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Project Start-up

Chapter Overview


Award Setup

Upon official receipt of an award or fully executed contract, the Principal Investigator/Project Director (PI/PD) ORSP will have already received a completed routing sheet, an approved budget, SOW and necessary justifications and completed compliances. ORSP will obtain the final approvals (after the department dean) and signatures needed to process the routing form and final elements. PI(s) should be aware changes or clarification may be needed at any review and or routing approval. When the package is complete, reviewed and approved, ORSP will set up a proposal account in banner, then send the routing sheet and materials to Sponsored Programs Accounting. Sponsored Programs Accounting will then review the materials and may have additional questions based on the package. When Sponsored Programs Accounting approves the package, then the index is created to record accounting transactions on the grant/contract. Sponsored Programs Accounting will e-mail the PI/PD all pertinent account information for the grant, at which point the PI/PD can begin to incur expenses on the project.

Some sponsors fund multiple year awards incrementally: that is, they provide for one year of funding at a time rather than providing all the funding "up front." In such circumstances, ORSP will process an award setup only for the specified year and amount. When subsequent funding is received, at that point ORSP will process an award modification and send to Sponsored Programs Accounting. In order to effectively manage a grant project, it is essential for the PI/PD to carefully review the policies, terms, conditions, and procedural requirements of the funding agency. Informational meetings with Sponsored Programs Accounting are strongly encouraged, particularly for new investigators and project managers.  

Institutional Prior Approval System

Many federal sponsors allow universities to unilaterally authorize approval to incur pre-award costs up to ninety days in advance of the anticipated start date, provided there is sufficient programmatic justification for starting work early on the project. Email Sponsored Programs Accounting if you need to do any of the following.

    • requesting authorization to incur pre-award costs up to 90 days prior to the anticipated start date of the award as sponsor terms and conditions and federal expanded authorities guidelines permit; or
    • requesting authorization for creation of an advance fund if award is imminent but delayed beyond the anticipated start date.

Requests for prior approval of “pre-award costs” or requests for “advance funding” are at the grantee’s risk, and must be well justified programmatically (and not for mere convenience). Anticipated costs must be reasonable and allowable.

Compliance

Federal regulations stipulate that institutions applying for federal funds assure the appropriate federal agency that certain conditions and policies are in place at the applicant institution. Federal funding is at risk University-wide if individuals do not comply with these very important assurances.

Pacific's Institutional Review Board (IRB) has an obligation to review all human subjects' research by Pacific faculty, staff and students as a condition of receiving Federal funding.  More importantly, all research projects, whether funded or unfunded, in which human subjects participate, are subject to the federal regulations governing such research requiring IRB review.

1. Institutional Review Board (IRB) : Pacific policy requires that individuals who conduct research involving human subjects, or who supervise researchers, must comply with various ethical and legal standards. All research involving human subjects must obtain IRB review and approval before research activities commence. Funding source, location, duration and the population subject to research do not alter the Principal Investigator's responsibility to obtain IRB approval. To initiate the review and approval process complete the required Human Subjects Research Worksheet and submit to IRB@pacific.edu. Additional IRB resources can be obtained online here.

      • Award set-up on projects conducting research with Human Subjects: ORSP must receive a notice of IRB approval before it will submit routing sheet and materials to Sponsored Programs Accounting. Grant funds will not be released and grant work cannot begin without necessary compliance approval (IRB/IACUC).
      • Incentive Payments to Human Subject Participants: PI's must adhere to the applicable terms of the grant, contract, and/or signed funding agreements. For awards that plan to provode incentives (e.g., cash or gift cards) to research subjects, please contact your departments Business Manager to ensure that incentives are distributed in accordance with the University Business Policies and Procedures.

Award set-up on projects that use human subjects: ORSP must receive a notice of IRB approval before it will submit an the routing sheet and package to Sponsored Programs Accounting. Grant funds cannot be released or any grant work started without IRB/IACUC/All Compliance approval.

2. Institutional Animal Care and Use Committee (IACUC): Pacific has an appointed IACUC to ensure that the University and covered entities are in compliance with the Animal Welfare Regulations and Public Health Service Policy. To this end, every research, testing, and teaching project involving the use of a live vertebrate animal must be reviewed and approved by the IACUC prior to initiation. For awards that involve animal research, ORSP will notify the IACUC Administrator.

3. Financial Conflict of Interest (FCOI): Pacific is committed to preserving the public trust and upholding the integrity of the design, conduct, and reporting of its research. This policy promotes objectivity in research by establishing standards to ensure that research performed under federally sponsored grants or cooperative agreements will be free from bias resulting from FCOI.All Pacific faculty, staff, students, and any other University investigators who are responsible for the design, conduct, and reporting of research funded or proposed for federal funding are required to follow Pacific’s FCOI policies and procedures.


Policies ButtonMore on FCOI policies here.

4. Responsible Conduct of Research: Effective October 1, 2009, the NSF mandated that all students and post-doctoral fellows supported by NSF funding must receive training in the Responsible Conduct of Research (RCR). Pacific must certify that the institution in its entirety is familiar with applying the procedures for the responsible conduct of research.Faculty who are supervising students working on research grants must be familiar with these procedures in order to ensure that students are applying them. This is the rationale for requiring faculty to participate in RCR training. All faculty receiving NSF awards (and staff and students) must complete the responsible conduct of research training online module as soon as a grant is awarded to Pacific.
Contact ORSP for directions on how to complete the training. The PD/PI will notify ORSP when the training is complete.

Policies ButtonMore on Responsible Conduct of Research (RCR) here.

5. Export Control: Export Controls involves the set of U.S. laws, rules, and regulations that govern the distribution to, or sharing of information, technology, services, and materials with foreign individuals, entities, and/or countries to protect the nation’s national security interest. University of the Pacific’s Export Controls Policy provides faculty, staff, and students with guidance and applicable procedures, should a project involve international elements.PIs/PDs should always report any changes to funded projects which may evoke export controls immediately and submit any questions contact ORSP.

Policies ButtonExport Controls Policy

6. Invention Reporting and Disclosure: As a recipient of federal funding, under the Bayh-Dole Act (37 CFR 401), the University has an obligation to report all government-funded subject inventions, patents, and any associated use of the invention to the agency that funded the project from which the invention was derived. To comply with this federal law, over thirty federal agencies use the Interagency Edison (iEdison) web-based system, to include the NIH, NSF, Department of Energy, EPA, NOAA, and Department of Defense. iEdison’s reporting system allows grantees to securely and confidentially create, upload, and submit new invention reports. Each report is unique and contains the source of the funding and the name(s) of the inventors. Disclosure of inventions at University of the Pacific are governed under Pacific’s Patent Policy.

It is critical that the principal investigator disclose any invention in a timely manner to the University Patent committee and Dean. The Invention Disclosure Form contains important questions about the invention and the inventor(s), any prior or planned publications, potential commercial applications, and several others. But also, importantly, it asks the inventor(s) if the work that led to the invention is the result of sponsorship. If it is the result of federal sponsorship, then the University is obligated—in most cases—to report the invention to the federal government via iEdison.

Policies ButtonMore on Pacific's Patent Policy here



Issuing Agreements to External Collaborators

Upon notice of award (and, in some cases, prior to notice) the process will begin in issuing appropriate agreements to any external collaborating entities, be it a public or private university, corporation, or non- profit entity. ORSP's staff will assist the PI/PD with this often complex process.
The terms “subcontract” and “subaward” are often used interchangeably, but in its most “technical” sense, a subaward is issued under a prime grant agreement, whereas a subcontract is issued under a prime contract agreement. For the purposes of this discussion, the term subcontract will be used.

I. When Pacific is the Lead Institution: When Pacific is the prime recipient of a grant that has one or more subrecipient(s), a subcontract agreement is sent to the subrecipient(s) by ORSP. ORSP will prepare the subcontract agreement in accordance with the terms and conditions of the prime award and send to the subrecipient’ s institutional contact for signature. Subcontracts are generally issued from year to year, although if a program/project is “fully-funded” up front, a subcontract can be issued for the entire project period, particularly if the PI/PD and ORSP have a level of familiarity and comfort in working with that particular subrecipient. Under Uniform Guidance, Subpart D (§200.331), prime recipients are required to evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate level subrecipient monitoring. To meet the Uniform Guidance mandates, ORSP will conduct a risk analysis at the time of award and include the appropriate mechanisms, based on the level of risk, to ensure that the subrecipient and, consequently, Pacific are compliant with Uniform Guidance. Ultimately, however, it is the responsibility of the PI/PD of the lead institution to monitor the performance of the subcontractor and to ensure that work on the project is proceeding as planned and proposed in the original application.

Where one or more institutions of higher education are concerned, the subcontract negotiation process is generally quite smooth, largely due to the efforts of the Federal Demonstration Partnership, which creates uniformity in the issuing of standard template subcontracts that universities can use to facilitate the subcontracting process. ORSP will work directly with the Sponsored Programs Officers at each institution to facilitate the process. During this process, requirements for IRB/IACUC will need to be satisfied by the subrecipient’ s institution if any human and/or animal subject use will be performed by the subrecipient.

Negotiation of subcontract agreements with private sponsors (e.g., corporations) may be more complex due to competing interests and internal processes and procedures. Once the subcontract agreement has been fully executed by all parties, ORSP will send a copy of the agreement to Sponsored Programs Accounting. Sponsored Programs Accounting monitors subrecipients subject to the Uniform Guidance: Subpart D, Subrecipient Monitoring (§200.330-§332) to ensure that there are no internal control of compliance findings associated with the sponsor.

II. When Pacific is the Subrecipient (an external entity is the lead institution): When a PI/PD receives notice from his/her collaborators that an award is forthcoming, the PI/PD should contact ORSP pre-award staff as soon as possible so that ORSP can make contact with the external organization’s Sponsored Programs Office. As with any award, it is important not to incur any expenses or start work on the project until the subcontract agreement has been fully executed by all parties. In some cases, a PI/PD may request authorization to incur pre-award expenses up to 90 days in advance of the anticipated start date (see section on Institutional Prior Approval earlier in this chapter). Similar to a subcontract issued from Pacific to another organization, a subcontract received by Pacific from another organization may be issued annually, or multi-year. Pacific may need to satisfy any pending IRB/IACUC approvals prior to the award’s issuance, and the lead organization or institution may request additional information (e.g., a copy of Pacific’s latest Audit Statement).

III. Typical Components of a Subaward or Subcontract

a.  Cover Page: The cover page typically identifies the subcontracting parties, the project title, budget or performance period start and end date, subcontract number, prime award number, and signature lines for each party’s authorizing officials.  More information on Signature Authority here.
b.  Contact Page: Identifies the appropriate institutional technical, financial, and administrative contacts at each organization/institution.
c.  Terms and Conditions: Incorporated in full or by reference and includes those terms and conditions to which the subrecipient must comply in the performance of the sponsored agreement. Some examples might include: technical and financial reporting requirements; disposition of tangible (equipment) or intangible (intellectual) property; termination; provisions for changes or modifications of the budget, key personnel, scope of work, and other amendments.
d.  Attachments: The attachments section most often includes the final statement of work and final approved budget.

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