus SPO will advise the FSO of the acceptance of a classified contract.
   

   Columbia SPO on Behalf of UM System

• Perform all project-specific administrative and financial functions pertaining to those multi-campus sponsored projects awarded to UM System units.
   
• Award documents for which UM System has responsibility shall be maintained at the Columbia SPO.
   

   UM System

Office of the General Counsel

• Provide legal review and approval for all contractual documents as set forth in the Collected Rules and Regulations. Participate in reviewing changes in laws affecting sponsored programs administration and in the development of procedures where appropriate.

Office of the Controller

• Coordinate all audits to be conducted by external audit agencies and by internal auditing, and final responses to all findings and recommendations resulting from system audits. Review individual contract closing audits prior to submission of campus responses.
   
• Coordinate the effort of all campuses in the gathering of data necessary for determining Facilities and Administrative (F&A) costs and assist campuses in designing and conducting special cost studies for this purpose. Design, prepare and submit the F&A cost proposals for all campuses and negotiate the resulting F&A cost rates.
   
• Coordinate all requests from the campuses for enhancements to the accounting system as it pertains to the administration of sponsored projects. Implement such changes when approved. Provide all accounting system special reports required by campuses in the administration of sponsored projects. Coordinate the development of new reports as necessary.
   
• Maintain the PeopleSoft Grants module functionality to accurately calculate and record all F&A costs and cost sharing in the accounting system for sponsored projects as configured by the campus SPOs.
   
• Maintain the grant/contract database management system, not including data entry, and coordinate all requests from the campuses or other UM System administrative units for system enhancements. Upon approval, implement such enhancements with the assistance of appropriate technical staff.
   
• Perform all aspects of letter of credit management, including monitoring of cash on hand, drawdown of cash when necessary, and preparation of periodic cash reports as required.
   
• Oversee accounting, financial reporting, cash management, and the financial portion of all audits related to Federal Student Aid Programs.
   
• Assist or perform all financial administrative requirements, and/or prepare financial reports for federal and state appropriations; e.g., federal appropriations for the Agricultural Experiment Station, Cooperative Extension, and Veterinary Medicine appropriations.