Inside Linfield - External Faculty Grants

VII. Awards from federal agencies

Much of the information in this section comes from 2 CFR §200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards published by the U.S. Government Publishing Office. 

Award payment

For federal grants, including subgrants through other institutions, payment is normally made on a billed basis and handled through the Accounting Office.

Budget development

Budgets for proposals to government agencies should be developed in accordance with the federal regulation as outlined in 2 CFR  §200.

Direct costs

Equipment and supplies – According to the federal government, equipment is any item needed to carry out your project that costs more than $5,000. Anything per unit cost that is less than $5,000 should be included under supplies (e.g., computers). Please note that equipment purchased should be American made “where practical” and anything costing more than $100,000 must be purchased using a competitive bidding process.

Participant support costs – Federal regulations prohibit diversion of these costs (e.g., student stipends, travel, tuition) to other categories and the costs must be tracked separately.

Travel – Use federally-determined domestic and international rates in estimating travel costs.

Subcontracts – Federal agencies require that both the contractor and subcontractor adhere to Office of Management and Budget requisites regarding accounting and audit procedures. It is the responsibility of the faculty members to obtain assurance from the subcontractor that compliance with federal regulations will be maintained. Failure to do so makes the primary contractor liable. Subcontracts on federal grants may not be issued to any person or entity appearing on the U.S. Government Excluded Parties List System.

Indirect costs

Negotiated indirect cost rate – Per university policy, a 37 percent federal negotiated indirect cost rate applies to all grant application budgets unless the funder indicates a lesser rate must be used or that the organization does not fund indirect costs.

Cost sharing

Federal agencies may require the institution to demonstrate its participation through the contribution of a portion of the funds required for the overall project. Potential cost-share items include faculty salary, related fringe benefits, the difference between the university's negotiated indirect cost rate and the cost rate allowed by the funder, and other non-federal grant support. General supply and expense items should not be included. UC Berkeley provides an excellent guide to cost sharing, no cost sharing (as required by NSF) and the language to use for this in the budget narrative.

Unallowable costs

The following costs, per CFR 200, are not allowable:

  • Alcoholic beverages
  • Alumni activities
  • Bad debt
  • Commencement and convocation cost
  • Contingency provisions
  • Costs of criminal and civil proceedings
  • Donations and contributions
  • Entertainment costs (except when they have a programmatic purpose)
  • Fines and penalties (failure to comply with federal, state or local laws & regulations)
  • Fundraising and investment costs
  • Goods or services for personal use of university employees
  • Housing and personal living expenses
  • Interest
  • Lobbying
  • Meals other than budgeted travel costs/conferences/participant support costs
  • Student activities (unless specifically provided for in the sponsored agreement)
  • Travel – Airfare costs in excess of the customary standard commercial airfare (coach or equivalent) are not allowed except under very specific conditions such as the medical needs of the traveler. These conditions must be documented.

Compensation

Any faculty member receiving compensation from a federal grant must record their work on time and effort report forms. The effort shown is not based on a 40-hour work week nor on FTE. Effort is an employee's total activity within her or his university appointment. For faculty, this includes all research, teaching and administrative duties. However, it excludes any income obtained outside one's duties at Linfield. Effort is expressed in percentages and must total 100 percent.

Contracted services

The procurement of contracted services must follow federal guidelines, which are outlined in the document: Linfield Federal Procurement Procedures. Please note that services costing more than $100,000 must be purchased using a competitive bidding process.

Data management plan

A proposal to apply for funding from the National Science Foundation must include a two-page Data Management Plan describing faculty plans for managing data and sharing the products of research. Guidance for developing a plan is available through the NSF Frequently Asked Questions resource and the Linfield external faculty grants website.

Deadlines

New methods of online submission for most federal funding requests are sometimes difficult and time-consuming, and some requests are rejected for minor infractions and must be resubmitted. For this reason, anyone expecting to submit a proposal online should begin the process at least a week in advance to allow for errors, electronic issues, and general delays that are common with this system. 

Expenditure of funds

Charges must meet the requirements of Office of Management and Budget CFR 200 regulations, WHICH MEANS ALL EXPENDITURES MUST BE SIGNED OFF BY ANOTHER PERSON AT THE UNIVERSITY. No payment may be made to a vendor or individual included in the U.S. Government’s Excluded Parties List System.

Equipment purchase

The procurement of equipment must follow federal guidelines, which are outlined in the document: Linfield Federal Procurement Procedures. Please note that equipment purchased should be American made “where practical” and anything costing more than $100,000 must be purchased using a competitive bidding process. The selection of any computer or video equipment should be reviewed by Information Technology Services before purchased. All equipment and supplies purchased through grants funds are the property of Linfield University.

Excluded parties list system

Any persons, business or organizations receiving federal funds through Linfield University must not be listed as excluded from payment on the federal government's Excluded Parties List System.

Financial conflict of interest

Per university policy, in compliance with federal regulations, any faculty member holding a federal grant must complete a Financial Conflict of Interest (FCOI) form should that person determine that a potential conflict of interest has occurred. A conflict of interest is a convergence of an individual's private interests and his or her professional obligations to Linfield such that an independent observer might reasonably question whether the individual's professional actions or decisions are determined by considerations of personal gain, financial or otherwise. For the National Science Foundation and National Institutes of Health, FCOI forms must be submitted for review prior to submitting an application. Applicants to the National Institutes of Health must receive FCOI training, per agency rules.

No-cost extension grant

In the event of a no-cost extension, it is the responsibility of the faculty member to inform Human Resources when employees charged against the grant are to be paid past the initial termination date. In addition, for continuation grants, the faculty member must submit new Temporary Employment Hire forms for all personnel and dates of employment to be charged to the new grant year. This should be done prior to the starting date of the continuation so that salaries can be properly applied against the correct budget number.

Rebudgeting

Certain federal agencies have provided expanded authority to the recipient institution to change a budget without receiving prior approval. This includes the reallocation of budget line items, pre-award setup costs limited to 90 days prior to the start date of the award, and a one-time-only no-cost extension for up to one year. Prior approval from the granting agency is required for the changes in 1) scope of work, 2) senior project personnel, 3) subcontracts (excepting supplies, materials, and equipment), 4) building construction, and 5) cost sharing.

Research misconduct

All federal agencies under the umbrella of the U.S. Public Health Service including the National Institutes of Health require applicant institutions to have a policy and set of procedures to deal with research misconduct. In compliance with this regulation, Linfield has developed a Research Misconduct Policy pertaining to all employees of the institution.

Responsible conduct in research

The National Science Foundation requires Responsible Conduct in Research training by specified individuals including student researchers. The required RCR Training must be completed, and a copy of the certificate of completion should be attached to the Personnel Action Form requesting payment. In compliance with this regulation, Linfield has developed a Responsible Conduct in Research Policy.

Sexual harassment

The National Science Foundation has a no-tolerance policy for sexual harassment, other forms of harassment, and sexual assault, within the agency, at awardee organizations, field sites or anywhere science or education is conducted. As such, this agency now requires that Linfield report any findings/determinations of sexual harassment or administrative actions due to allegations of sexual harassment by any principal investigator or co-principal investigator to that agency, which is detailed in our Sexual Harassment Policy for the NSF

Subcontracts

If you received a federal grant, all subcontractors must state in writing that they will abide by the federal regulations governing grants. The Grant Administrator will draw up a subcontract agreement, which must be signed by an authorized representative of the subcontracting entity. Subcontractors should submit bills to the faculty member who then routes the statements to Accounting. Subcontracts may not be issued to anyone or any organization on the U. S. Government's Excluded Parties List System.

Technical and financial reports

The faculty member is responsible for the timely submission of all technical reports, in accordance with the terms of the grant agreement. The Accounting Office is responsible for all financial reports, in accordance with the terms of the grant agreement. Unless otherwise specified in the agreement terms, final reports are normally due within three months of the termination of the grant.

Travel regulations

U.S.-flag carriers must be used for U.S. government-financed commercial foreign air travel if service is available to be compliant with the Fly America Act.