Sponsored Programs Policy

Approved by: Allana Hamilton

Original Date Effective: 2014-07-01

Last Modified: 2017-11-06

GENERAL STATEMENT

It is a good practice of Jackson State Community College to participate in grant and contract awards through proposals. All awards for grants and contracts are made between JSCC and the Granter and must be approved by the President or his/her designee. The College thus assumes full responsibility for ensuring that the program is conducted within the administrative guidelines and regulations specified by both the sponsoring agency and the College.

Grants and contracts are restricted funds awarded to JSCC by federal, state, local, private industry, private foundation, non-profit agencies and individuals. These awards are used for research, public service, and instruction. Awards may cover a period of one year or multiple years. Administration of these restricted funds is governed by the awarding agency, federal, state, Tennessee Board of Regents and Institutional policies.

Federal and State laws as well as internal policies and regulations must be followed when preparing, accepting, signing and executing sponsored agreements.

The project director/principal investigator has the responsibility for directing the technical aspects of the project and otherwise carrying out the research or program effort within the scope authorized by the agency and for initiating any and all expenditures of grant funds within budget and contract constraints. The Principal Investigator is responsible for all compliance issues, and completing the closeout process. Post award accounting and monitoring, will be done by the Sponsored Programs Officer.

The President or the President's designee must approve and execute all agreements and contracts. (TBR Policyl-03-02-10) Furthermore the President or the President's designee must approve all grant proposal before they are submitted for funding consideration.

TENNESSEE BOARD OF REGENTS GUIDELINE

The purpose of a written contract is to embody the complete agreement in writing. Whether the document is called and agreement, contract, memorandum of agreement ( or memorandum of understanding), or purchase order (see TBR Purchasing Policy 4:02:10:00), it is subject to the requirements of this guideline. No relevant terms should be left to an unwritten "understanding" or verbal agreement (see G-030). Yon may obtain a copy of these guidelines at https://policies.tbr.edu/guidelines/contracts-guideline

FEDERAL REGULATIONS

Although each grant or contract has its own terms with which the College must comply, there are several federal regulations that govern each grant or contract. Most state and private organizations have incorporated these regulations into their guidelines. The Uniform Administrative Requirements, Cost Principles and Audit Requirements for federal awards can be found in 2 CFR Chapter I, Chapter II, Part, 200, et al. A link is provided. https://www.gpo.gov/f dsys/granule/CFR-2014-title2-voll/CFR-2014-title2-voll -part200/ content-detail.html

The following policies and procedures relate to all sponsored programs funded through grants and contracts for externally funded projects awarded to the College.

Code of Conduct

The college frequently enters into contractual and other formal obligations with outside entities. These obligations may include, but are not limited to, research and other grants and contracts, commercial contracts, software licenses, gift indentures, and memoranda of understanding. All employees and individuals representing the college are expected to act in good faith and adhere to all obligations assumed by the college. No employee or individual representing the college shall participate in the selection, award or administration of a contract or grant if a real or apparent conflict of interest would be involved.

All employees and individuals representing the college should strive to avoid the perception of or actual conflicts of interest that might compromise their integrity and objectivity. Conflicts, including those of a financial, personal, or professional nature, must be disclosed. Members of the college should strive to eliminate or manage such conflicts in an appropriate manner. (See Conflict of Interest Procedures).

Grants and contracts awards supported with federal funds must comply with 0MB 2 CFR 200 .318 https://www.gpo.gov/fdsys/pkg/CFR-2014-title2-vol 1/pdf/CFR-2014-title2-vol 1-sec200-318.pdf

Contracts and Grants Development

Faculty and staff should notify their respective supervisor and vice president of their intent to seek external funding for all projects that they wish to pursue. In the event that a funding source cannot be found the assistance of the Sponsored Programs office can be employed. When a funding source has been determined, the announcement of funding or other solicitation information must be submitted to the, Division Dean, respective Vice President and Sponsored Programs Officer for review. In no event shall the employee pursue funding without the approval from the Division Dean and the Vice President. In no event shall proposals be submitted electronically or mailed without the final approval of the President.

It is the Institution's policy that all grants and contract proposals, letters of intent and preprosals (whether private or public) be routed through the proper Vice President and the Sponsored Programs Office before submission.

Most funding agencies publish guidelines that list proposal requirements and instructions on how to prepare a proposal. Proposals not meeting such requirements are typically not reviewed by the receiving agency and are returned to the proposing institution. Therefore, great detail should be given to all requirements, instructions, special forms and time frames.

A meeting with the Sponsored Programs Officer must be scheduled to discuss areas of the proposal including but not limited to the following issues and concerns:

Project Manager/Principal Investigator
Budgets
Compliance
Conflict of lnterest
Financial potential
Subcontracts/Partner Agreements
F & A Cost (rate, negotiations)
Match requirement (space, personnel, equipment, etc.)
Line items related to the budget

JSCC Policy Number

Phone discussions and emails may be sufficient for discussing the various areas of the proposal.

When preparing budget information staff should contact the Sponsored Programs Officer for assistance. The institutions compensation plan must be used to calculate salary amounts for all personnel listed in proposal budgets. Any exception(s) must be granted by the President.

All proposals must be submitted to the Sponsored Programs Officer five (5) business days before the due date to ensure a thorough review is done. Exceptions may be granted based on when the proposal is due. The full proposal must be submitted with all required attachments (letters of support, appendix, equipment list, etc.).

Every full proposal submitted for external funding to any agency or organization whether public, private, or otherwise, must receive administrative approval by the respective Vice President(s) and President before it is submitted.

When JSCC issues contracts one of the contract forms in the TBR guideline should be used in order to assure that the agreement conforms to the requirements of TBR policy and the G-030 guideline,

Acceptance of Awards

Grants are awarded to Jackson State Community College, not to the Principal Investigator/Project Director. Therefore, the college is the legal entity for compliance with the terms and conditions of awards.

Programmatic negotiations will be conducted by the Principal Investigator. Funding negotiations will be conducted by the Director of Business Services with direct input from the Sponsored Programs Officer, and Principal Investigator/Project Director. Should the negotiation result in programmatic and funding changes that significantly increase the level of JSCC commitment beyond those authorized by the original proposal the Sponsored Programs Officer will secure approval from all administrators signing the original proposal prior to accepting the award.

Grants awarded to the College must be approved and accepted by the President or his designee.

When a granting agency requests formal acceptance of an award, the acceptance will be routed to the President or his/her designee to be signed. No award agreement exists until the required documents are signed and returned.

When a sponsor issues an award letter that does not require a written acceptance, the President will commit the College to that award by notifying the Sponsored Programs Officer. An award letter creates an agreement unless specifically declined by the College. Initial expenditure of funds constitutes formal acceptance of such awards.

Declination

An award can be declined by the President in writing.

All declination will be routed to the Sponsored Programs Officer.

The Sponsored Programs Officer will notify all administrators signing the original proposal of the intent to decline an award prior to taking further actions.

Project Budget Format

Budgets for both proposal and final awards shall be prepared in accordance with the College's financial system. When Standard Forms are used, the Principal Investigator/Project Director may be required to assist with preparation of all fiscal reports and provide additional documentation to support expenditure classifications.

Budgets for all proposals and final agreements must include line items for employee benefits and indirect cost. If the sponsoring agency has written policies disallowing these costs and negotiation is not an option, written documentation of the awarding agency's policy must be obtained and filed by the Sponsored Programs Officer. Other funding sources must be identified to cover these costs. JSCC will document such expenditures as cost sharing/match.

Project budgets will clearly indicate the start and end date of each budget period. Salary, travel, supply and equipment items will be budgeted in conformity with relevant JSCC and Tennessee Board of Regents policies and guidelines unless sponsors' written requirements are more restrictive.

Creation of Restricted and Matching Accounts

Once the award is accepted by the College, the Sponsored Programs Officer will enter the award in Banner and request a Fund, Organization and Program code be established by the Director of Business Services.

If cost-sharing or matching funds are required by the agreement, the Sponsored Programs Officer will notify the Director of Business Services to establish the necessary unrestricted account(s) and setup the necessary budget.

All cash cost-sharing or matching funds will be placed in project specific unrestricted accounts.

Cost-sharing or matching obligations met through third party contributions or through in-kind contributions, will follow the Cost Sharing Policy located on jWeb.

The Project Director/Principal Investigator must provide the following information to the Sponsored Programs Officer prior to the creation of the grant in Banner, if not included in the grant agreement:

A list of due dates for all billings and reports on the award/contract.
A billing address for the award/contract.
The name, address and telephone number of a contact person for inquiries pertaining to fiscal/program matters on the award/contact.
The date for final billing and reporting, and closeout requirements, if any
Identification of the source of funds (e.g., private, state, federal)
The CFDA number for any federal funds awarded.

Once the account has been created the Project Director/Principal Investigator may spend from the account upon notification of the assigned number(s). The Dean and Vice-President will be notified by the Principal Investigator/Project Director.

Pre-award Spending

The 2 CFR 200.309 Period of performance is when charges may be incurred to the award that are allowable and any pre-award cost that have been incurred that were authorized by the awarding agency.

Any expenditure or commitment of project funds in advance of the existence of an agreement between the College and the sponsor shall be considered pre-award spending. 2 CFR 200.209 defines pre-award cost as those incurred prior to the start date of the period of performance.

Pre-award spending will be permitted only in documented, exceptional circumstances, and must be requested in writing by the Project Director/Principal Investigator. Pre-award spending must be approved by the awarding agency in writing before a request is made to the Institution.

Pre-award spending requires approval of Director of Business Services and/or Vice President of Financial and Administrative Affairs. All requests for pre-award spending must identify a College account to which the expenditures will be charged in the event an agreement is not achieved.

Allowable Cost/Project Spending

OMB 2 CFR Chapter I, Chapter II, Part 200, et al defines cost principles to be applied and set limits on the costs which may be charged to the government under federally sponsored agreements. Only allowable direct costs required for the performance of the award and allowable indirect costs can be charged.

According to 2 CFR 200.403, a cost may be charged to a sponsored program if it meets all of the following criteria:

It must be a reasonable cost
It must be allocable (ability to be assigned or charged) to the sponsored program
It must be treated consistently, through the application of generally accepted accounting principles
It must be within the limitations specifically defined in 2 CFR 200 Subpart E-Cost Principles and the particular contract or agreement, in terms of the type of cost item and dollar amount charged.

Direct costs are costs that can be specifically identified with the sponsored project and that are charged directly to the account(s) assigned to that project. The College treats the following types of expenditures, incurred in the performance of sponsored work, as direct costs charged to sponsored projects:

Salaries, wages, and proportional fringe benefits of personnel directly engaged in the sponsored project.
Travel and transportation expenses
Consultant fees
Subcontracts
Telephone charges
Postal charges
Space rental
Equipment, materials and services
Other allowable costs per the terms of the agreements

Indirect costs consist of costs that cannot be easily identified with a specific sponsored project or other College activity. The College uses an approved rate set by its cognizant agency the U.S. Department of Health and Human Services.

All cost must comply with College policies on allowable expenditures. Cost must then be evaluated according to federal definition of allowable and unallowable expenditures. These guidelines apply to both direct and indirect costs supported by either institutional funds (unrestricted match) or sponsored funds. In SciQuest, the purchasing system, the Sponsored Programs Officer is setup as a Level One fund approval. The Sponsored Programs Officer reviews expenditure request prior to being charged to grant awards to ensure all charges are allowable.

Although some cost may be allowable under Institutional policy they may not be allowable under grant terms and federal regulations. 2 CFR 200 Subpart E Cost Principles -General Provisions for Selected Items of Cost 200.420 forward describes fifty (50) selected types of cost items. In case of a conflict between General Provisions for Selected Items of Cost and the provisions of a specific agreement, the terms of the agreement shall apply.

Charging annual leave to a grant is an allowable expense; however, certain precautions must be taken to protect the College and the awarding agency. Annual leave earned under sponsored programs must be taken by the end of each fiscal year or by the end of the grant period, whichever comes first. Individuals hired on grants that cover multiple years will have until the end of the grant period to use their leave. Grant employees who are not able to use all their annual leave before the grant ends may be allowed to receive a lump sum payment if it is allowed by the granting agency and if funds are available at the end of the grant period. A person hired on one grant and transferred to a different grant must take all leave earned under the first grant. It is not transferrable to the new funding source. It will be at the president's discretion to allow leave earned while working on a grant to be transferred to unrestricted funds in the event the individual remains with the college.

Authority and Responsibilities of the Project Director/Principal Investigator

The individual designated on the award document( s) as Project Director or Principal Investigator becomes responsible to the Institution for completion of the funded project and compliance with the terms and conditions of the award.

The designated Project Director/Principal Investigator shall be responsible for budgetary controls and fiscal management for the award, subject to compliance with this policy, and all other Institution and TBR policies, procedures and guidelines governing sponsored agreements-as well as the terms and conditions of the award.

The designated Project Director/Principal Investigator, under the guidance of the respective Dean and Vice-President, shall have full programmatic control and fiscal management of the award, subject to the terms and conditions of the award agreement and all applicable TBR and Institution policies and procedures. The Project Director/Principal Investigator will maintain complete and orderly records documenting project performance in compliance with the terms and conditions of the award agreement.

The Project Director/Principal Investigator is responsible for the timely preparation and submission of all performance or programmatic reports required by the funding agency or the terms and conditions of the award agreement. A copy of all reports must be submitted to the Dean and Vice President of that area (if desired) and to the Sponsored Programs Officer for filing.

Debarment & Suspension

The Uniform administrative requirements for grants and agreements with institutions of higher education, hospitals, and other non-profit organizations 2 CFR 215 .13 requires recipients of federal funds to comply with debarment and suspension. Section 13 states, "federal awarding agencies and recipients shall comply with the non-procurement debarment and suspension common rule implementing Executive Orders 12549 and 12689, "Debarment and Suspension." The common rule restricts sub-awards and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.

Further discussion in Appendix A 8; No contract shall be made to parties listed on the General Services Administration's List of Parties Excluded from Federal Procurement or Non-procurement Programs in accordance with E.O.s 12549 and 12689, "Debarment and Suspension." This list contains the names of parties debarred, suspended, or otherwise excluded by agencies, and contractor's declared ineligible under statutory or regulatory authority other than E.O 12549. Contractors with awards that exceed the small purchase threshold shall provide the required certification regarding its exclusion status and that of its principal employees.

Jackson State will not enter into any contract or subcontract agreement with any parties included on the Debarred and Suspended List

Project Monitoring

All expenditures on sponsored projects require prior approval from the Sponsored Programs Officer. Expenditure documents (purchase requisitions, faculty supplemental pay, travel authorization and claims, check requisitions etc.) must be routed through the following approval prior to processing:

Project Director/Principal Investigator's immediate supervisor
Sponsored Programs Officer
Any special approvals required ( e.g. OIT, Purchasing)

Purchasing and Business Services personnel will return all documents to the Sponsored Programs Officer that arrives without appropriate approvals.

The Sponsored Programs Officer will review all expenditures for programmatic justification; conformity with sponsor's approved budget, and conformity with policies, regulations, terms and conditions of the agreement.

Budget Revision and Modifications

All requests for budget revisions must be submitted on a budget revision form. It will be reviewed and signed by the Dean and Vice President for that area and the Sponsored Programs Officer.

If sponsor prior approval is needed for a budget revision, the request for such approval will be forwarded through the Sponsored Programs Officer. Approval of all budget revision will be dependent on the approval of the awarding agency

If sponsor prior approval is unnecessary, the Sponsored Programs Officer will add a statement to that effect to the budget revision request and forward the document appropriately.

Reports and Sponsor Billings

Financial Reports

All financial reports and invoices or billings for sponsored agreements will be prepared by the Grants and Loan Officer in consultation with the Project Director/Principal Investigator, and Sponsored Programs Officer when necessary.

Reports and billing will be prepared and submitted according to the sponsor's specifications.

When a specified format has not been stated by the sponsor, the Grants and Loan Officer may use a format in the Banner Research Module.

Financial reporting must be in compliance with the following: Generally Accepted Accounting Principles; Financial Accounting Standards Board; Governmental Accounting Standards Board Statement; Cost Accounting Standards Board Statement. The basic requirements of these standards include the following:

Sources and uses of funds must be aggregated by the type of activity they support, and in accordance with any restrictions imposed on their use.
Revenue is reported when earned, and expenditures are reported when goods or services are received.
In general, revenue is earned when the Institution provides goods or services.
Likewise, expenses are incurred as the Institution uses goods or services.
Accounting principles must be applied consistently, both within fiscal years and between fiscal years.
Transactions must be classified and recorded consistently.

Program Reports

Most awarding agencies require quarterly or semi-annual updates of all program activities. The Project Manager or Principal Investigator will be responsible for all timely submission of these reports and will follow guidelines stated by the awarding agency. A copy of each report shall be sent to the designated Dean/Department Head and Sponsored Programs Officer.

Cash on Hand

Reimbursement is the preferred method of payment when the sponsor is a federal agency. In some instances an advance from the federal agency may be requested. When a cash advance is needed the PI or Project Manager must notify the Sponsored Programs Officer of their need to request an advance. Proper steps will be taken to ensure that the receipt of cash and the payment of expenditures minimize the days of cash on hand. Advances will only be allowed for major capital purchases and will require the approval of the VP for Financial and Administrative Affairs or the Director of Business Services. The Sponsored Programs Officer will make sure that the advance is for allowable costs. Funds will be requested once the items have been purchased, delivered and invoice received. Since most agencies use A CH/wire transfer as their method(s) of payment it is usually received within 48 hours. Therefore, the time elapsing between the receipt of cash and payment is minimized.

Closeout and Audit

The Project Director/Principal Investigator is responsible for proper project closeout at the end of an award period. This includes reconciliation of financial, equipment and programmatic records, completion of all necessary reports to sponsor, and any other obligations incurred as a result of the award.

Unless an authorized extension has been granted by the sponsor agency, all obligations incurred under the award shall be liquidated by the date of completion as specified in the terms and conditions of the award; but no later than 90 calendar days after the funding period. The Sponsored Programs Officer will set termination dates in Banner Research that coincides with the funding agencies policy.

The Project Director/Principal Investigator, in cooperation with the Sponsored Programs Officer, will make project financial and programmatic records available for audit by the College internal auditor and by the Tennessee State Audit as required.

In the event of a sponsor site visit or audit of a project, the Project Director/Principal Investigator will notify the Sponsored Programs Officer that the site visit/audit will occur.

Because awards are made to the College, and the College incurs liabilities as a consequence of accepting awards, the College reserves the right to terminate an agreement or to replace a Project Director/Principal Investigator in the event of mismanagement or misconduct.

GLOSSARY OF TERMS

ALLOCABLE - The ability to be assigned or charged. Cost that benefits the account to which it is charged in proportion to the benefit that it provided.

COST SHARING (also referred to as match) - expenses to be absorbed by Jackson State Community College based on the terms of the award. Items purchased with federal funds cannot be used to meet the cost sharing/matching requirement of another federal award unless it is allowed by the awarding federal agency.

DIRECT COST - cost that can be identified specifically with a particular sponsored project, an instructional activity, or any other institutional activity; or that can be directly assigned to such activities relatively easily with a high degree of accuracy.

FACILITIES AND ADMINISTRATIVE COST (formerly Indirect Cost or overhead) - F & A costs are those that are incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular sponsored project. Nonetheless, they are real costs of the project, including building and equipment use allowances, general administration, library expenses, etc.

PROJECT DIRECTOR/PRINCIPAL INVESTIGATOR (PI) - The faculty or staff person responsible to both the College and the awarding sponsor for proper management and administration of the technical aspect of a sponsored project; while also complying with financial and administrative policies and regulations of the award (s).

PROJECT PERIOD - The entire time period for which support has been approved by the sponsor, including extensions. All cost allowable to the grant must be incurred during this period.

RESTRICTED FUNDS - Funds available for current operations but which are limited by donors and other external agencies to specific purposes, programs, and departments.

SPONSORED PROJECT - A "sponsored project" is an initiative funded by an externally generated grant, contract, and/or a cooperative agreement.

SPONSORED PROGRAMS OFFICER- the staff person that holds oversight for all restricted fund activities and transactions ensuring that the institution remains in compliance with all applicable federal, state, private, board and institutional policies and guidelines. This person assists the college community in all phases of the grant life from pre-award to closeout and is also included in the approval process from pre-award to closeout.

TIME AND EFFORT REPORT - Documentation of effort which reflects an accurate amount of time that is used to justify direct cost or match on grants. This institution uses after-the-fact reporting.