Sponsored Projects FAQs and Best Practices
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Best Practice: Some answers to frequently asked questions are noted as "Best Practice". This answer is not specifically addressed in research policies, but it is addressed in other policies and procedures within ASU.
General Questions
1. What services and resources are available to faculty and departmental administrators? For
timely delivery, FedEx packages should be addressed using the name of
the person, "ASU",
the person's department, and their building and room number.
Federal Express, UPS, and other carriers use the PO Box system for ASU. The
drivers know this system so it is appropriate to use: Staff Member's Name The street address is not necessary but if
it is insisted
upon, use the administrative office address: Staff Member's Name You can also use the street address of any other building on campus, if known. It is also appropriate to use the shipping and receiving
address information. Remember the package may not arrive in the
same timely manner you expect from FedEx. Once they deliver to
shipping and receiving
it is out of their hands and final delivery depends on the ASU Mail
Services schedule. Arizona State University Main Receiving
2. How do I locate my sponsored projects officer (SPO), sponsored projects accountant (SPA), or other ORSPA contacts?
You can find your ORSPA and department contacts by using that tool at this link:
http://researchadmin.asu.edu/contacts/index.cfm
3. What's your FedEx shipping address?
ASU ORSPA
PO Box 873503
Building
Room Number
Tempe, AZ 85287-3503
ASU ORSPA
1120 S Cady Mall
Interdisciplinary B, Room 163
Tempe, AZ 85287
1711 S. Rural Road
Rural & Vista Del Cerro Rds
Building Room Number (Staff Member’s Name)
Tempe, AZ 85287
Funding Information
1. Who coordinates limited submission announcements?
Contact
Deborah Ash Goode
at (480) 727-7961.
2. Where can I find out about the ASU Expertise Database System and Community of Science (COS)?
See ORSPA's Expertise page or visit our Funding
Information page.
Proposal Preparation & Processing
1. Where do I locate proposal budget information on Facilities and Administration costs (F&A), cost sharing, etc.? Cost sharing: Infrastructure support:
See Developing the proposal budget.
2. Where do I locate ASU's standard institutional information for completion of sponsor forms?
The Proposal Preparation and Processing page has this form as well as other information that
may be useful to you. You can also access the form directly.
3. Who is designated as the authorized institutional representative?
Deborah Shaver
Director, Research Administration
4. How do I know when I should have a sponsored agreement versus a personal consulting agreement?
You should always use a sponsored agreement when the resources of the university are used to complete all or part of the scope of work. In most cases, a personal consulting agreement is appropriate when you are performing work on your own time, outside of the contractual commitment to the university.
5. What is the institutional policy on matching funds and cost sharing?
The policy can be found here: http://www.asu.edu/aad/manuals/rsp/rsp506-03.html
6. What is the difference between cost sharing and infrastructure support?
The difference is significant to the university. Cost sharing
is a legally binding condition for accepting sponsor's funding. In contrast,
infrastructure support represents an investment in resources needed to
conduct research.
7. How do I determine when an expenditure is cost sharing or infrastructure?
Direct cost items that are not funded by the sponsor are by definition
cost sharing. Facilities & administrative (indirect) items
are institutional support. (For more information on the differences
between direct and
F&A items see RSP
508-01: Charging Direct and Facilities & Administrative Costs to Sponsored Projects.)
For example, a research
study requires a new personal computer to process survey results.
The researcher will use the computer on the research study and for
e-mail in general. Because the computer is used non-project activities,
it is by definition infrastructure support. However, if the
proposal the specifies the university will purchase one Dell X-390
with a cost
of $5,500
for
tabulating
survey results, it will
be considered cost sharing.
To avoid turning infrastructure support
into cost sharing do not insert F&A costs into proposal budgets and
budget justifications.
8. Under what circumstances are instructional programs considered sponsored projects?
Most instructional programs are funded by tuition or by program
income. Instructional
programs are considered sponsored projects when they are offered outside
of the standard tuition funded approach. Instructional programs
may also be considered sponsored if deliverables are required (e.g. curriculum
development, a research report on the teaching experience) or when there
are unusual contract terms (e.g. requirements of a foreign sponsor/partner). When
in doubt, always consult with your Sponsored Projects Officer.
9. How do I know if it's a grant or a contract?
An integral factor in the budgeting process is the type of award (e.g., grant, contract, cooperative agreement) that will be issued in the event that the proposal is successful. Certain costs that are acceptable for grants and cooperative agreements are not reasonable costs for contracts. As an example, travel to conferences is an acceptable and even desirable cost for a grant since attendance at professional conferences helps to further the overall grant goals of expanding the public knowledge base. However, for a contract, conference-related travel might not be considered germane to the accomplishment of contract requirements and be of no interest to the sponsor. Another example is publication costs; generally speaking, costs associated with disseminating research results via professional publications are not usually relevant to contracts.
Another area of concern is the purchase of capital equipment. For the most part, sponsoring agencies for grants not only authorize the purchase of such equipment, but allow the University to retain title to the equipment, even after grant termination. However, most contracting activities discourage or forbid the purchase of capital equipment and in cases where the purchase is authorized, title to the equipment usually will reside with the sponsor.
Clearly, determining the type of anticipated award plays a significant part in the budget development process. Generally speaking, most federal granting agencies and private non-profit foundations will award grants, and most other federal sponsors and for-profit companies will issue contracts. However, there are instances when a typical granting agency, such as PHS, may issue a solicitation for a contract; and another agency such as DARPA may solicit and fund a project through a granting agency. So, before the assumption is made, read the solicitation or program announcement. If in doubt, contact your ORSPA site officer for a determination.
10. How do I request Supplemental Pay on a Sponsored Project?
The procedure for requesting supplemental pay is located in the Proposal section of the ORSPA website, under Budget Development. You can also access the Justification for Supplemental Pay form directly.
Award Negotiation & Acceptance
1. What if a sponsor asks me to sign a non-disclosure or confidentiality agreement?
It is almost always inadvisable for a faculty member to sign a confidentiality
agreement because such an agreement may have serious consequences for
such things as publications and intellectual property. If necessary to
close a deal, then the University will consider signing a confidentiality
clause on behalf of the faculty member when such a clause is limited to
the proprietary information of the Sponsor and the use of such information
is not necessary for the publication or verification of the research results.
2. How do I know when I should have a sponsored agreement versus a personal consulting agreement?
One should always use a sponsored agreement when the resources of the
University are used to complete all or part of the scope of work. In most
cases, a personal consulting agreement is appropriate when one is performing
work on his or her own time, outside of the contractual commitment to
the University.
3. What is the institutional policy on matching funds and cost share?
See the policy at: http://www.asu.edu/aad/manuals/rsp/rsp506-03.html
General Financial Accountability
1. Do I have to monitor my sponsored account?
Yes. As Project Director you are responsible for insuring that only allowable
costs related to your project are charged to the sponsored account set
up to reflect the spending on your project.
2. How do I monitor my sponsored account activity?
As Project Director, you will receive a packet of financial and payroll
information each month that details all transactions processed against
your account that month. You may also monitor financial activity throughout
the month by accessing your account on-line in the Advantage financial
system.
3. What is the Fly America Act? Do I have to do anything special when traveling to a foreign country?
Air travel funded with U.S. Government funding must be booked on a United
States of America flagged air carrier. For a list of allowable air carriers,
see http://dms.dot.gov/reports/domagnt.pdf.
If you choose to fly a non US flagged air carrier, contact your Sponsored
Project Officer (SPO) prior to booking the flight. Your SPO will determine
if you meet one of the extremely restrictive exceptions in the Act.
4. How do I know when I should have a sponsored agreement versus a personal consulting agreement?
One should always use a sponsored agreement when the resources of the
University are used to complete all or part of the scope of work. In most
cases, a personal consulting agreement is appropriate when one is performing
work on his or her own time, outside of the contractual commitment to
the University.
5. Does ASU have to receive the funds from the sponsor before I can start spending out of the account?
No. Once the account is established, spending can begin. ORSPA accounting
will follow up to secure the funds.
6. What is the institutional policy on matching funds and cost share?
See the policy at: http://www.asu.edu/aad/manuals/rsp/rsp506-03.html
7. How can I set someone up on payroll for less than six months without
affecting their benefits eligibility? When is someone considered benefits
eligible?
Best Practice: ABOR
defines "regular" vs. "temporary", instead of "benefits eligible" vs.
"non-benefits eligible". ASU obtained the definition language and practice
from Department of Administration and ABOR. See the definition for regular
employee found in section
002 of the SPP manual.
Generally employees on a temporary appointment, or temporary funding,
for less then six months would not be extended benefits even if they work
100% FTE. However, there is a manual process in place to use if needed
to override this automatic "6-month rule" payroll process. The HPR
should be completed using the 'regular' and 'full time' indicators. This
will reflect that they are in fact benefits eligible. However, because
of the start and stop dates, a NOTE will have to be made on the HPR which
states that "the positions are technically less than six months, but the
employees are benefits eligible". Otherwise, Human Resources would believe
that the regular and full time codes are incorrect.
8. What is a SPET (formerly SET) and CTR?
SPET: Sponsored Payroll Expense Transfer for payroll (salary) transactions (where a
sponsored account is involved in the transfer from/to local and/or state
accounts). Formerly known as a Sponsored Expense Transfer (SET).
CTR: Cost
Transfer Request of non-salary or non-payroll transactions (where a sponsored
account is involved in the transfer from/to local and/or state accounts).
For more information on ADRs or SPETs contact Cost
Analysis & Fiscal Compliance.
9. Does the University have policies that prohibit personal use of university
property and resources, including those purchased with sponsored projects
funds? If so, who is responsible for restricting personal use?
Best Practice: University policy prohibits
personal use of university property and resources. This includes supplies,
equipment and other resources purchased with sponsored projects funds.
Refer to http://www.asu.edu/aad/manuals/com/com117.html,
http://www.asu.edu/aad/manuals/pcs/pcs902.html,
http://www.asu.edu/aad/manuals/PCs/pcs505.html,
http://www.west.asu.edu/acadaffairs/ReFaculty/InTeach/FPolicies.htm.
All employees are responsible for complying with these polices. Failure
to do so can result in disciplinary action, including termination and/or
criminal prosecution.
Org Managers are responsible for restricting the personal use of university
resources. If personal use does occur, the org manager must ensure that ASU is reimbursed for resources committed to personal use. Refer to COM
203.
10. What happens to any residual balance once a sponsored project under a fixed price agreement ends?
University policy is that there should be little or no residual on a
fixed price agreement. However, if there is a balance once the project
is over, ASU will first book F&A on expenses or budget, whichever is greater
at the fully negotiated rate. Any existing cost overruns on other accounts
belonging to the specific investigator will also be net out. This process
is to discourage residual balances in an effort to have the investigator
properly budget and fully utilize funds provided for all project costs.
Next, the balance is transferred to a local discretionary departmental
account based on information provided by the Chair of the Department (not
the investigator). Refer to http://www.asu.edu/aad/manuals/rsp/rsp509-03.html.
Effort Reporting
1. Why is effort reporting required?
Federal regulations issued by the Office of Management & Budget (OMB) require employees performing work on sponsored agreements to certify university work efforts as a distribution of 100% of total compensated time worked. ASU has chosen the After-the-Fact effort reporting method described in Section J.10.c.(2) of OMB Circular A-21 to meet the requirement for certifying effort on sponsored project agreements.
2. What is included in the 100% of total compensated time worked?
The 100% of total compensated time and effort encompasses all activities performed for the university.
Examples of activities included in the 100% measure are teaching classes, working on committees, conducting research, writing reports and articles, proposal preparation activity, participating in seminars, consulting with colleagues and graduate students, and attending meetings and conferences.
Intra-University Consulting as described in ACD 510-04 is an example of incidental work paid by the university which is excluded from effort reporting certification. Also excluded from the 100% measure of effort is consulting not associated with the university as disclosed in a Notification of Consulting or Other Remunerative Arrangement.
3. My Graduate Research Assistant’s appointment is 50% FTE, but the Effort Report says that 100% of her salary came from the grant. Is this correct?
This is one of the most common misconceptions about effort on sponsored projects. Regardless of your appointment percent or the number of hours you work, your 100% effort equals all the activities for which you are compensated by the university -- your total ASU effort. Effort Reporting is not based on a 40-hour work week.
Examples:
4. How precise a measure is appropriate when reporting effort?
It is recognized that the nature of the work and the workload involved at academic institutions, varies and is often interrelated. Therefore, it is appropriate that reliance is placed on reasonably accurate approximations and a degree of tolerance in measuring project related effort is acceptable.
OMB has also recognized that it would be punitive to require faculty and senior researchers to document effort percentages “volunteered” in excess of proposed efforts. OMB issued an effort reporting clarification indicating that faculty and senior researchers’ sponsored work efforts in excess of proposed levels (referred to as volunteered uncommitted cost share) do not have to be captured on effort reports.
5. How has effort reporting changed from the paper Activity Distribution Reports (ADRs) to the new Effort Reporting in Peoplesoft?
Beginning in FY2008 the review and certification of effort on sponsored projects at ASU takes place in an Effort Reporting application within PeopleSoft.
Some of the changes and features of the new Effort Reporting application include:
6. Where are the activity categories in the new Effort Reports?
There is no longer a functional activity reporting requirement. Instead, reliance is placed on the NACUBO function coding of the sponsored account where the effort is certified. Additionally, using this residual category, we subsequently determine the F&A cost activities (e.g. departmental administration) through an alternative methodology. The information being collected which is most important on the Effort Report is the percentage of time an employee spends on each sponsored project during the designated Effort Reporting period.
7. Who receives Effort Reports?
The system will generate an Effort Report for all faculty, researchers, post-docs, graduate assistants, hourly student employees, staff, and other ASU employees who are paid from sponsored projects or have cost sharing obligations. The system automatically determines Effort Reporting recipients based on payroll records and cost sharing commitments. Effort reports are initially routed to the Department Effort Administrator (DEA) for initial review and further distribution.
8. How is an Effort Report generated?
The Effort Report contains an estimated effort distribution for the effort period that are based on an individual’s sources of pay, cost sharing commitments, and salary in excess of the NIH salary cap. The certifier can agree with or correct the estimated effort distribution depending on actual effort on sponsored projects during the effort reporting period.
Since the system uses an After-the-Fact effort reporting methodology, changes to the apportionment of the salaries and wages already paid and charged to specific accounts are accomplished with Payroll Redistributions processed in PeopleSoft HCM.
Cost sharing commitments entered into the Effort Reporting commitment module are based on the obligated award period and percent of effort indicated on the Cost Sharing Requirements Approval Form (305), a.k.a. “the green sheet”. Only commitments for the obligated budget period are entered. Future cost sharing commitments beyond the original obligated budget period must be included with the award modifications in order for the commitment to be pre-populated in the Effort Reporting commitment module.
Congress legislatively mandates a provision limiting the direct salary that an individual may receive under an NIH grant, cooperative agreement or applicable contract to a rate of no greater than Executive Level I of the Federal Executive Pay Scale. For FY2008, Public Law 110-161: Consolidated Appropriations Act, 2008 restricts the amount to $191,300. See http://grants1.nih.gov/grants/policy/salcap_summary.htm for a summary of past salary caps, the most recent cap, and a link to the recent notice and guidance on the proportion of salary above the cap that results in a cost sharing commitment on any related NIH sponsored project effort.
9. When are Effort Reports distributed?
Federal regulations require a minimum frequency for effort certification depending on the employee groupings of professorial, professional staff, or other employees. To meet these requirements, effort reporting periods are more frequent for Non-Exempt employees (those subject to overtime rules) than for the professorial and professional staff identified as Exempt employees. Although federal regulations allow bi-weekly time sheets containing effort distribution to be used as an alternative to effort report certification for Non-Exempt employees, ASU currently must certify this effort through effort reporting since the payroll system is not capturing and displaying payroll distribution by account on the time sheets employees complete and sign.
Non-Exempt employee (classified staff subject to overtime) and hourly student Effort Reports are distributed following every two pay periods (13 times a year) if paid from or providing effort to fulfill cost sharing commitments on sponsored projects.
Exempt employee (faculty, GRAs, GTAs, professional staff, etc.) Effort Reports are distributed three times a year following the close of the Fall, Spring, and Summer academic periods if paid from or providing effort to fulfill cost sharing commitments on sponsored projects.
The effort reporting periods will vary depending on the end dates of the PeopleSoft bi-weekly payroll cycle which are different from year-to-year.
Exempt employee effort reporting period example:
12/31/2007 – 05/18/2008 Period 1: Spring Effort 05/19/2008 – 08/24/2008 Period 2: Summer Effort 08/25/2008 – 12/28/2008 Period 3: Fall Effort
In general the standard fiscal year appointment is July 1 – June 30 and the academic appointment is August 16 – May 15. Due to the bi-weekly payroll cycle, effort reports for academic employees may contain a portion of the Summer effort during the Spring report, Fall effort in the Summer report, and Winter Intersession effort in both the Fall and Spring report.
10. What is the Effort Reporting workflow?
Level 1: ORSPA reviews form for any high-level data issues.
Level 2: Department Effort Administrator (DEA) reviews and releases forms to the certifier.
Level 3: Certifier applies electronic signature to the Effort Report.
Level 4: Department Effort Administrator makes any payroll adjustment or cost sharing adjustment request and then approves.
Level 5: ORSPA closes the form and locks the workflow.
If a payroll distribution or notification of a cost sharing commitment occurs after certification at Level 3, the form will be regenerated and cycle through the process as a new sequence. The original sequence(s) are saved for audit purposes.
11. When should Effort Reports be certified and the workflow completed?
Prompt review, certification, and correction of an employee’s paid and unpaid (cost sharing) commitment to a project is essential. Each time you certify effort, you do so for a specific period of performance. The time during which you certify effort is called the certification window. Each certification window is opened by ORSPA a month or more after its corresponding period of performance. Each time the certification window is opened, you have 45 days to certify the effort for the corresponding period of performance. Academic employees who are unavailable during the summer to approve their effort statements online when the Spring effort reports are distributed will need to need to review and certify them immediately upon their return in the Fall. In the event that effort reports for pay on sponsored accounts are not certified, the Department Effort Administrator (DEA) will be required to remove the payroll from the sponsored project account.
Since the online Effort Reporting system in PeopleSoft is new in FY2008, it is being incrementally rolled out in June 2008. It is expected that certification of effort reports may not be as timely as what will be required in the future. However, after we have processed a department’s initial group of effort reports, the timeliness described in the preceding paragraph will be followed. We will be in regular communication with the departments to make sure any concerns or circumstances which arise are addressed.
12. Who at ASU must certify effort?
Effort on a sponsored project of Graduate Assistants and hourly student employees is certified by the lead Principal Investigator (PI) for that project. All other employees with cost sharing commitments and/or pay on sponsored projects are required to certify their own Effort Reports.
13. Why do I have to certify the Effort Report myself? Can’t my Business Manager or Research Advancement staff do this for me?
Federal regulations for "after the fact activity records" requires that confirmation of the effort on Effort Reports be signed by the employee, principal investigator, or responsible official(s) using suitable means of verification that the work was performed. Having first-hand knowledge of the work performed and the ability to make a reasonable estimate of the effort expended on each sponsored project is key to fulfilling this requirement. Best practices indicate that having the employee certify their own record is preferred. Additionally, at ASU and other institutions, Graduate Assistants are typically certified by the project PI who is aware of the efforts provided on their projects by their graduate students. Business Manager or Research Advancement staff typically do not have the required first-hand knowledge or suitable means of verifying that the work was performed on particular projects.
14. What happens if I don’t certify my effort report in a timely manner?
If your effort is not certified within the date parameters specified, the Vice President for Research and Economic Affairs has instructed ORSPA not to process any pending proposals or set up any awards/award increments for you.
15. What are the risks of not complying with OMB Circular A-21’s effort reporting requirement?
Federal awards represent the majority of ASU’s sponsored project grant and contract award activity. Salary expense represents the largest direct cost component included in the budgets of sponsored projects. Paying salaries with federal funds requires an institution to have an effort reporting system that provides records on how individuals participating in federally funded sponsored agreements actually spend their time. It is incumbent upon institutions receiving federal funding to maintain accurate and auditable systems and records.
In recent years, the federal government has become very active in reviewing the effort reporting requirement. It is currently a specific audit focus in federal audit plans. As evidenced below, federal audit disallowances can result in large audit disallowances and financial penalties for institutions. Additionally, criminal charges may be brought against an individual certifying to falsified effort. Some of the recent cases of audit disallowances are:
Documentation on how individuals spend time on federally sponsored projects is subject to audit and can result in institutional or individual disallowances.
Institutional disallowances can result if:
Individual disallowances can result if:
16. What are some common Effort Report corrections?
The most common Effort Report issues Department Effort Administrator will encounter in their review which will require corrections are:
Incorrect Payroll Distribution Changes to the accounts or amount charged to reflect the actual effort worked during a bi-weekly pay period on a sponsored project are made through PeopleSoft Payroll Redistributions. Payroll Redistributions approved and processed in PeopleSoft post nightly in Effort Reporting.
Incorrect or Missing Cost Sharing Commitments The Department Effort Administrator will create a new case to be addressed by the ORSPA effort reporting team at http://www.asu.edu/go/support/ describing the cost share commitment change. An adjustment due to a reduction or increase in an existing commitment or the addition of a new commitment may also require submitting an updated Cost Sharing Requirements Approval Form (305) substantiating the change in the university’s commitment. Changes to cost sharing commitments are updated in Effort Reporting on a nightly basis.
17. Where can I get more help?
Effort reporting policy and procedure guidance and training videos are provided by ORSPA at http://researchadmin.asu.edu/effortreporting/training/
Support for using the Effort Reporting system (security access within PeopleSoft, performance, availability, interpreting content of effort report, correcting pay or cost sharing commitments, navigation within application, etc.) are requested by generating a new CRM (Customer Relationship Management) case at http://www.asu.edu/go/support/
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18. How do I sign up to be a Department Effort Administrator (DEA)?
Facilities and Administrative (F&A) Costs
1. What are F&A Costs?
Costs associated with providing facilities and administrative support for the conduct of research and other sponsored activities. These costs are not readily identifiable with a particular project or activity but are real, audited costs associated with the infrastructure needed for the general operation of a university and the conduct of its activities. They include costs of operating and maintaining buildings and grounds, equipment, the libraries, and of providing administration at the university, college and department levels.
On the other hand, direct costs are those costs which can be easily identified with a high degree of accuracy with a sponsored project or any other university activity. Direct costs include project related costs such as salaries and wages, personnel benefits, equipment, supplies and services, and travel.
2. Can the same type of cost be either a Direct Cost or an F&A Cost?
The Office of Management and Budget (OMB) Circular A-21 requires that costs incurred for the same purpose in like circumstances be treated consistently as either a direct cost or an F&A cost. However, there are special situations in which costs may be incurred for the same purpose but the circumstance is not the same. For example, the salaries of administrative personnel normally would be treated as an F&A cost. However, when these personnel perform project specific activities or extraordinary amounts of routine business activities associated with large projects that involve multiple investigators, they may be direct charged according to the relative time spent on the project.
3. What are the components of F&A rates?
F&A costs are divided into the following components (referred to as cost pools) which support sponsored project and other university direct cost activities:
Facility Costs
Administrative Costs
A rate is calculated for each cost pool based on methods prescribed in OMB Circular A-21. The total of these individual cost pools results in a rate that is subject to negotiation and approval of officials from the Department of Health & Human Services (DHHS), our cognizant federal agency. There is an “off-campus” rate which includes only administrative costs that is calculated for projects conducted in facilities not owned or operated by ASU, which include charges for facility rental as a direct expenditure, and for which more than 50% of the project salaries and wages are for effort conducted in the rental facility. Also, there are separate “on-campus” rates that include both the facility and administrative costs calculated for research, instruction and other sponsored activities. Each rate is expressed as a percentage of Modified Total Direct Cost (MTDC) which includes all direct costs except equipment, capital expenditures, patient care, tuition remission, rental costs of off-site facilities, scholarships, fellowships, and the portion of subcontracts in excess of $25,000.
4. What are the components and rates of ASU's current negotiated F&A agreement?
Predetermined Rates through 6/30/06*:
Organized Research
Instruction
Other Sponsored Activities
General Administration
7.70
5.10
7.80
Department Administration
14.80
14.90
14.90
Sponsored Projects Administration
3.50
.10
3.30
Student Services Administration
0.00
5.90
0.00
Administrative Components—Off Campus Rate:
26.00%
26.00%
26.00%
Equipment Depreciation
5.00
2.50
3.00
Building Depreciation
2.60
3.20
.70
Interest
1.60
2.60
.10
Operation & Maintenance
13.00
8.80
2.80
Library
1.30
14.80
.40
Facility & Admin Components—On Campus Rate:
49.50%
57.90%
33.00%
*Rates based on FY 1999 expenditures.
5. In simple terms, how are F & A rates calculated for sponsored projects?
ASU identifies its F&A costs (i.e., expenditures already incurred) and accumulates those costs in the various F&A cost pools. The F&A costs in each cost pool is then allocated to the direct cost functions of the university (research, instruction, and other sponsored activities) according to methods prescribed in OMB Circular A-21, or alternative methods approved by federal negotiators.
6. How are F&A cost rates negotiated?
ASU submits a formal F&A cost rate proposal to our cognizant federal agency, the Department of Health and Human Services (DHHS). The proposal is based on the most recent fiscal year for which complete cost data is available and is evaluated by DHHS negotiators who represent all federal agencies. The negotiators' role is to determine if ASU has accurately identified its F&A costs and allocated these costs in accordance with the prescribed methods. There are usually some differences in the interpretation of the rate proposal processes which lead to compromises between federal negotiators and university officials in arriving at a final rate agreement. Once this negotiation is concluded, the F&A rate agreement is signed by both DHHS and ASU. Federal negotiators prefer to negotiate rate agreements for multiple years. This type of negotiated rate settlement provides a greater degree of assurance for both the government and university as to the general level of future F&A funding that can be
estimated for budgeting purposes.
7. Why do F&A cost rates vary so much from one university to another?
There is no single answer to this question. Instead, the principal differences result from the following factors:
Administrative costs are the most difficult to quantify and, consequently, they are the most criticized and questioned F&A costs. They are not, however, a major contributing factor to differences in F&A rates among universities. The Federal government has capped the amount of administrative cost recovery at 26% by revising OMB Circular A-21 language several times in recent years, even though the regulatory burden and related administrative costs to universities continues to increase.
8. Does ASU receive full reimbursement for its F&A costs?
No.
Most universities calculate an F&A cost rate greater than the final negotiated F&A cost rate. ASU has historically accepted some reduction of its calculated rate in the interest of reaching a prompt agreement with federal negotiators.
Additionally, many federal programs either do not provide F&A funds (such as conference grants) or limit the F&A reimbursement to a prescribed rate that is less than the negotiated rate (such as training grants). Most non-corporate private sponsors also have policies limiting F&A reimbursement to a prescribed rate.
Universities are also asked to cost share both direct and F&A costs under many sponsored agreements as a way to show their commitment to a project.
9. How are ASU's F&A fund recoveries utilized?
It is important to note the term "recoveries" in this context refers to recapturing F&A costs that have already been incurred, not those to be incurred in the future. Nonetheless, ASU has established policies to return a portion of the F&A cost recoveries to the faculty, department, and college in which the funded sponsored project activity occurs.
A portion of the F&A recoveries is reserved for the support of various research initiatives under the auspices of the Office of the Vice President for Research & Economic Affairs. In addition, there are some significant annual allocations of funds as well as a number of special funding requests for new initiatives, sponsored project matching, bridging funds and emergencies that are approved by OVPREA to support and enhance the research enterprise and support the research activity that benefits a large segment of the University research community.
Examples of F&A cost recoveries being returned directly to the campus include: 1) distributing a percentage of the total F&A costs budgeted in awards received to investigator incentive accounts and, 2) returning a percentage of the total F&A costs recovered, by college and department, each year to the Deans for reallocation.
10. How do I request approval to use a lower Facilities and Administrative (F&A) rate on my sponsored Project?
All sponsored projects are required to use the full F&A rate. However, some exceptions may be made. Refer to the Waiving F&A Costs procedure.
11. What is the downside (for me) of F&A waivers?
When a waiver is approved, there will be no Research Incentive Distribution (RID) for that project. For sponsored projects with federally mandated reduced rate, the RID will be proportionately reduced. See related article.
Program Income
1. What is program income?
Program Income is revenue received by ASU directly generated or earned as a result of a sponsored project. Some examples are charging a fee at a sponsored conference or selling items fabricated under an award.
2. How does program income affect the project budget?
Unless the sponsor specifically instructs differently, program income generated by research projects increases the project's budget (additive method) and program income generated by non-research projects lowers the portion of the budget funded by the sponsor (deductive method).
3. What can I spend program income on?
Treat program income just like it was received directly from the sponsor. Follow all the rules and regulations for money received directly from the sponsor. The only time ASU may treat it differently is when the sponsor gives us permission in writing to spend the program income on something you couldn't normally spend sponsor money on.
4. What happens when I have program income remaining at the end of the project's period of performance?
In a cost reimbursable project, which is the majority of projects, it is returned to the sponsor as unspent funds. To help prevent the need to return funds spend the program income first.
5. How is program income accounted for in Advantage?
A sponsored project program income account is created. The program income revenue is deposited into this account. The program income budget is set to equal the program income revenue generated by the project. In non-research projects (deductive method) where the program income reduces the funding from the sponsor, the sponsor's account budget is reduced by the amount of program income.
Space Survey
1. What is the space survey? Why do I have to participate?
The space survey records information about ASU's facilities and their usage. It is important to maintain accurate space records. ASU uses the information to:
For more information, visit the Space Survey website and FAQs. You can also contact .
Conflict of Interest
1. What is ASU's Objectivity in Research Policy?
The university expects every employee to be alert to potential financial conflicts of interest. Individuals may not, in their university roles, act in ways that would reasonably appear to give them (or their families or household members) privileged access to financial or other material benefits. In particular, academic appointees must inform their department chair (or equivalent), dean (or equivalent), and the Office for Research and Sponsored Projects Administration if they may have a potential conflict of interest.
2. Is this the only university policy related to conflict of interest?
No. The Objectivity in Research Policy (RSP 206) is not the only university policy applicable to financial and other interests of university faculty, researchers, and other employees. ASU employees must comply with all policies to the extent applicable. See, for example, the ACD 204-08: Conflict of Interest Policy.
3. What is a conflict of interest?
The term "conflict of interest" refers to situations in which financial interest or other personal consideration may significantly affect or have the reasonable appearance of affecting an investigator's professional objectivity in the performance or management of research or other sponsored activity.
4. What is a financial interest?
"Financial interest" and "financial benefit" mean the receipt or expectation of anything of monetary value, including salary or other payments for services (e.g., consulting fees or honoraria), equity or other ownership interests, and intellectual property rights (e.g., patents, copyrights, and royalties from such rights).
The terms do not include salary, royalties, or other remuneration paid by the university directly to an employee of Arizona State University; income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities; income from service on review panels or advisory committees for public or nonprofit entities; income from writing or editing professional journals or textbooks; or a financial interest in a commercial entity if the value of such financial interest, when aggregated with the interests of your family, does not exceed 3% ownership interest in such a commercial entity. ("Using the services of ASU students or employees" does not include infrequent or incidental use of students or employees in connection with your reportable outside activities.)
5. How do I determine if a financial interest requires reporting?
If the publication or presentation of the results of your research or sponsored project could be viewed by a scientific or lay audience (public officials, news reporters, or lay consumers of scientific information) as having an impact on the value of the company stock or products sold by the company with which you have a financial or other interest, the arrangements should be reviewed by the internal committee. This is particularly important, since even the appearance of a conflict of interest is significant. The internal review committee may determine that the relationship between an investigator's financial interest and the sponsored project is so remote (or unreasonable to expect) that there is no need for action. However, that determination should be made by the disinterested reviewers and not by the potentially partial investigator.
6. How do I report a potential conflict of interest?
Complete and file an Annual Objectivity in Research Questionnaire to identify any significant financial interests, including those of your spouse and dependent children. If you have previously filed you should complete a new questionnaire as new potential conflicts arise. If the answer to any question is yes, complete the Investigator's Disclosure of Financial Interest Form I. This disclosure would include all known significant financial interests that could reasonably appear to influence the research or research results. Submit your form(s) to the ORPSA Compliance Office at mail code 3503.
7. Why do I need to include information on family members?
The federal and state regulations that govern objectivity in research require disclosure of financial interest including those of your spouse or domestic partner, dependent children, and any other family members living in your household.
8. Where/what is the Annual Objectivity in Research Questionnaire?
The Annual Objectivity in Research Questionnaire, also known the annual disclosure form, assists ORSPA in determining whether an investigator has any known financial interest that could reasonably appear to influence the research or research results. The form is located at http://researchadmin.asu.edu/forms/objectivity.doc.
9. Why do I need to fill out this form/questionnaire?
ORSPA must be able to monitor and report potential conflicts of interest to remain eligible for federal funding and to comply with U.S. Public Health Service and National Science Foundation regulations, state laws, and internal policies. Under these regulations ASU must identify and manage, reduce or eliminate financial interests related to research and other activities supported as a sponsored project. The monitoring procedures have been streamlined by requiring investigators to file only ONCE a year, rather than completing the 114A form for every submitted proposal.*
*Note: In addition to filing an annual disclosure, investigators are required to certify objectivity for each proposal submitted by completing the certification questions on the internal proposal routing form RSP 300.
10. Who will see the information on the annual disclosure and how is it kept confidential?
All forms related to certifications and annual disclosures are kept in the OVPREA, ORSPA Compliance Office. Only a select few employees in this office are allowed access to this information, which is considered confidential and is appropriately secured.
11.
Do all PIs and co-investigators need to complete the annual disclosure form and routing form certification?
Yes. All faculty members or other investigators who conduct research at the university using funding from any public or private source outside the university must complete the certification for each proposal and an annual disclosure form.
12. What do I do if I have no financial interests to report?
Fill out the Annual Objectivity in Research Questionnaire. If you have no activities or your interests are less than the amounts defined as "significant financial interests," you should respond accordingly to the questions. Submit the questionnaire to the ORSPA Compliance Office, mail code 3503, and you're all finished until the following year! In the interim, if you have any changes in status or new potential conflicts to report, you are required to fill out a new questionnaire prior to the next reporting period.
13. When do I need to submit the form?
The pilot process now in implementation began on November 1, 2003 for FY 04. If you have not submitted an annual disclosure for FY 04, you should do so now. The questionnaire is required annually for each year and/or prior to the submission of proposals that year. Investigators will be notified in advance of the annual due date.
14. Do I have to report changes in my activity and/or interests before the next annual submission date?
If there is a change in your financial interests, you must fill out a new questionnaire. If you answer yes to any of the questions, you must complete the Investigator's Disclosure of Financial Interest Form I and mail it to the ORSPA Compliance Office at mail code 3503.
15. Do students need to complete the form?
If students are considered co-investigators on the project and are listed on the Proposal Routing and Approval Form, or the PI determines that they are independently responsible for the design, conduct or reporting of the research and outcomes then they are required to complete the proposal certification and the annual disclosure questionnaire.
16. Do subcontractors/consultants need to complete the form?
No. The ASU annual disclosure questionnaire is required only of ASU investigators. The disclosure process would identify any relationship the investigator may have with proposed subcontractors/consultants. The requirement for objectivity disclosure of our subcontractors would be provided as a term in our subcontract document separate form our institutional monitoring of objectivity in research.
17. Do I need to complete ALL of the conflict of interest forms?
If the answer to all questions on the Annual Objectivity in Research Questionnaire is "no," then you only need to complete that form. If any of the answers is "yes," then you will need to fill out and submit the Investigator's Disclosure of Financial Interest Form I to the ORSPA Compliance Office at mail code 3503. If a possible conflict is identified, you will be asked to complete an additional form.
18. What happens if I do have a conflict of interest?
If a conflict is identified, the circumstances will be reviewed by the Director of ORSPA and the Compliance Manager, who will determine if the situation needs to be review by the Intellectual Property Committee and/or the Office of the Vice President for Research and Economic Affairs. The investigator will be invited to participate in the internal review process and will be kept apprised of the committee's recommendations and final determination. Failure to comply with this policy or restrictions imposed under this policy will be grounds for discipline under other ASU policies and procedures pertinent to such actions and circumstances.
19. Can an investigator appeal a determination made by the review committee?
If an investigator disagrees with the committee's recommendations, s(he) may submit an appeal to the Associate Vice President for Research.
20. What will happen if I do not complete the annual questionnaire or the individual proposal certification?
An award can not be accepted and set up in the university financial system until the required conflict of interest forms have been received and reviewed. Any incoming award for which objectivity is not disclosed will be held until the necessary forms are completed processed.
21. What will happen if I fail to report or disclose a conflict of interest?
If an unreported significant financial interest of an investigator biases the design, conduct, or reporting of the research, ASU will promptly notify the sponsor and describe the corrective actions taken, or to be taken, in accordance with applicable law or policy. Note: the sponsor may provide further directions to ensure objectivity in the research.
22. Who do I call for more information?
Call your Sponsored Projects Officer or ORSPA's Compliance Office at 965-2179.