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Handbook of Operating Procedures
Chapter 10 - Research
Previous Publication Date: April 13, 2005
Publication Date: February 9, 2021
Policy Owner: VP for Research


10.12 Sponsored Programs Administration


I. POLICY STATEMENT


Within the Office of the Vice President for Research, Economic Development, and Knowledge Enterprise (REDKE), there are two assistant vice president level divisions providing services for sponsored programs administration. The Office of Sponsored Projects Administration (OSPA) includes Research Service Centers (RSC) and Contracts and Industry Agreements (CIA) units. The Office of Research Finance and Operations (ORFO) includes Grants and Contracts Financial Services (GCFS) and Post-Award Administration (PAA). In an integrated manner, OSPA and ORFO enable and safeguard the conduct of research and development and other sponsored activities for The University of Texas San Antonio by applying specialized regulatory, statutory, and organizational knowledge in a timely and professional manner. OSPA and ORFO focus on maximizing the related institutional key performance indicators by balancing the university's mission, the sponsor's objectives, and the investigator's intellectual pursuits.


II. RATIONALE


UTSA is committed to the ethical stewardship of funding from external sources. Through that commitment, UTSA follows sponsor requirements as well as federal and state mandates for supporting funding requests and managing external funding received. To ensure consistency and accuracy in meeting these requirements, proposal submissions and awards management are centralized activities conducted by a professional staff with broad knowledge of the regulations of federal and state agencies and records retention obligations.


III. SCOPE


All UTSA faculty, staff, students, and affiliated researchers.


IV. WEBSITE ADDRESS FOR THIS POLICY


http://www.utsa.edu/hop/chapter10/10.12.html


V. RELATED STATUTES, POLICIES, REQUIREMENTS OR STANDARDS


All policies, rules, regulations, and standards referenced here are incorporated herein to the requirements described in this policy.

UTSA or UT System Policies or the
Board of Regents Rules & Regulations

Other Policies & Standards

2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
HOP Chapter 10

UTSA Financial Management Operational Guidelines
OSPA Guidelines and Standard Operating Procedures


VI. CONTACTS


  • The Office of Sponsored Project Administration (OSPA) 210-458-6221
  • The Office of Research Finance and Operations (ORFO) 210-458-xxxx [To be added after HOP Review. AVP position vacant at this time]
  • Visit http://research.utsa.edu/whotocontact for department-specific points of contact for pre-award and post-award business services.

VII. DEFINITIONS


Formal Proposal
A formal proposal includes all submissions to support a specific scope of work, including proposed contracts and cooperative agreements which formally identify specific obligations or commitments of UTSA.

Allowable Cost
A cost that is reasonable, allocable to the sponsored program, and consistently treated throughout the institution. The cost must not be previously committed to another project as cost sharing or included in the F&A calculation.

Authorized Official (AO )
Authorized Official (AO) is the administrative official who is empowered to sign certifications and assurances, and submits proposals to external sponsors on behalf of the university. 

Facilities and Administrative Costs (F&A)
Costs incurred for a common or joint purpose that cannot be identified specifically with a particular sponsored project or instructional activity. Indirect costs include utilities, depreciation, and facility costs. They are real costs of conducting research, instruction, and training, which must be funded by either the sponsor or UTSA Administration. F&A cost are also known as "Indirect Costs" (IDC).

Principal Investigator (PI)
A Principal Investigator is the primary individual responsible for the preparation, conduct, and administration of a research grant, cooperative agreement, training or public service project, contract, or other sponsored project in compliance with applicable laws and regulations and institutional policy governing the conduct of sponsored activity.

Sponsored Activity
An award is broadly defined as financial support for a specific research project, training program, equipment purchase, or other type of project funded by an external sponsor, which is determined by the source of funding such as Federal (coded as Fund: 5100), State (Fund: 5100), Local (Fund: 5300), and Private/Industry (Fund: 400). For an award to be considered a sponsored activity (i.e. sponsored program or sponsored project) and to be subject to this policy, it should have one or more of the following characteristics:

  • Payment is contingent upon the delivery of a specific tangible item (deliverables), such as a report, samples, a data set, assays or prototype, or the achievement of specific performance targets.
  • There is a line item budget detailing or limiting expenses by activity, function, or project period or limiting the freedom to transfer funds among expenditure categories; this makes it a “restricted fund”.
  • A detailed financial report, certified voucher, federal single audit or external audit is required.
  • Any unexpended funds must be returned to the sponsor at the end of a project period, unless it is a “fixed price” contract.
  • The proposed agreement provides for the disposition of intellectual property (e.g., copyrights, patents, or licenses).
  • The proposed activity involves government-supported construction, alteration, renovation or acquisition of equipment or facilities.
  • The proposed budget includes payment of indirect costs by the sponsor.

Uniform Guidance (UG)
The Uniform Guidance (2 CFR 200) is a set of regulations that that govern research administration and management of federal funds, replacing A-110 (Grants and Agreements with Institutions of Higher Education), A-21 (Cost Principles for Educational Institutions), and A-133 (Audit Requirements).

Restricted Research Expenditures
An externally sponsored project is considered restricted research when an expenditure of funds that an external entity has placed limitations on and for which the use of the funds qualifies as research and development according to the Texas Higher Education Coordination Board’s definition of restricted research in the Standard Accounting Methods. These projects are set up with a function code of 200 in PeopleSoft.


VIII. RESPONSIBILITIES


Principal Investigators and Project Directors (PI/PD)

  • Prepare proposals to external funding organizations and assure that the information contained therein is accurate and correct to the best of their knowledge
  • Follow compliance requirements and manage scientific aspects and deliverables of externally sponsored project(s) in accordance with sponsoring agency and UTSA’s guidelines and procedures
  • Monitor the appropriateness of all financial charges and transactions on sponsored projects, including those of any subawards
  • Prepare and deliver timely progress reports, final technical reports, or other deliverables on the project as required according to the milestones of the project
  • Contact the Research Service Center for Pre-Award and the Post-Award Administration for Post-Award related issues (http://research.utsa.edu/whotocontact)

Research Service Center (RSC)

  • Proposal submissions
  • Award negotiation and acceptance.
  • Confirm compliance with federal, state, sponsor, and UTSA terms and guidelines for applications and awards.
  • Assist in administering and maintaining compliance requirements by advising UTSA academic and administrative departments during the proposal process.
  • Work collaboratively with the RSCs’ Advisory Teams.

College/Department

  • Assist PI/PD in the administration of their projects in making appropriate charges to sponsored project accounts
  • Ensure consistency of charging practices within the unit
  • In conjunction with PI/PD, review and maintain financial records for appropriateness of charges (periodic financial reconciliation) and for reviews by internal or external auditors
  • Approve budget transfers for cost share cost centers

Grants and Contracts Financial Services (GCFS)

  • Set up new Project IDs in PeopleSoft for grant and contract awards
  • Process Award modifications in PeopleSoft for grant and contract awards
  • Create and issue Internal Notice of Award
  • Prepare and submit required financial reports
  • Prepare and submit invoices to sponsors
  • Create Cost Share cost centers
  • Initiate cost share transfer(s) from units as documented on cost share statement
  • Process, review, approve cost transfer requests
  • Create and issue Internal Notice of Award
  • Route billing, collections and reconciliation of grants and contracts receivables (not reconciliation of expenditures
  • Confirm state pass-through funds
  • Troubleshoot financial issues throughout the duration of the award in conjunction with the RSCs Post-Award.
  • Prepare Letter of Credit (LOC) draws
  • Prepare federal cash requests
  • Prepare state drawdowns
  • Process no-cost extensions
  • Reconcile and manage Accounts Receivable (Funds 5100 – 5400)
  • Record ACH deposits
  • Transfer residual funds for fixed price awards
  • Ensure all sponsored revenue is received and recorded correctly
  • Finalize project closeouts

Post-Award Administration (PAA)

  • Review and approve expenditures in accordance with Uniform Guidance or sponsor requirements
  • Process re-budgeting and cost transfer requests
  • Serve as the chief liaison to the sponsor and authorized official (AO) on all sponsored funding grants/contracts.
  • Monitor and track cost share commitments
  • Facilitate payroll confirmation reporting
  • Review and submit prior approval requests to sponsor
  • Prepare, review, negotiate, and execute subaward agreements
  • Review and approve service/participant/speaker agreements funded by sponsored grants/contracts.
  • Assist with subrecipient monitoring
  • Process payment of subaward invoices
  • Review and approve non-competing continuation applications and progress reports
  • Participate in award negotiation, set up, and closeout
  • Confirm compliance with federal, state, sponsor, and UTSA terms and guidelines for sponsored awards.
  • Serve as the chief coordinator for administering and maintaining compliance requirements by advising UTSA academic and administrative departments.

Contracts and Industrial Agreements (CIA)

  • Draft, review, negotiate, and execute sponsor program agreements and contracts (financial and non-financial) to ensure compliance with applicable laws and regulations, and UTSA’s policies and procedures.
  • Work closely with the RSCs and GCFS to establish research agreements that involve funding e.g. sponsored research agreements (SRAs), contracts, subaward agreements, and others.
  • Work directly with faculty and staff to establish non-financial research-related agreements, e.g. non-disclosure agreements, material transfer agreements, cooperative research and development agreements, teaming agreements, and data use agreements.
  • Coordinate with appropriate units within UTSA to ensure contractual compliance, e.g. Institutional Review Board (IRB), Export Control.
  • Serve as the primary point of contact with sponsor and other external parties for contractual related matters.
  • Provide technical assistance and training on contractual processes, and contractual terms and conditions.
  • Distribute fully executed agreement to RSC, faculty, and/or staff to complete administrative processes and start project activities.

Budget Office

  • Process budget transfers for residual funds for fixed price awards
  • Process budget transfers for cost share cost centers

Accounting Office

  • Process drawdowns for Federal awards based on Letter of Credit or SF-270 prepared by GCFS.
  • Process cost transfer requests between Projects and Cost Centers

IX. PROCEDURES


A.  Proposal Preparation
Any formal proposal requesting project support from an external funding organization must be approved before it is submitted to the funding organization. Formal proposals include all submissions to support a specific scope of work, including proposed contracts and cooperative agreements which formally identify specific obligations or commitments of UTSA. For the purposes of this policy, proposals also include applications for renewals, continuations and proposal revisions.

A proposal must be prepared by the PI/PD and approved by the corresponding department chair, dean, and Director of Research Service Center. The RSC directors are authorized officials (AO) to sign proposals on behalf of the university. In some cases, the Director of Contracts and Industrial Agreements approves contracts and cooperative agreements under institutional signature authority.

Changes will be permitted in proposals that have received final approval only when authorized by the RSC director. UTSA may withdraw a proposal if it is submitted to a funding organization with changes made after the proposal was approved. Proposals which have not been fully approved may not be submitted to a funding organization.


B.   Processing Funds from External Sources
The appropriate processing of funds from external sources is of extreme importance to the university. Some general rules governing the processing of external funds are:

1. Grants, Contracts, and Cooperative Agreements. When funds are received in support of a sponsored activity, there should be either a proposal which has been processed through RSC, a grant, contract or cooperative agreement that OSPA has reviewed and approved, or some arrangement relating to the receipt of project funds which have been agreed to by OSPA.

2. Gifts. Funds which are designated as gifts to the university and not defined as project grants/contracts or research arrangements are subject to the approval procedures for gift solicitation developed by the Office of the Vice President for Development and Alumni relations (OVPDAR). OSPA and the OVPDAR will coordinate to manage the external funds accordingly.

3. Other. Occasionally, departments will receive funds which are not the result of contracts, grants, cooperative agreements or gifts. Where there is a question regarding classification of external funding as a grant, contract, or gift, OSPA and OVPDAR will determine the appropriate classification and acceptable uses of the funds. After review, the appropriate VP unit will ensure the funds are placed in the appropriate departmental accounts. The provision for or the lack of funding for Facilities and Administrative Costs (F&A) is not relevant in classifying external funding as a grant, contract, or gift.

4. Sponsored Project Classification.The RSCD and the Pre-Award Staff in collaboration will determine and document the determination of a sponsored project’s proper classification. Based on several indicators and documented materials (i.e. Notice of Award, CFDA Program Grant Overview, Sponsored Project Agreement, etc.) to classify the project as Research, Instruction, Public Service, Mixed Purposes, Other Purposes and Service Only.

C.  Negotiations and Unusual Requirements
All grant and contract awards are negotiated by the OSPA. All negotiated budgets that differ from the original budget that was submitted with the request for funding must be approved by the RSCD in conjunction with the PI/PD.


A grant or contract proposal with unusual procedural, reporting, or billing requirements beyond UTSA’s policies or practices should not be accepted or recommended for approval until the OSPA has received approval from appropriate university officials (e.g., GCFS Director).


D. Budget Categories and Classifications
All grant and contract proposal budgets shall comply with the applicable regulations of the intended funding organization and with the fiscal and personnel policies of the university.


All proposal budget items must satisfy three basic tests: allowable, reasonable and necessary as defined in Uniform Guidance 2 CFR 200 (UG). A cost is allowable if it is within the applicable regulations or has been approved by the funding agency. A cost is reasonable if the nature of the goods or services acquired and the amount involved reflect the action that a prudent person would have taken under the circumstances prevailing at the time the decision was made to incur the cost. A cost is considered necessary if it is required to successfully and satisfactorily complete the project.

A proposed budget must be based upon a "good faith estimate" of the anticipated costs. The cost estimates must have a reasonable basis.

Any personnel listed in a proposal budget must use the established university job titles, pay scales and associated employee benefits.

i. Salary. UG requires that charges for work performed on sponsored agreements by faculty members must be based on the individual faculty member's regular compensation which constitutes the basis of his or her salary, i.e., the faculty member's budgeted academic rate. In no event may charges to sponsored agreements exceed the proportionate share of the base salary for the period covered. See HOP 10.06, Institutional Base Salary.

Budgeted salaries and wages for non-faculty employees must agree with UTSA's compensation plan currently. Employees on grants and contracts are considered to be State employees and are entitled to State mandated pay increases.

ii. Administrative Stipends. Supplemental administrative stipends which result in an increase to the base salary are not allowable in accordance with UG.

E. Facilities and Administrative Costs (F&A)

UTSA strictly requires that allowable facilities and administrative (F&A) costs are included at the proper rate in all proposals submitted to prospective sponsors. F&A rate can only be adjusted under these conditions:

1. The grant program prohibits or limits reimbursement for F&A in writing;

2. The sponsor has a written policy governing F&A recovery, a copy of which should accompany the proposal; or

3. REDKE makes the determination to reduce or waive F&A if it is in the best interest of the university.

F&A Revenue from sponsored projects is allocated and distributed based on a memorandum of understanding (MOU) signed by the Vice Presidents of Academic Affairs (VPAA), Business Affairs (VPBA), and Research, Economic Development and Knowledge Enterprise (VPREDKE).


XI. FORMS AND TOOLS/ONLINE PROCESSES


None.


XII. APPENDIX


None


XIII. Dates Approved/Amended


04-13-2005: formerly known as 9.32
02-09-2021