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Grants Policy2 

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Administration and Finance

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Grants Office, Fiscal Affairs

 

 

 

GRANTS POLICY

Policy

 

 

 

Worcester State University (WSU) encourages its faculty and administrative staff to seek external funding from governmental and independent funding agencies, organizations and individuals in support of academic research, improved instruction, curriculum and programmatic development, student support, facilities and overall institutional development activities that adhere to and promote the mission of the University.

 

To comply with federal, sponsor, state, private foundations, corporate sponsors, and other regulations and to properly account for grant expenditures and revenue, the University provides guidelines that all members of the University community must follow in the proposal development, grant applications, procurement and management of all externally grant funded activities. Regulations that WSU complies with include, but are not limited to, federal Office of Management and Budget (OMB) Circulars A-21, A-110, and A-133, Massachusetts Office of the Comptroller policies and procedures, Massachusetts General Laws and Code of Massachusetts Regulation (CMR) 815. In the case of differing or multiple regulations or procedures, the most restrictive is followed.  

 

Procedure

 

 

 

 

I. Pre-Award Procedures

 

A. Cultivation of the Idea

If you have an idea that you believe will (1) address an institutional, local, regional, state and/or national need(s);  (2) improve instructional or support services for the students, (3) enhance professional development; or (4) contribute to the mission of the University, we encourage you to have a preliminary discussion with your department head and the grant administrators for private and government funding to examine the feasibility of pursuing an external support and identifying possible source(s) of funding.

 

As the Principal Investigator (PI) or the Project Director (PD) cultivating an idea, you will be assuming the following responsibilities:

 

·         Writing the proposal.

·         Following the grant proposal guidelines.

·         Gathering necessary data.

·         Finding and securing any collaborator(s) needed.

·         Securing the approval signatures needed for submission.

·         Performing any other task necessary for the preparation of the proposal.

 

Once the idea is funded, the PI is fully responsible for:

 

·         Project implementation.

·         Equipment and supplies procurement.

·         Hiring personnel for the grant.

·         The financial management of the project.

·         Monitoring and certifying effort reports for grant personnel and

·         Report writing and submission.

 

B. The Department Chair/ Academic or Administrative Area Supervisor

The academic department chair or administrative department head plays a crucial role in the proposal development process. Early discussion between Principal Investigator (PI) or Project Director (PD) of the grant and the department head is required prior to writing the proposal.  The department head reviews the intent and the detailed idea to ensure that the proposal meets the mission of the department/administrative area and that the impacts on the department are addressed satisfactorily (i.e. release time, use of space, equipment, etc).  Any necessary collaboration across University divisions must be addressed at this point. The department head’s signature is required on the Grant Application Approval Form, committing the department to the grant requirements.

 

C.  Area Vice President/Dean

All potentially externally funded activities must have the approval of the Area Vice President and, when appropriate, the Area Dean. At the outset, the PI/PD should discuss the proposal idea with the VP/Dean and should receive a preliminary approval to go ahead with the plan. Once the proposal has been fully developed and the budget prepared, the VP/Dean must review the application to insure that it meets all institutional requirements including any current or ongoing financial commitment, identifies any liabilities incurred and/or cost sharing. Significant proposals should be discussed at the Cabinet to ensure that there are no conflicts among divisions, that resources are available and that they support, and do not conflict with, strategic goals.  The VP and Dean's signatures are required on the Grant Application Approval Form, committing the academic/administrative division to the grant requirements.

 

D. Worcester State University Grant Administrators

1. Private Funding Sources – Consultant for Corporate & Foundation Relations, Office of Institutional Advancement

The Office of Institutional Advancement serves as the primary liaison and leading entity for all campus-wide development activities from private donors. This includes the soliciting and raising of funds (gifts, donations and grants) from corporate, individual and philanthropic organizations. Within this office, Sharon S. McDonald, Consultant for Corporate and Foundation Relations facilitates the pre-award process for private grants and acts as a liaison with the private funding agencies.

2. Government Funding Sources – Grant Coordinator, Administration and Finance

The Grants Coordinator, Linda M. Crocker, in the Administration and Finance Office, facilitates the Government pre-award process and acts as liaison with the funding agencies for all government grant funds (federal, state and local government).

 

The Consultant for Corporate and Foundation Relations and the Grant Coordinator are available to assist University faculty/staff in the following areas:  

 

  • Identifying potential funding sources based on project objectives.
  • Securing submission requirements, funding guidelines and budget forms.
  • Providing technical support in the grant writing process.
  • Conducting a review of applications for adherence to funders' guidelines and inclusion of required institutional documents/information.
  • Providing institutional descriptions when required in the grant narrative.
  • Liaison with funding agencies.
  • Assisting in securing institutional approvals and the submission of the proposal.

 

These two grant administrators work closely with the PI / PD to ensure that the proposal follows the guidelines and application format stipulated by the funding agency and all of WSU, state and federal policies and procedures. These offices have all available necessary institutional documents that are often required for submission with grant proposals.

 

E. Formal Proposal Preparation

All proposals for grants must be submitted through the University’s Grant Coordinator.

The Grant Coordinator will assist the PI/PD, regardless of the funding source, in the proposal development process with respect to the preparation of the budget and for the final institutional review. The office will provide information on fringe rates, overhead costs, etc. The University’s formal approval process ensures compliance with the funding guidelines; University, state and federal regulations; and facilitates the tracking of proposals both before and after submission.  The University’s Grant Approval Form must be completed with all signatures obtained prior to submission.

 

F. Formulation of Grant Budget

All budget items must comply with regulations on allowability according to the grantor.  Costs directly charged or allocated to the grant must be accurate, reasonable and consistent in allocation methods, regardless of the source of funding.

 

1. Compensation

Compensation for University employees working on grant projects must be consistent with established compensation policies as determined by Human Resources, the Payroll Department and appropriate union contract.

2.  Faculty / Administrator Effort

The proposal budget must indicate the percentage of faculty effort to be spent on grant activity that would be otherwise devoted to instruction, other scholarly activities or administrative assignment during the academic year. The assignment of faculty and / or administrator effort to externally sponsored activity must be consistent with University policies and must be approved by the department chair, Dean and the Provost, Academic Affairs or appropriate Vice President.

3. Fringe Benefit Rate

The fringe benefit rate to be used in budget preparation for grant programs should be obtained from the Grant Coordinator.  The fringe benefit rate is determined by the Commonwealth of Massachusetts Office of the State Comptroller and is subject to change.

4. Cost Sharing

Cost sharing, whereby the University absorbs some of the costs of the proposed project, is sometimes required by the funding agency/institution.  Cost sharing may be defined in different ways and it needs to be determined what the funder’s definition is for the proposal.  Some types of cost sharing are:

 

         a) Cash expenditures, defined as new funds not currently budgeted.

 

            b) In-Kind contributions of direct costs borne by the University, such as facilities, employee time, or other currently budgeted items.

5. Indirect Cost Rate (Facilities & Administration or F&A Rate)

All grant proposals submitted by WSU members must include indirect costs if they are allowed by the funder.  Please contact the Grant Coordinator for the appropriate rate to budget.  Waivers to this policy must be approved by the Vice President of Finance and Administration.  Indirect cost waivers are strictly regulated and may be granted only for vital programs matching the following criteria:

·         Small seed grants which may attract larger future awards.

·         Cases of hardship for a new investigator.

·         Awards which include contributions of equipment or building renovation funds.

·         Awards for a community relations interest vital to the campus.

·         Supplements for a student services activity which the campus must provide.

·         Supplements for library holdings or public exhibits.

 

If granted an indirect cost waiver, the reduction in overhead may be used as cost sharing, however, in no circumstances will an indirect cost waiver be approved for the sole purpose of meeting cost-sharing requirements.

 

G.  Internal Review of Budget Proposal

All proposals for grants must be submitted through the University’s Grant Coordinator.  The Grant Coordinator, as the Grant Compliance Officer, must be provided a complete copy of the final grant proposal for review and must sign the Grant Application Approval Form, certifying that the proposal meets compliance requirements and follows all University, state and federal regulations.

 

The Vice President of Administration and Finance reviews the grant proposal to verify that any current financial commitment is available and any ongoing financial commitment is sustainable and is appropriate for the University.  The Vice President must sign the Grant Application Approval Form committing the University to the grant requirements.

 

The appropriate area Vice President/Provost AND the Vice President for Administration and Finance are responsible for committing the University to activities and requirements of grant proposals.  Individual faculty, chairs of academic departments or deans cannot commit the University to such activities.

 

The combined approvals of the Area Vice President/Provost and the Vice President of Administration and Finance constitute the official commitment of WSU to the grant proposal requirements, if funded.

 

H. Time Line for Proposal Submission

To ensure an appropriate review for compliance, completed proposals should be submitted to the Grant Coordinator five (5) business days before the submission deadline.  Proposals submitted to the Grant Coordinator with less lead-time may not be processed in time to meet the submission deadline. 

 

Informal discussions should be held well in advance of proposal deadlines with the appropriate campus personnel as required to insure that any potential concerns are alleviated.  This is particularly important if there are proposed items such as course release or cost sharing on the part of Worcester State University.

 

All grants must have a completed Grant Application Approval Form with all signatures prior to submission, or the proposal may not be submitted.

 

 

II. Post-Award Procedures

 

A. Award Notification

A Grant Award (or decline) notice may be received by the President of the University, the PI or the Grants Office. Once a grant award notice is received a copy should be forwarded to the Grant Coordinator, who will ensure that the appropriate chair, dean, Vice Presidents/Provost, and President are notified.

 

If a decline letter is received, a follow-up discussion with the agency staff is worthwhile to learn about the proposal strengths and weaknesses, and to determine if the proposal should be resubmitted. A copy of the letter should be sent to the Grant Coordinator.

 

B. Award Acceptance

All grant awards must be formally accepted by the WSU President.   Receipt of an award notice does not constitute acceptance by the University of the grant and its requirements.  The Grant Coordinator, with input from the Consultant for Corporate and Foundation Relations, the Provost and the Vice President of Finance and Administration, will provide information to the President for consideration.

 

The University is ultimately responsible for the management and accountability of grants. The PI/PD, as an agent of the University, is primarily responsible to assure that all programmatic and fiscal accountability requirements are met.

 

C: Contracts and Agreements

All agreements for grants and contracts must be made in the name of the University (or possibly the Worcester State Foundation if 501(c) 3 status is required).  All grant contracts must be approved by the Grant Coordinator and, if over $2,500, signed by the Vice President for Administration and Finance.

 

 

IV. Post-Award Procedure

 

A. Budget and Account Set-up Meeting

In order to establish a grant account number in the Colleague financial system at WSU, the PI/PD must contact the Grants Coordinator to schedule a grant information and budget meeting.  When necessary the Consultant for Corporate & Foundation Relations will attend these meetings and help facilitate follow-up as needed.  This meeting is required before the PI/PD can expend any funds and before account numbers will be set up.  At this meeting the grant proposal, budget and award will be reviewed to make decisions concerning budget setup, hiring and contract needs, effort reporting, responsibilities of all parties, procedures for purchasing and reporting, and to establish a timeline for items with due dates.

 

The Grant Accountant will establish a grant account/project number when the budget is uploaded into Colleague and will notify the PI/PD of this number and that they may begin to encumber costs.

 

All requests for expenditures of grant funds must first go through the Grant Coordinator and/or the Grant Accountant to ensure compliance with the grant and appropriate regulations.  The paperwork -  purchase requests, 03 forms, etc. – will be forwarded to the appropriate office, once approved.

 

B. Receipt of Grant Funds

1. Checks – All grant checks should go to the Grant Accountant to be properly deposited into the correct grant account.

2. Wire Transfers – Those agencies that only remit funds via wire transfer will provide the grantee with the appropriate (ACH) Automated Clearing House form requesting the University’s bank account number, routing number, etc.  This form will be filled out by the University’s Accounting office and forwarded back to the granting agency.  The Grant Accountant will code the wire transfer to the appropriate grant account.

 

C. Changes to Existing Grants

1. Budget Changes

Many times prior approval from the funding agency is needed before any changes can be made to a grant, i.e. equipment substitution, budget adjustments, the scope of project or other changes.  The PI/PD must contact the Grant Coordinator or Grant Accountant with the change that they would like to make, prior to implementation, so that they can ensure that the proper procedures and approvals are met, and to update the grant working budget.

 

2. No Cost Extensions

If the PI/PD wants to make a no cost extension (see definitions in section VI) to the grant end date, they must contact the Grant Coordinator who will ensure that the appropriate steps are taken by the appropriate offices.  There must be a significant reason for requesting this.  University approvals must be in place prior to any contact with the grantor/funder.

 

D. Buy American Act and Fly American Act

WSU complies with requirements of both the Buy American Act and Fly American Act in procurement when using federal funds. 

 

E.  Reports

Preparation of grant reports is the responsibility of the appropriate PI/PD. The Grant Accountant will work with the PI on any financial information to be included.  A copy of the report is to be sent to the Grant Coordinator and in cases of private funders to the Consultant for Corporate & Foundation Relations.

 

 

V. Award Closeout

 

Awards will be closed in a financially responsible manner within the appropriate time period. All necessary reports and documents for closeout will be completed and submitted by the appropriate deadline.

 

A. Notification

The appropriate liaison office (Grants Office or Institutional Advancement) will notify the PI 60 days prior to project end date to take action to close out the project. The PI will ensure remaining funds are expended, review all remaining encumbrances and ensure that the requirements and objectives of the grant project have been met. 

 

B. Reporting

The PI will be responsible for preparing the final technical report and a project narrative. For private funders the PI will work in partnership with the Consultant for Corporate & Foundation Relations to complete any reporting requirements.  The Grants Office will assist in preparing a final financial report and/or invoice.  The PI is responsible for submitting the final reports to the sponsor according to the instructions in the award document at or before required deadline.  A copy of the final report and the transmittal letter to the sponsor should be sent by the PI to the Grants Office.

 

The Grants Office reviews the grant, verifying that: All costs incurred have been reported to the sponsor; all dollars have been received from the sponsor; any necessary adjustments have been made; and cash balance is zero.

 

C.  Records Retention

Financial records, supporting documents and all other records pertinent to an award shall be retained for a period of seven years after final payment, in accordance with the Commonwealth of Massachusetts Public Records Law and State Comptroller’s Office (or longer if required by the grantor).  These records will be maintained by the WSU Grants Office.

 

 

VI. Definitions

 

501(c)3:  is an American tax-exempt, nonprofit corporation or association.  Worcester State University, while tax-exempt, is NOT a 501(c)3 organization. The Worcester State Foundation is a 501(c)3 entity, and any funder that requires that the grant recipient be a 501(c)3 organization can have the grant received through the Foundation on behalf of the University.

 

Amendment: Any change to a contractual agreement needing official signature.

 

Award:  An executed agreement between Worcester State University or Worcester State Foundation and a sponsor.

 

BO:  Blanket Order

 

Budget Period: The period of time during which a particular increment of funding can be used.

 

Commitment: Project funds that have been set-aside in anticipation of expenditures. Project funds are committed when payroll appointments, requisitions, subcontract requests, etc. are processed. The costs are actually charged to the project when the person is paid, when the equipment or supplies are received or when subcontractor invoices are approved for payment.

 

Cost Sharing: Institutional or third party contributions to a grant/sponsored project. Cost sharing may be required (e.g., for many equipment or renovation grants) or voluntary. If cost sharing is included in a proposal (e.g., faculty time is listed as without cost to the project) that cost sharing must be accounted for and documented against the project.

 

Direct Costs: Includes all items that can be categorically identified and charged or assigned with a high degree of accuracy to a specific project, such as personnel, fringe benefits, consultants, subcontractors, travel, equipment, supplies and materials, communications, computer time, and publication charges.

 

Donor: An individual or organization that makes a grant or contribution to a donee. (Also known as the grantor.)

 

Effort:  Activities related to a grant from a principal investigator’s or grant employee's duties, for which University compensation is received. External activities such as consulting are not included.

 

Effort, Actual: The time that an employee actually devotes to a particular grant/sponsored project (including time pledged to a sponsor as mandatory or voluntary committed cost sharing) or other activity, expressed as a percentage of total effort.

 

Encumbrances: A specific amount of funds that has been set-aside in an account for the receipt of an order or the payment of an invoice. Encumbrances reduce the available balance of an account.

 

Endowment: Funds intended to be invested in perpetuity to provide income for continued support of a not-for-profit organization.

 

Gift or donation: A voluntary and irrevocable transfer of money, services or property (e.g., equipment, personnel time and skill, etc.) from a donor without any expectation of or receipt of direct economic benefit or provision of goods or services from the recipient.

 

Grant or contract: An agreement formalizing the transfer of money or property from a sponsor in exchange for specified services (e.g., research and development), sometimes including proprietary rights to and products derived from the services, and including financial and/or technical reporting by the recipient as to the actual use of the money or results. The agreement is enforceable by law, and performance is usually to be accomplished within a specified time frame, with payment being subject to revocation for cause.

 

Grant: A type of award that is supportive in character, given for a specific purpose, yet permitting the recipient considerable latitude in determining what is to be done, for whom, when, how much, and within limits, at what cost.  Types of grants: Block grants, categorical grants, formula grants and discretionary.

 

 

Contract: A legal agreement that specifies the services to be provided and the results expected in exchange for resources.  Contracts are a mechanism used by the government for the acquisition of materials or services for which the need or the idea arose within the governmental agency.  Types of contracts: Sole source, open bid, fixed price, cost reimbursement and cost sharing.

 

Grant Expenditures: Costs that have been charged to grant/sponsored projects accounts to pay for grant activities: personnel, travel, supplies, etc.

 

Grant Personnel: Individuals who work on grant/sponsored projects.

 

Grantee financial report: A report detailing how grant funds were used by an organization. Many grant makers require this kind of report from grantees. A financial report generally includes a listing of all expenditures from grant funds.

 

Indirect Cost/Facilities and Administrative Cost Rate (F & A Rate): F&A costs are those costs (e.g., libraries, information technology, heating and lighting, etc.) incurred for common or joint objectives and, therefore, cannot be identified readily and specifically with a particular grant/sponsored project, an instructional activity, or any other institutional activity. (OMB Circular A-21, Section E1).

 

In-kind Cost Sharing: The reasonable valuation and allocation of existing WSU equipment, materials, personnel or other property used in the performance of the statement of work.

 

Mandatory Cost Sharing: A contribution to a grant/sponsored project or program required by the sponsor as a condition of obtaining the award. Such contributions are binding commitments and must be accounted for and documented. Mandatory cost sharing may be reportable to the sponsor.

 

Matching Contribution: A type of cost sharing, wherein a contribution to a grant/sponsored project or program that is pledged to match some portion of funds provided by the primary sponsoring agency.   Matching contributions may be in any form acceptable to the sponsor, including cash and third-party in-kind.

 

No Cost Extension: A no-cost extension is granted by the sponsor to allow the PI extra time to complete the scope and objectives of the project without additional funds being provided by the sponsor.

 

PD: Project Director

 

PI: Principal Investigator

 

PO: Purchase order

 

Project: A planned scholarly or service activity. Grant/sponsored projects are funded from a source outside the University.

 

Proposal: A request for funding submitted to an external funding agency.

 

Reasonable: The Federal Office of Management and Budget (OMB) under circular A-21 defines reasonableness in terms of the "prudent person test." The general guide of reasonableness is, does the action "make sense" considering the context in which, and the purpose for which, the action is being taken.

 

RFP: Request for Proposal is a document which is sent out to solicit grant proposals.  It contains critical information on what the funder is looking for and who is eligible.

 

RFR: Request for Response is a document which is sent out to solicit bids for funder defined specific activities with specific outcomes.  It is usually implemented via a contract.

 

Sponsor: An external agency that provides funding for a University scholarly activity, research or service program.

 

Sponsored Project:   A project funded by a grant, contract or cooperative agreement under which the University agrees to perform a certain scope of work, according to specified terms and conditions, for a specific budgeted monetary compensation.  This externally funded activity is budgeted and accounted for separately and governed by specific terms and conditions.  Sponsored projects may be in the form of grants, contracts, or cooperative agreements for research, instruction, and/or public service activities.

 

Start Date: Start date of grant/sponsored project activity.

 

Subcontracts: A subcontract may be required if part of the research effort under a grant or contract is to be performed by another organization. If the subcontract is part of a proposal to a federal sponsor or from federal funds, please work with the Grant Coordinator to determine whether the subcontractor should be treated as a Vendor or Subrecipient. Making the appropriate decision before proposal submission can avoid problems after the project is funded. Subcontracts are always awarded to an organization or institution, not to an individual.

 

Third -Party In-Kind Contribution: A non-cash contribution to a grant/sponsored project or program provided by a party other than Worcester State University or the primary sponsoring agency.  Third-party in-kind contributions may be in the form of real property, equipment, supplies and other expendable property, or goods and services directly benefiting and specifically designated for the project or program.

 

 

Approved by

Vice President/Date

 

 

Approved by

Cabinet/Date

 

 

Revised Date

 

December 5, 2012

 

Version: 3.0 
Created at 5/31/2012 9:38 AM  by Hoxha, Anisa 
Last modified at 12/17/2012 10:34 AM  by Hoxha, Anisa