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UCLA Policy 910:
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Management of Sponsored Projects |
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Issuing Officer:
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Vice Chancellor - Research |
View/Print
Document |
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Responsible Dept:
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Office of Research Administration |
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Effective Date:
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July 1, 2002 |
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Supersedes:
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UCLA Policy 910, dated 11/1/99 |
[References]
[Definitions] [Background]
[Statement] [Responsibilities]
I.
REFERENCES
- University
of California Contract and Grant Manual, Chapters 2 and 10;
- UCLA Policy 900 - Principal
Investigator Eligibility;
- UCLA
Delegation of Authority 250.05 - To Solicit and Accept or
Execute Certain Extramural Grants and Contracts;
-
Office of Management and Budget Circular No. A-110, Uniform
Administrative Requirements for Grants and Agreements with Institutions
of Higher Education, Hospitals, and Other Non-Profit Organizations;
-
Office of Management and Budget Circular No. A-21, Cost Principles
for Educational Institutions;
- UCLA
Office of Contract and Grant Administration Web site.
II.
DEFINITIONS
Award: Financial
or other support for a specific project being conducted under a
Contract, Grant or Cooperative Agreement or gift.
Contract: A
written agreement under which the University conducts research,
training, public service or other services. Specific obligations
are generally imposed on all parties to the Contract and milestones
and/or deliverables are often required.
Cooperative Agreement:
A version of a Grant in which the sponsor participates in the project
along with University personnel.
Grant: A written
agreement under which the University conducts research, training,
public service or other services. Deliverables other than technical
or financial reports are generally not required.
Principal Investigator
(PI): A UCLA employee (normally an academic appointee) who
has primary responsibility for the scientific and technical conduct,
reporting, fiscal and programmatic administration of a Sponsored
Project.
Sponsored Project:
A specific research, training, public service project or other program
that receives support from external sponsors and/or University programs
under a Contract, Grant, Cooperative Agreement or Subaward. Support
may be in the form of funding, equipment or other material contributions.
Subaward: Agreement
that transfers to another organization a portion of the substantive
work being conducted under a Contract, Grant or Cooperative Agreement.
III.
BACKGROUND
This policy
describes the shared responsibility for the administration of Awards
accepted as Contracts, Grants, Cooperative Agreements or Subawards
at UCLA. Through designated officials with delegated authority,
UCLA solicits and accepts Awards on behalf of The Regents of the
University of California from a variety of organizations for organized
research, instruction and training, and other sponsored activities
(i.e., public service, community service, health service projects,
etc.). Federal, state and local governments, industrial and commercial
concerns, institutions of higher education, private foundations
and other non-profit organizations, provide extramural funding.
In addition, the University of California also issues Awards through
a variety of funding programs.
Awards take
on the appearance of Contract, Grants or Cooperative Agreements
when they include requirements such as a specified period of performance
or a specific scope of work to be followed or other conditions or
obligations required of the University to fulfill the terms of the
Award. Awards without restrictions generally constitute gifts.
IV. STATEMENT
With the submission of proposals and the acceptance of Awards, UCLA
agrees to provide technical or scientific expertise, and to manage
each Sponsored Project in compliance with various fiscal and administrative
regulations. Specific individuals and select administrative support
units share responsibility for managing Sponsored Projects.
- Principal Investigators are responsible for the proposal preparation,
acquisition of appropriate approvals (i.e., human subject, animal
subject, use of biohazardous materials, etc.) and licenses, scientific
and technical conduct and reporting, fiscal and programmatic management
of the project, which includes responsibility for any applicable
Subawards.
- Deans, department chairs
and Organized Research Unit (ORU) directors share primary responsibility
for the management of Sponsored Projects in their respective units,
along with various components of the Office of Research Administration
(ORA).
- The Vice Chancellor -
Research has general oversight responsibility for policy related
matters associated with Sponsored Projects. He or she is also
responsible for coordinating compliance with federal and other
research regulations in areas such as the protection of human
and animal research subjects, scientific integrity, conflict of
interest, and environment, health and safety.
- A number of other units,
including Audit and Advisory Services, the Controller's Office,
and other departments within Corporate Financial Services, the
Office of Insurance and Risk Management, Purchasing, Equipment
Management, and the Office for the Protection of Research Subjects,
have expertise in varied subject areas and provide a wide spectrum
of support services related to the administration of Sponsored
Projects.
V.
RESPONSIBILITIES
Principal Investigator
It
is reasonable and appropriate for the Principal Investigator (PI)
to rely on administrative staff for assistance in carrying out responsibilities
under a Sponsored Project. However, it is expected that the PI will:
- Be
knowledgeable about appropriate agency and University guidelines
and restrictions relative to the budgeting of both direct and
indirect costs, proposal preparation, the conduct of organized
research, instruction and training, and other sponsored activities,
and be willing to comply with such guidelines and restrictions;
- Secure
appropriate federal and campus approvals such as New Drug Applications
(NDA), Investigational Device Exceptions (IDE), human and animal
subject approvals and approval to use biohazardous materials and/or
recombinant DNA;
- Comply
with the specific terms and conditions of each Award as stated
in the Contract, Grant, Cooperative Agreement or Subaward documents
and with all administrative requirements, as set forth by the
federal government, sponsoring agency and campus policy statements,
as applicable;
- Adhere
to specific budget restrictions, ensuring that activities do not
begin and expenditures are not incurred prior to the receipt of
a fully executed Award unless necessary and authorized advanced
approvals have been obtained, and that expenditures do not exceed
the total amount of funds obligated;
- Certify
that all costs charged to a Sponsored Project are accurate and
specifically benefit the project being charged including the certification
of salaries charged to federal Awards using the Personal Activity
Reporting (PAR) system forms;
-
Provide justification and documentation of costs being transferred,
if after-the-fact adjustments in the allocation of certified costs
become necessary;
- Comply
with the reporting requirements as stated in the Contract, Grant,
Cooperative Agreement or Subaward documents, including the submission
of periodic and final programmatic reports, financial reports,
invention reports and inventory and equipment reports; and
- Ensure that any subrecipients comply with the terms and conditions
of each Award as stated in the Subaward documents and with all
administrative requirements, as set forth by the federal government
and sponsoring agency, as appropriate.
Department Chair or Organized Research Unit (ORU) Director
Department chairs and ORU directors are responsible for reviewing
proposals developed by faculty, in particular to:
- Ensure the proposed project is consistent with the educational
and professional objectives of the school or college;
- Determine the eligibility of the individual designated as Principal
Investigator (PI) or Co-Principal Investigator in accordance with
UCLA Policy 900, Principal Investigator Eligibility;
- Ensure the appropriateness of the effort committed to the project
made by UCLA faculty, staff and students;
- Ensure that appropriate on-campus or off-campus space has been
identified and is available for the project;
- Confirm that support will be provided for the administration
of the project;
- Determine that cost sharing and/or matching fund commitments
set forth in the proposal can be met; and
- Ensure that where appropriate, equipment-screening procedures
have been followed.
Once an Award has been made, the department chair or ORU director
has continuing responsibility to ensure that administrative staff:
- Reallocate appropriated funds into the appropriate budget categories;
- Review and approve financial transactions related to personnel,
the purchase of equipment, rebudgeting of funds, or the retention
of consultants for consistency with project purposes and the terms
and conditions of the Award;
- Maintain budgetary control through the use of departmental
bookkeeping and cost control systems and monthly reconciliation
with the general ledger;
- Provide the PI with accurate and timely information about expenditures;
confer with the PI in order to make adjustments as may be necessary
to ensure that the general ledger is cleared of any expenses not
applicable to the Sponsored Project. Such adjustments may include
transferring outstanding liens, transferring items of expense
not allowable under that particular Award, and transferring overdrafts
to other permissible fund sources;
- Identify appropriate unrestricted fund sources at the departmental
level to cover cost-sharing commitments, overdrafts and/or disallowances
that PIs are not able to cover with funds under their jurisdiction;
ensure that equipment purchased or acquired under Contracts, Grants,
Cooperative Agreements or Subawards are accounted for and/or disposed
of in accordance with sponsor and University requirements.
The Office of Extramural Fund Management (EFM) is responsible for
the preparation and submission of reports of expenditures. However,
the department chair or ORU director is responsible for ensuring
that all financial transactions are properly recorded in a timely
manner so that the reports of expenditures can be submitted promptly
to sponsors.
Deans
Deans are accountable for all Contract, Grant, Cooperative Agreement
and Subaward funds administered by units under their control, and
for the coordination of all programmatic elements within their school
or college including:
- Review of all proposals to ensure that the proposed project
is consistent with the educational and professional objectives
of the school or college;
- Review and approval of requests for PI exceptions;
- Approval of cost-sharing and/or matching fund commitments contained
in proposals; and
- Identification of appropriate unrestricted fund sources to
cover overdrafts and/or disallowances that department chairs within
the school or college have not been able to cover with funds under
their jurisdiction.
Office of Research Administration - Office of Contract &
Grant Administration (OCGA)
As campus officials with delegated authority to submit proposals
and accept Awards, OCGA staff:
- Review, approve, and submit all proposals for organized research,
instruction and training, and other sponsored activities to ensure
that projects are consistent with Regental and UCLA policy, agency
terms and conditions, and application guidelines;
- Negotiate, execute, and accept Awards that are consistent with
Regental and UCLA policy and which contain terms and conditions
that minimize administrative burden, and limit exposure to compliance
issues;
- Provide pre- and post-Award consultative service and support
to PIs and department staff;
- Interpret Award terms and conditions and inform PIs, departmental
staff and appropriate campus personnel of the requirements and
obligations imposed by the sponsor's Award;
- Review and approve certain post-Award transactions for consistency
with Award terms and conditions; and
- Serve as liaison with sponsors, maintain the University's official
file of record, participate in agency site visits and audits,
and assist in closeout activities.
Office of Research Administration - Extramural Fund Management
(EFM)
EFM staff are responsible for financial management of extramurally
supported Contracts, Grants, Cooperative Agreements and Subawards.
EFM staff:
- Set up extramural Awards in the financial system by assigning
fund numbers, linking expenditure accounts to funds and appropriating
funds;
- Review and certify expenditures for extramurally funded projects
for consistency with sponsor and University policies and Award
terms and conditions;
- Conduct post-audit reviews of selected transfers of payroll
and non-payroll expenditures for conformance to agency and University
policies and procedures;
- Prepare and submit invoices and financial reports of expenditures;
- Obtain adequate and timely reimbursement for Award expenditures
from sponsoring agencies;
- Generate Personal Activity Reporting (PAR) system forms, reviewing
signed and completed forms and/or providing assistance to campus
departments in completing forms as required under federal regulations;
- Close out funds, transferring overdrafts and unallowable expenditures
or adjusting the budget to clear out unexpended balances after
conferring with the PI and departmental/ORU administrative staff;
- Provide assistance to departments that may be experiencing
difficulties in the management of Contract, Grant, Cooperative
Agreement or Subaward funds; and
- Work with Audit and Advisory Services to respond to sponsor
audit requests.
Corporate Financial Services - General Accounting
Staff of General Accounting are involved in some aspects of managing
funds transferred to UCLA investigators from the UC Office of the
President to support Sponsored Projects funded under the University
of California (UC) program. The staff:
- Set up UC Awards in the financial system by assigning account
numbers, linking expenditure accounts to funds specified by the
UC program and appropriating funds;
- Prepare and submit claims to the State Controller's Office for
the State-related funds;
- Prepare and submit financial reports as required;
- Close out funds, transferring overdrafts and unallowable expenditures
or adjusting the budget to clear out unexpended balances after
conferring with the PI and departmental/ORU administrative staff;
- Provide assistance to departments that may be experiencing difficulties
in the management of Contract, Grant, Cooperative Agreement or
Subaward funds; and
- Work with Audit and Advisory Services to respond to sponsor
audit requests.
Office of Research Administration - Office of Intellectual
Property Administration (OIPA)
The OIPA staff:
- Provide advice and counsel to faculty, staff and students regarding
their obligations under the University Patent and Copyright policies;
- Review all new inventions disclosed to the University to determine
their commercial value, ownership, and any potential obligations
to research sponsors and providers of research materials;
- Engage patent attorneys and legal counsel to file appropriate
intellectual property protections (i.e., patents, copyrights,
trade secrets and trademarks);
- Market inventions to industrial entities capable of furthering
the commercialization of inventions;
- Assist entrepreneurs, investors and management teams to form
and launch new start-up companies to further the development and
commercialization of early-stage emerging technologies;
- Negotiate, execute and monitor all licenses of University-owned
intellectual property to third parties;
- Manage all legal expenses related to intellectual property protection
and distribute income to inventors and organizational units qualified
to receive a share of net revenues;
- Negotiate, execute and monitor all incoming material transfer
agreements; and
- Ensure that federal, State and private sponsor requirements
regarding invention reporting are met.
| Issuing
Officer |
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/s/ Roberto Peccei |
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Vice Chancellor - Research
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