Gettysburg College grant compliance policies have been developed based upon the standards in the Federal Uniform Guidance, research terms and conditions, and the College’s internal Ethics and Integrity Program and Statement of Ethical Behavior.
To ensure compliance with the highest humane, ethical, scientific and legal standards, all Gettysburg College faculty members undertaking research on any vertebrate animal must follow the policies outlined by the College’s Institutional Animal Care and Use Committee.
For any federally sponsored research, the College is obligated by federal regulations to promptly report (within two months) to the appropriate federal agency any inventions conceived or reduced to practice during the course of a government-sponsored research program. The Bayh-Dole Act permits a university, small business, or non-profit institution to elect to pursue ownership of an invention in preference to the government. Intellectual Property Policy
This federal regulation, passed in the 1930s to protect American workers and reinforced by the Federal Acquisition Regulations, applies to certain federal contracts and grants above the micro-purchase threshold of $3,000 and includes flow down to subrecipients. Awardees must certify that all articles, materials, and supplies funded by these awards are American-made. Exceptions can be made in the case of:
- unreasonable cost
- unacceptable quantity or quality
- use outside the U.S. only
- conflict with the public interest
- certain trade agreements
- commercial items of information technology
- domestic manufactured products (e.g., engines), if at least 50% of components are U.S. made
Exceptions to the act must be identified in the project specifications and justified in the documents retained with procurement records relating to small purchases. False certification may be considered fraud and can result in debarment. The government also publicizes information about noncompliant awardees, who may not participate in federally funded projects for three years from the date that they are found noncompliant. This act is not the same thing as the Buy America Act of 1983, which applies only to procurement for mass-transit projects.
Though it is unlikely that Gettysburg investigators have any financial conflict of interest, the federal government requires the College to annually document this information. Please see our Conflict of Interest Policy and fill-out the Conflict of Interest Disclosure Form.
With respect to U.S. Public Health Service (PHS) funded projects and research carried out by Gettysburg Investigators, Gettysburg College complies with additional PHS requirements, and other federal agency disclosure and financial COI regulations, as applicable, in order to maintain institutional compliance and eligibility for the application of and receipt of PHS funding, including grants, subawards and cooperative agreements. In order to submit a PHS proposal (i.e. NIH, DHHS), please review the PHS Requirements for Financial Disclosures and Conflict of Interest Policy and complete the Financial Disclosure Form for All Senior Personnel. This should be submitted with the Proposal Processing Form.
Debarment and Suspension certification is designed to prevent fraudulent or improper use of government funds, applies to all grants and cooperative agreements and to most contracts. Applicants must certify that they, their principals, and their researchers:
- aren’t debarred, suspended, ineligible for, or excluded from funding by any federal entity
- haven’t been convicted of fraud or a criminal offense in connection with federal agreements within the past three years
- haven’t been convicted of violating federal statutes within the past three years
- haven’t been convicted of committing any form of theft or fraud within the past three years
- haven’t been charged with any of these crimes by any government entity
- haven’t had any government agreements terminated for cause or default within the past three years
False certification could result in termination of the grant and debarment, suspension, or both.
Cost must meet the following general criteria in order to be allowable under Federal awards:
- Be necessary and reasonable for the performance of the Federal award.
- Conform to any limitations or exclusions set forth herein or by the Federal awarding agency.
- Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the College.
- Not be included as a cost or used to meet cost sharing or matching requirements of any other federally- financed program in either the current or a prior period.
Categories of Direct Costs
The Federal government generally supplies the recipient of a Federal grant or contract with the funds necessary to cover the expenditures directly associated with a project; these categories of costs are described as allowable costs. There are other expenditures, however, that the Federal government deems inappropriate and will not reimburse; these categories of costs are described as unallowable costs (example: alcoholic beverages). Furthermore, there are certain categories of costs that are allowable only when pre-approved by the Federal awarding agency.
Attached is a listing of the direct costs categories and their respective classification as allowable, unallowable and allowable with pre-approval.
All expense reimbursement and Pcard payment requests must be accompanied by the correlating itemized receipt of the purchase. In the case of meals and restaurant expenses, the receipt included with the payment request must be itemized and include the names of those in attendance.
In compliance with the Federal Drug-Free Schools and Communities Act, it is the policy of Gettysburg College to provide an environment that is free from the use, sale, possession, or distribution of illegal drugs or the improper or abusive use of legal drugs or alcohol on Gettysburg College premises.See: Drug-Free Workplace and Drug-Free Campus
It is the policy of Gettysburg College not to discriminate improperly against any matriculated student, employee or prospective employee on account of race, color, religion, ethnic or national origin, age, gender, sexual orientation, veteran status disability, or any other protected classification. Such policy is in compliance with the requirements of Title VII of the Civil Rights Act of 1964, Title IX of the Education amendments of 1972, the Rehabilitation Act of 1973, and all other applicable federal, state, and local statues, ordinances, and regulations. See: Employee Handbook Section Two: EEO
Export controls are the United States laws and regulations that regulate and restrict the release of critical technologies, technical data, software code, equipment, chemical and biological materials and other materials, and information and services to foreign nationals and foreign countries for reasons of foreign policy and national security. Export control regulations, as well as boycott programs, have the potential to impact many aspects of the freedoms typically associated with research in a university setting, including publication rights, international collaboration, sending or bringing equipment to foreign countries (including laptops and cell phones), and the sharing of research technology (verbally, in writing or visually) with persons who are not U.S. citizens or permanent residents. Most of Gettysburg College’s activities and travel to foreign countries are either not affected by export control laws, or they are subject to an exemption. Fundamental research—basic and applied research in science and engineering, the results of which are published and shared broadly within the scientific community—generally is not subject to export controls and trade sanctions. Proprietary research and industrial development are more likely to be. Projects that involve engagement with sanctioned countries or entities also may be subject to restrictions. If you have questions or think that your research may apply, please contact the College Grants Office.
Generally, if a traveler is traveling on funds provided by the federal government, he/she must use a U.S. flag carrier (an airline owned by an American company), regardless of cost or convenience. If you are scheduling international travel that is federally funded, you must ensure that all flights, where possible, are scheduled on U.S. flag carriers or on foreign air carriers that code share with a U.S. flag carrier. Code sharing occurs when two or more airlines “code” the same flight as if it was their own. In other words, a U.S. airline may sell a seat on the plane of a foreign air carrier; this seat is considered the same as one on a plane operated by a U.S. flag carrier. Compliance with the Fly America Act is satisfied when the U.S. flag air carrier's designator code is present in the area next to the flight numbers on the airline ticket, boarding pass, or on the documentation for an electronic ticket (passenger receipt). For example, Delta has a code share agreement with Air France to Paris, France. If the boarding pass (flight coupon) or e-ticket identifies a flight as DL, the requirements of the Federal Travel Regulations would be met, even if the flight was on an Air France airplane. If however, the boarding pass (flight coupon) or e-ticket identifies the flight as an AF, then the requirements of the Federal Travel Regulations would not be met.
Exceptions to the Fly American Act
The biggest exception to the Fly America Act is the Open Skies Agreement. The United States Government has entered into several air transport agreements that allow federal funded transportation services for travel and cargo movements to use foreign air carriers under certain circumstances. See http://www.gsa.gov/portal/content/103191 for the current Open Skies Agreements.
What do these Open Skies Agreements mean to you?
- European Union: When traveling to a destination serviced by a European Union airline, College travelers flying on a Federal grant can fly on either a US carrier or a EU (European Union) carrier as long as they touch down in an EU country.
- Australia: College travelers using federal dollars can use an Australian airline only if a point of origin/destination is either the US or Australia and there is no city-pair contract flight between the two points (origin and destination).
- Switzerland: College travelers using federal dollars can use a Swiss airline only if a point of origin/destination is either the US or Switzerland and there is no city-pair contract flight between the two points (origin and destination).
- Japan: College travelers using federal dollars can use a Japanese airline only if a point of origin/destination is either the US or Japan and there is no city-pair contract flight between the two points (origin and destination).
Gettysburg College faculty and students are committed to advancing knowledge within their respective academic disciplines. In order to accomplish this goal most effectively, the college community believes that adherence to strict ethical norms is essential. Values such as honesty, respect for the rights and dignity of human beings, and the humane treatment of animals are not only important for living an ethical life but are among the values that underlie excellent research. However, ethical decisions may often be complex when weighing the common good with the integrity of the study and so the College has established the Institutional Review Board (IRB) to ensure that Gettysburg faculty and students have considered all relevant ethical issues when designing and conducting their research.
It is the policy of Gettysburg College to provide a safe and healthful environment, free from recognized hazards that may cause serious injury to students, employees, and visitors. This is accomplished by maintaining a comprehensive safety, health, and environmental program that involves all college employees. Gettysburg College will conduct all of its activities in compliance with applicable standards, codes, regulations, and laws. Every person at the institution understands that safety and health is not an additional job responsibility, but that it is an integral part of every task.See: Laboratory Safety
All faculty members in science areas funded by the National Institutes of Health (NIH) and the National Science Foundation (NSF) should be familiar with “Procedures for Dealing with and Reporting Possible Misconduct in Science” that the College adopted in April, 1990. These procedures cover cases of fabrication, falsification, plagiarism, and other serious deviation from accepted practices of proposing, carrying out, or reporting results for research. They also cover material failure to comply with federal requirements for protection of research, human subjects, or the public; for ensuring the welfare of laboratory animals; or failure to meet other material legal requirements governing research. A copy of the “Procedures” is available from the Provost’s Office.
Gettysburg College may only charge to the Federal award allowable costs incurred during the period of performance.
Purchase of Goods or Services with Federal Funding
Effective June 1, 2018
General Procurement Requirements
All procurement transactions must be in compliance with existing Gettysburg College procurement guidelines . In addition to the College policies, there are additional restrictions that must be followed relating to the expenditure of federally awarded funds. These additional restrictions and requirements are found under Procurement Standards of the Uniform Guidance sections 200.317 – 326. All purchases made with federal funding are subject to audit by federal awarding agencies.
Additional Requirements when Purchasing with Federal Funding
All procurement transactions must be conducted in a manner providing full and open competition consistent with the standards noted below. In order to ensure objective contractor performance and eliminate unfair competitive advantage, contractors that develop or draft specifications, requirements, statements of work, or invitations for bids or requests for proposals must be excluded from competing for such procurements. Some of the situations considered to be restrictive of competition include but are not limited to:
- Placing unreasonable requirements on firms in order for them to qualify to do business;
- Requiring unnecessary experience and excessive bonding;
- Noncompetitive pricing practices between firms or between affiliated companies;
- Noncompetitive contracts to consultants that are on retainer contracts;
- Organizational conflicts of interest;
- Specifying only a “brand name product instead of allowing “an equal” product to be offered;
- Any arbitrary action in the procurement process.
The College will conduct procurements in a manner that prohibits the use of statutorily or administratively imposed state and local preferences in the evaluation of bids or proposals, except in those cases where applicable Federal statutes expressly mandate or encourage geographic preference.
Methods of Procurement to be Followed (200.320)
The PI must use one of the following methods of procurement whenever purchasing goods or services with federal funding. The thresholds listed below are per the OMB issued memorandum M-18-18, “Implementing Statutory Changes to the Micro-Purchase and Simplified Acquisition Threshold for Financial Assistance” which was effective as of June 20, 2018.
- Micro Purchasing Method: Procurement by micro-purchase is the acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold of $10,000. To the extent practicable, the PI will distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive quotations if the PI considers the price to be reasonable.
- Small Purchase Method: Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies or other property that do not cost more than the defined Simplified Acquisition Threshold of $250,000. Price or rate quotations must be obtained from at least two suppliers. The PI is responsible for documenting suppliers reviewed, quotes received and reason for selection of supplier. Quotes can be obtained from suppliers or from public websites and included as backup documentation for the purchase. For purchases of $25,000 or more, the PI, before engaging a supplier, must search the System for Award Management (SAM) for the vendor by name, tax identification number, or another characteristic to make sure the person or entity hasn’t been suspended or debarred from performing federally funded work.
- Sole Source Method: Procurement by noncompetitive proposal is procurement through solicitation of a proposal from only one source and may be used only when one or more of the following circumstances apply:
- The item is available only from a single source;
- The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation;
- The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal entity;
- After solicitation of a number of sources, competition is determined inadequate.
- The Uniform Guidance recognizes that researchers need to acquire items from a sole/selected source for scientific/technical reasons (for example when a service or items is only available with the required quality from one source or only one source can provide the items or service in the time frame required). This “sole/selected source” option is available at all dollar amounts and the justification must be documented and maintained by the PI.
Instances when sole/selected source purchasing may be applicable would include, but not limited to, the following:
- The equipment, supplies and/or service provider are required by the funding agency (specifically named in an awarded grant or contract) and therefore deemed essential to the project. Please note: just naming a supplier in a proposal does not justify their use as a sole source supplier – justification still needs to be documented.
- Specific materials or supplies are required to maintain critical experimental continuity.
- Property and services can be obtained only from a specific supplier (i.e. real estate, utilities services, one of a kind items, etc).
- Competitive sourcing is precluded because of the existence of patents, copyrights, secret processes, control of raw materials by suppliers or similar circumstances that limit competition.
- Procurement of replacement or upgrade components for equipment manufactured by a specific original equipment manufacturer (OEM) if OEM parts are required in order to not void the warranty.
- Purchasing of support services in connection with the assembly, installation or servicing of equipment or software of a highly technical or specialized nature.
- Purchasing of compatible additions to existing equipment where a different manufacturer’s equipment would be impractical for the specific need.
- The project/work has a firm schedule requirement which only one supplier has the capability of meeting. Failure to meet the schedule requirement would seriously impact the project/work.
- Purchasing where only a single supplier in a relevant market is licensed or authorized to service or sell a specific product line and related services.
- Software / Subscription renewal or equipment services / maintenance agreement.
- Sealed Bids Method (formal advertising): Required for any construction projects greater than $250,000. Bids are publicly solicited and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming to all the material terms and conditions of the invitation for bids, is the lowest price. In order for sealed bidding to be feasible, the following conditions should be present:
- A complete, adequate and realistic specification or purchase description is available;
- Two or more responsible bidders are willing and able to compete effectively for the business; and
- The procurement lends itself to a firm fixed rice contract and the selection of the successful bidder can be made principally on the basis of price.
- If sealed bids are used, the following requirements apply:
- Bids must be solicited from an adequate number of known suppliers, providing them sufficient response time prior to the date set for opening the bids;
- The invitation for bids, which will include any specifications and pertinent attachments, must define the items or services in order for the bidder to properly respond;
- All bids will be opened at the time and place prescribed in the invitation for bids;
- A firm fixed price contract award will be made in writing to the lowest responsive and responsible bidder. Where specified in bidding documents, factors such as discounts, transportation cost, and life cycle costs must be considered in determining which bid is lowest. Payment discounts will only be used to determine the low bid when prior experience indicates that such discounts are usually taken advantage of; and
- e. Any or all bids may be rejected if there is a sound documented reason.
- Competitive Proposal Method: Required for any non-construction purchases greater than $250,000. Competitive selection is normally conducted with more than one source submitting an offer, and either a fixed price or cost-reimbursement type contract is awarded. It is generally used when conditions are not appropriate for the use of sealed bids. If this method is used, the following requirements apply:
- Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Any response to publicized requests for proposals must be considered to the maximum extent practical;
- Proposals must be solicited from an adequate number of qualified sources;
- The PI must have a written method for conducting technical evaluations of the proposals received and for selecting recipients;
- Contracts must be awarded to the responsible firm whose proposal is most advantageous to the program, with price and other factors considered; and
- The PI will use competitive proposal procedures for qualifications-based procurement of architectural/engineering (A/E) professional services whereby competitors’ qualifications are evaluated and the most qualified competitor is selected, subject to negotiation of fair and reasonable compensation.
The College is committed to providing a healthy and safe learning and research environment in accordance with guidance provided by the NIH. Should your research involve rDNA or other potentially hazardous biological matters, please indicate this when completing the Proposal Processing Form and then contact Darren Glass, Dean of Natural Sciences, Computer Science and Mathematics. Your research proposal will then be reviewed by the College’s Institutional Biosafety Committee.
Financial records, supporting documents, statistical records, and all other College records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. The only exceptions are the following:
- If any litigation, claim, or audit is started before the expiration of the 3-year period, the records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken.
- When the College is notified in writing by the Federal awarding agency, cognizant agency for audit, oversight agency for audit, cognizant agency for indirect costs, or pass-through entity to extend the retention period.
- Records for real property and equipment acquired with Federal funds must be retained for 3 years after final disposition.
- When records are transferred to or maintained by the Federal awarding agency or pass-through entity, the 3-year retention requirement is not applicable to the College.
Beginning in January 2010, many federal grantmaking agencies – including the National Science Foundation and the National Institute of Health – required grantees to certify that they provided appropriate training and oversight in the responsible and ethical conduct of research. Please see Gettysburg’s RCR Website for more details.
During the course of a sponsored project, unexpected circumstances may arise that may not have been previously anticipated. As a result, the PI/PD may need to request changes to his/her project. Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies when:
- Change in scope of the objective of the project or program
- Change in a key person
- Disengagement from the project for more than three months or a 25% reduction in time devoted
- The transfer of funds budgeted for participant support costs
- The subawarding or transferring out of any work no previously described
- Changes in the amount of cost-sharing or matching
Gettysburg College may only charge to the Federal award allowable costs incurred during the period of performance.
This law (Public Law 100.463, Section 8136) is intended to give the federal government public credit for federally funded programs and projects. It requires federal grant recipients to include funding information on all publications related to projects that use federal funds, including statements, press releases, signs at construction sites, requests for proposals, bid solicitations, and other documents that describe projects or programs funded in whole or in part with federal money. The information must state clearly the total cost of the program and the dollar amount of federal funds used.
This law applies to grants and cooperative agreements but not to contracts. It does not apply to subcontracts, but it may apply to subawards. Academic publications (peer-reviewed journals, presentations to professional groups) resulting from the project research are not required to include this information.
Although no sanctions are specified for noncompliance, failure to comply could be considered a breach of responsibilities and may result in termination, suspension, or debarment.
Gettysburg College is responsible for ensuring that all sub-award agreements it issues comply with federal regulations. Prior to a sub-award being issued the College must take certain steps to ensure the appropriate use of federal funds by the sub-recipient. Gettysburg College will use our sub-award agreement for compliance. Subrecipient Monitoring Policy Upon the execution of a subaward, the Principal Investigator / Project Director (“PI/PD”), with support from the College Grants Office and Finance, is responsible for monitoring the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.
Responsibilities of the Principal Investigator/Project Director
The PI/PD is responsible for tracking and monitoring progress of the subrecipient to ensure the efforts outlined in the scope of work are being met and reimbursements are being made in relation to programmatic progress. To this end, the PI/PD monitoring activities shall include:
- Providing subrecipients with guidance, technical assistance and training (if necessary) on program-related matters.
- Reviewing financial and programmatic reports as required in the sub-agreement, supplemented by informal communications with the subrecipient, to ensure progress on performance goals.
- If deemed necessary, perform on-site reviews of the subrecipient’s program operations.
- Approving all the subrecipient’s invoices for payment by Financial Services. In approving the invoice, the PI/PD is certifying the expenditure was incurred during the period of performance of the subaward, is for authorized activities of the subaward, and that progress towards performance goals are being achieved.
- Special attention should be given to budgeted purchases by the subrecipient in excess of $3,000. The subrecipient should be providing documentation substantiating it complied with the College’s price or rate quotation requirements.
- Notifying the College Grants Office of any instances of non-compliance with the terms and conditions of the subaward or failure to make progress with programmatic goals by the subrecipient.
Responsibilities of the College Grants OfficeThe College Grants Office will report all new federal subawards in excess of $25,000 to the Federal Funding Accountability and Transparency Act (FFATA) as required by federal guidelines. In February of each fiscal year, the College Grants Office will send an annual certification letter to all subrecipients currently receiving federal funding to ensure the subrecipient established and maintains effective internal controls over compliance with requirements of laws, regulations, contracts and grants applicable to Federal programs. In the event that any deficiencies in internal control over compliance are identified, the College Grants Office and Finance Offices will take steps necessary to follow up and ensure that the subrecipient is taking timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient.
Sub-recipients must include in their budget an approved, federally recognized indirect cost rate negotiated between the sub-recipient and the federal government. If no such rate exists, with a negotiated rate or a 10 percent de minimus rate should be used.
Termination of Awards to Subrecipients
The College may terminate a Federal award to a subrecipient in whole or part because the subrecipient fails to comply with the terms and conditions of a Federal award. Upon sending the subrecipient a written notification setting forth the reasons for such termination, the effective date, and in the case of partial termination, the portion to be terminated. The notification will also state that the termination decision may be considered in evaluating future applications received from the subrecipient. In accordance with requirements of the Federal awarding agency, the College must provide the subrecipient an opportunity to object and provide information and documentation challenging the termination.
In accordance with the Code of Federal Regulations (CFR), 2 CFR 200.216, Gettysburg College prohibits agreements for certain telecommunications and video surveillance services or equipment from the following companies as a substantial or essential component of any system or as critical technology as part of any system:
- Huawei Technologies Company;
- ZTE Corporation;
- Hytera Communications Corporation;
- Hangzhou Hikvision Digital Technology Company;
- Dahua Technology company; or
- their subsidiaries or affiliates.
Entering into agreements with these companies, their subsidiaries or affiliates for telecommunications equipment and/or services is prohibited, as doing so could place the College at risk of losing federal grants and contracts. Please note, this listing may be incomplete.
Gettysburg College Effort Certification Policy and Procedures
In accordance with Federal requirements (§200.430) prescribed by the Office of Management and Budget (OMB), charges to Federal awards for salaries and wages must be based on records that provide reasonable assurance that the charges are accurate, allowable, and properly allocated. In order to receive and maintain eligibility for funding, sponsoring agencies require organizations to gather documentation to substantiate that the level of salary or wages charged to Federal awards is commensurate with the effort expended. This certification is completed for the following two purposes:
- To verify that the percentage of effort placed on a Federal award is not less than the percentage of salary charged to the Federal award.
- To capture any voluntary cost sharing by indicating any excess percentage of effort as compared to the percentage of salary.
After-the-Fact Certification Reporting
The College utilizes an “After-the-Fact” reporting system to comply with the federal effort certification requirement. Under an after-the-fact system, distribution of salaries and wages for employees working on externally-funded projects will be supported by effort certification reports. Charges are made initially on the basis of estimates made before the services are performed. Effort certification reports will reflect an after-the-fact reporting of the actual percentage distribution of activity of employees. If significant (>10%) differences between the charges and actual distribution, the charges will be promptly adjusted to reflect actual activity.
Employee Effort Certification Reporting Policy and Procedures
Employees working on Federal awards are required to adhere to following procedures on Effort Certification:
- Faculty and exempt employees will be asked to report the percent effort for all federally sponsored activity and curricular activities (i.e., instruction, administration, advising, etc.) using the Gettysburg College – Effort Certification Report. Note: Hourly employees and student workers are not required to complete a report as their time is certified via electronic time sheets.
- Effort Certification Reports will reasonably reflect the percentage distribution of effort by faculty and exempt employees charged to federally funded projects. Effort is not determined based on a 40-hour week but rather as a percentage of total employment activities. 100% effort is an employee’s total hours actually spent on work within the scope of his/her employment activities. The activities for which you are being compensated, include sponsored and non-sponsored activities, for a given time period. The purpose of the report is to certify the level of effort expended on these activities.
- Employees should provide an account of all effort expended on a sponsored activity, even if the sponsor did not compensate the employee for that activity, which constitutes “cost sharing.” This can occur on a mandatory or voluntary basis. Mandatory cost sharing occurs when it is required by the sponsor at the time of application. Voluntary cost sharing represents additional effort expended on a project that is not required by the sponsor. Although it is the College’s practice to minimize voluntary cost sharing, the Principal Investigator must record all effort expended on their projects regardless the source of compensation.
- Faculty and exempt employees will complete and sign the Effort Certification Report. Principal Investigators / Project Directors (PI/PD) are required to verify the accuracy of information provided by employees working on the grant. Certification reports of the PI/PD are to be verified by the department chair or dean.
- Effort Certification Reports are required annually and at the completion of a grant. Financial Services will distribute the reports to PI/PD’s in September of each year and when closing out a grant. Completed forms must be returned to Financial Services by October 15 or 30 days after a request. The PI/PD is responsible for sending the form to any other faculty or administrative employees working on the grant and ensuring the forms are completed.
- Completed Employee Effort Certification Reports will be filed in the Financial Services Office.
Subject to the following obligations and conditions, equipment acquired under a Federal award will vest in the College upon acquisition:
- The equipment is used for authorized purposes of the project, and the College will also make the equipment available for the use on other projects supported by the Federal government, provided such use will not interfere with the work on the project it was originally acquired
- The College will not encumber the property without approval of the Federal awarding agency
- When no longer needed for the original program or project, the equipment may be used in other activities supported by the Federal awarding agency, in the following order of priority:
- For activities under an award from the Federal agency which funded the original program or project
- For activities under an award from other Federal agencies
- When acquiring replacement equipment, the College may use the equipment to be replaced as a trade-in or sell the property and use the proceeds to offset the cost of the replacement property.
Management Requirements: Procedures for managing equipment, until disposition take place, will meet the following requirements:
- The College will maintain adequate property records, which include a description of the property, serial or identification number, the source of funding for the property, who holds title, the acquisition date, original cost, the location, and any disposition data.
- The College will take a physical inventory of the property and the results reconciled with the property records at least once every two years.
- The College will maintain a system of control to ensure adequate safeguards to prevent loss, damage or theft, and to keep the property in good condition.
If there is a residual inventory of unused equipment:
- Valued at $5,000 or less: The College may retain, sell or dispose of the equipment with no further obligation to the Federal awarding agency.
- Valued at $5,001 or more: Upon termination or completion of the project or program and the equipment is not needed for any other Federal award, the College must retain the equipment for use on other activities or sell them, but must, in either case, compensate the Federal government for its share. The College will contact the Federal awarding agency for instructions on the disposition instructions and determining the amount of compensation.
Supplies acquired under a Federal award will vest in the College upon acquisition.
If there is a residual inventory of unused supplies:
- Valued at $5,000 or less: The College may retain, sell or dispose of the supplies with no further obligation to the Federal awarding agency.
- Valued at $5,001 or more: Upon termination or completion of the project or program and the supplies are not needed for any other Federal award, the College must retain the supplies for use on other activities or sell them, but must, in either case, compensate the Federal government for its share. The College will contact the Federal awarding agency for instructions on the disposition instructions and determining the amount of compensation.