SIUC SPONSORED PROJECT GUIDE

   Section 10: Research Policies and Compliances

Research integrity involves adherence to ethical standards in practices ranging from treatment of research subjects and supervision of employees to management of data and assignment of authorship. Many of these issues are covered by official policies and compliances, but many are not. All researchers have the obligation to carry out their University-sanctioned projects responsibly and to train their staff and students likewise. See ORDA's page on responsible conduct of research for guidance.

Most formal policies affecting research and sponsored projects are first considered by the Research Committee of the Graduate Council and ultimately approved by the SIUC chancellor or president. Other research-related policies, principles, and guidelines listed here derive from broader University policy, from commonly accepted practices in sponsored project administration, and from government requirements.

Note: The position referred to in the text of formal policies as the Associate Vice Chancellor for Academic Affairs and Research and Dean of the Graduate School is now the Vice Chancellor for Research and Graduate Dean.

Compliances

Other University Policies Affecting Research

Other Sponsored Project Policies and Guidelines

See also Section 5, Proposal Submission, for submission procedures and lead time requirements
Section 7, Grant Management, for grant administrative procedures
Section 8, Hiring Staff, for hiring procedures and employment policies
 
 
  Compliances


10.1  Animal Care Compliance

The SIUC Institutional Animal Care and Use Committee was formed to establish and enforce ethical, humane guidelines for the use of live animals in research and teaching at the University. The committee reviews all protocols involving the use of vertebrate animals to assure compliance with humane standards and federal regulations.

Researchers whose project will involve vertebrate animals (whether laboratory animals, livestock, or wildlife) must submit a completed Animal Use Protocol form for the committee's review. This requirement applies regardless of whether the project will be externally funded. Approval of the protocol is required before the animals can be used for training, research, or testing purposes. For more information and protocol forms, see the Institutional Animal Care and Use Committee web site or contact the secretary of the committee at 453-4540.

Some agencies, such as the National Institutes of Health, will not review grant proposals that lack the necessary institutional approval. Thus, it is strongly recommended that you contact the committee as early as possible in the project planning stage.

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10.2  Hazardous Materials Compliances

Faculty and staff conducting projects that involve hazardous biological materials (including recombinant DNA), radiological materials, or hazardous chemicals must comply with all relevant government regulations. They must obtain institutional approval before the research can begin and before any grant/contract award to support the research can be accepted. In many cases, agencies will not even review a proposal that lacks proper clearance; thus, researchers should obtain any needed approvals during the project planning stage. SIUC's Center for Environmental Health and Safety (453-7180) oversees the activities described below and monitors compliance.

10.2.1  Hazardous Biological Materials and Recombinant DNA

SIUC's Institutional Biosafety Committee and Biological Safety Officer are responsible for ensuring that faculty and staff who conduct research with hazardous biological materials comply with the most recently published federal and state standards for such research. Biological materials covered by the standards include living organisms, products produced by such organisms, organic chemicals produced to mimic activity/actions of such products, and recombinant DNA molecules. Biological materials are considered hazardous if they present a direct or indirect risk to the well-being of humans, animals, or plants.

Any SIUC researcher who plans to conduct research involving potentially hazardous biological materials or recombinant DNA must submit to the Institutional Biosafety Committee a memorandum of understanding and agreement (MUA) describing the work and the safeguards to be used. The proposed project must be approved by the committee before activities can begin. For more information and for copies of the appropriate MUA form, contact the Institutional Biosafety Officer at 453-7180 or see www.cehs.siu.edu/biological/ibc/.

10.2.2  Radiological Materials

SIUC holds licenses issued by the Illinois Department of Nuclear Safety that contain specifications governing research projects that involve radiological materials. All research conducted at the University must be done within the framework established by the licenses and various other state and federal regulations. SIUC's Radiological Control Committee formulates policies for uniform practice throughout the University wherever radioactive materials or radiation-producing devices are involved.

Prior approval of the committee must be obtained by any University personnel who plan to use radioactive materials in their work. The appropriate application forms and training modules are available from the Radiation Safety Office, 536-2015, or see www.cehs.siu.edu/radiological/.

10.2.3  Hazardous Chemicals

The Center for Environmental Health and Safety formulates guidelines for managing and disposing of hazardous chemicals and complying with government regulations concerning such materials. Researchers whose projects will involve the generation of hazardous chemical waste should consult the Chemical Waste Management Guide for information about the procedures to be followed and training requirements, or they may contact the center at 453-7180.

There are no disposal options for "mixed waste"—i.e., waste that is both chemically hazardous and radioactive. Consequently, research involving the use or generation of such waste will not be approved.

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10.3  Human Subjects Compliance

The U.S. Department of Health and Human Services requires that all research projects involving human subjects be screened to confirm that the subjects' rights, privacy, welfare, and civil liberties are protected. The SIUC Human Subjects Committee is responsible for reviewing all proposed human-subjects research projects to be conducted by individuals affiliated with SIUC, including students. This review protects not only the human subjects involved in a research project, but also the researcher and, by extension, the University. No research involving human subjects, whether grant-funded or not, may be conducted prior to receiving committee approval. For more information and application forms, or to submit a planned project for review, contact the secretary of the committee at ORDA (453-4533).

Some agencies, such as the National Institutes of Health, will not review proposals that lack the necessary institutional approval. Thus, it is strongly recommended that you contact the committee as early as possible in the project planning stage.

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10.4  Significant Financial Interests Disclosure

Investigators and project employees with a significant financial interest in any business entity (a) sponsoring their research, (b) whose business is substantially related to the subject matter of the proposal, and/or (c) that could reasonably be expected to bias the activities described in the grant proposal must fill out a Disclosure of Proposed Non-University Activities and Financial Interests form. This form must be returned to ORDA before the grant proposal is submitted. "Significant financial interest" is defined as $10,000 or more in annual income, or ownership/stock interests of 5% or more, including the financial interests of any immediate family member.

Where a significant financial interest is disclosed, any grant award resulting from the proposal cannot be accepted by SIUC until the institution has determined that no significant conflict exists or has worked out safeguards to avert a conflict of interest. Disclosures must be updated by the researchers and other project employees during the period of the grant award, either on an annual basis or as new reportable significant financial interests are acquired.

This policy applies to grant proposals to all sponsors, public and private. It also satisfies the Investigator Significant Financial Interests Disclosure Policy of the National Science Foundation and the Public Health Service. See the University's Conflict of Interest Policy.

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10.5  Stem Cell Research Compliance

The SIUC Stem Cell Research Oversight (SCRO) Committee reviews proposals for any research to be undertaken at SIUC involving the derivation or use of human stem cells—whether adult, embryonic (to include the derivation of hESCs from human embryos/blastocysts, however they were created), umbilical, placental, or fetal. The committee must approve the proposal before the research can begin.

Review and approval by the SCRO Committee is in addition to and is not a replacement for approval by or adherence to other University policies, federal regulations, and state and local laws governing research. Other policies that need to be considered include, but are not limited to, reviews by the Institutional Animal Care and Use Committee, the Human Subjects Committee, the Institutional Biosafety Committee, federal HIPAA privacy standards, etc. See section IV-A of the SIUC Policy and Procedures Governing Stem Cell Research for the sequence of review. Note that all projects involving human stem cells, whether to be conducted at Carbondale or at Springfield, are reviewed by the Springfield Committee for Research Involving Human Subjects.

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  Other University Policies Affecting Research


10.6  Academic Freedom

SIUC supports the principle of academic freedom, including freedom of research and unrestricted dissemination of information. See the University policy statements Academic Freedom—Rights and Responsibilities and Code of Ethics. Faculty and staff are entitled to full freedom in research within ethical and legal constraints, including retention of research data and publication of research results, unless they negotiate and agree to limited restrictions as part of a sponsored project award. See Publication Rights, below.

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10.7  Clean Air

SIUC's Clean Air policy prohibits smoking in indoor areas. The section of the policy specifically relevant to research (I-1.) provides that where use of tobacco products is required in connection with approved research activities, researchers may request authorization from the Vice Chancellor for Research and Graduate Dean.

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10.8  Conflict of Interest

Overview below  |  Full text of policy here | Also see Significant Financial Interests Disclosure, above

Research and sponsored project activities should not result in any actual or apparent conflict of interest or conflict of commitment. Such conflict could lead to various problems, including undue influence of a private business in the University's operation or procurement practices, interference with a faculty or staff member's other employment duties at SIU, interference with a student's education, and improper use of University property. Although the University encourages interested faculty and staff to develop contacts in the private sector and to conduct industry-sponsored research activities, faculty and staff should be especially alert to potential conflicts in such situations.

SIU employees must read and comply with the requirements and principles set forth in the University's Policy on Conflict of Interest: Non-University Activities and Financial Interests. As the policy notes, Illinois law requires full-time faculty members to obtain official written approval from the institution (appropriate vice chancellor) before engaging in outside research or consulting for remuneration, and to provide an annual statement of the amount of actual time spent on such activities.

Full-time employees must complete a Disclosure of Proposed Non-University Activities and Financial Interests form annually if income greater than $1,000 is expected to be received from non-University activities that would reasonably appear to directly affect or be affected by their University responsibilities. The form must be submitted and approved before the employee initiates such activities.

Activities and financial interests for which reporting is not necessary include:

  • time spent in preparing books, articles, lectures, works of art, etc., expected of faculty and staff in the normal course of University duties;
  • royalties from writings published before the policy's effective date of 4/21/95;
  • prizes;
  • uncompensated and volunteer activities.

Activities and financial interests that are necessary to report include:

  • accreditation and program reviews for other institutions;
  • sale of art work or scholarly work, including royalties from writings published on or after the policy's effective date of 4/21/95;
  • honoraria;
  • guest lectures, workshops, and artistic performances (paid or unpaid);
  • consulting activities and outside research;
  • salary from any non-University entity;
  • stock, stock options, ownership interests;
  • intellectual property rights.

Employees engaged in approved non-University activities must complete and submit an Annual Report of Approved Non-University Activities and Financial Interests to the chair or director of their unit at the end (June 30) of the fiscal year in which the activity occurred.

All researchers should read the full text of the Conflict of Interest Policy.

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10.9  Drug-Free Workplace

Both the federal Drug-Free Workplace Act of 1988 and the Illinois Drug-Free Workplace Act of 1992 require contractors and grantees, as a precondition for receiving funds, to certify that they will provide a drug-free workplace. The University's Drug-Free Workplace Guidelines provide, among other things, that each employee to be engaged in the performance of a federal grant or contract shall be given a copy of the following statement:

"All employees are hereby notified that the unlawful manufacture, distribution, dispensation, possession, or use of controlled substances is prohibited on property owned or controlled by the Board of Trustees or in any site where duties of University employment are being performed. Violations of this prohibition will subject employees to disciplinary action in accordance with the applicable personnel policy, law, or regulations having the force of law. As a condition of employment for an employee directly engaging in the performance of work pursuant to a grant or contract covered by the said Act, the employee will abide by the above terms and shall notify the University of any criminal drug statute conviction for a violation thereof not later than 5 days after such conviction."

The guidelines further state that the University will notify the relevant granting or contracting agency within 10 days of receiving notice of a criminal drug statute conviction from a grant/contract employee.

Employees should read the full text of the guidelines, one of several University statements concerning drug and alcohol use by students and employees and concerning alcohol regulation on the SIUC campus.

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10.10  Electronic Information Privacy

The University's Electronic Information Privacy Policy has various implications for sponsored projects, including such issues as confidentiality of data, responsibility for security of stored information, and inappropriate usage of computing resources. All researchers should read the full text of this policy and be familiar with its provisions.

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10.11  Institutional Submission of Grant/Contract Applications and Acceptance of Awards

[The following is the text of a July 21, 2004, memo from then-Chancellor Walter V. Wendler reminding faculty of institutional requirements concerning submission of grant/contract proposals.]

It is an institutional requirement that all applications for externally funded grants and contracts be submitted through proper University channels. The Office of Research Development and Administration (ORDA) is the responsible unit for that purpose at Southern Illinois University Carbondale (SIUC). This requirement pertains to all employees who receive any part of their salary through the University, or whose activities use any University resources or facilities. Awards must be made to the Board of Trustees of Southern Illinois University.

This requirement is necessary to ensure that all research and other externally funded projects conducted by University employees, or with the use of University resources or facilities, are approved by ORDA for compliance with relevant University, state, and federal guidelines, policies, and regulations. These include, but are not limited to, the following:

  • Use of University facilities.
  • Adherence to personnel policies, including compensation plans and insurance.
  • Responsible conduct of research policies, including research integrity, misconduct, conflict of interest, and intellectual property.
  • Protection of human and animal subjects and the environment.
  • Fiscal accountability, including recovery of direct and indirect costs.

The accountability and legal responsibility for conduct of externally funded projects and for compliance with all applicable policies reside with ORDA as the agent of the University in these matters. If there are any questions pertaining to this policy, contact the Associate Vice Chancellor for Research and Director of ORDA, the Vice Chancellor for Research and Graduate Dean, or the Chancellor's Office.

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10.12  Intellectual Property (Patents and Copyrights)

Overview below  |  Full text of policy here

SIUC's Intellectual Property Policy states that patentable inventions, products, processes, or discoveries developed with University support belong jointly to the University and the creator. Their use shall be controlled by the University "in ways that will produce the greatest benefit to the University, the creator, and the public."

The policy also states that copyrightable works developed with significant University support likewise belong jointly to the University and the creator. (See the policy for the definition of "significant University support.") The University places no other claim on traditional academic copyrightable works, with the exception of material made for hire.

Inventions, products, processes, discoveries, and copyrightable works covered by the University's policy must be reported by the creator in writing to the University Intellectual Property Committee through ORDA's Senior Technology Transfer Specialist, Jeff Myers (jmyers@siu.edu, 453-4556). Disclosure forms (PDF) are available online. The next higher University authority (usually the department chair or unit director) must be informed in writing by the creator at the time the disclosure is submitted.

Within 45 days of the disclosure, the creator is notified of the date on which the committee will review the disclosure. The committee's recommendation as to the disposition of the intellectual property is forwarded to the Vice Chancellor for Research, who makes the decision whether to retain the intellectual property or release all rights to the creator. The decision must be made within 135 days of disclosure unless the creator agrees to an extension.

Faculty should be aware that publicly revealing or disclosing a patentable invention prior to filing a patent application precludes the availability of patent protection in foreign countries, creates a time limit for U.S. filing, and may cause problems related to development and licensing. Faculty and staff are required to cooperate in delaying publication or other public disclosure of intellectual property until the University's review/disposition process is completed. In some cases, longer delays may be needed.

Note that proper laboratory recordkeeping is crucial to legally defensible patent claims and protection in the case of a dispute over an invention. See Managing Your Intellectual Property on the Technology Transfer web site for links to some good resources in this area.

The Intellectual Property Policy establishes a sliding scale for splitting net income between the creator and the University. For example, the first $50,000 of net income is split 50:50 between these two parties. As income increases, the portion allotted to the creator gradually drops to 35%, with additional shares going to the creator's department and college. (Before profits are distributed, the University deducts expenses, such as those incurred in patenting and licensing the product.)

Licensing and royalty income allows SIUC to reinvest in its technology transfer activities and to support research endeavors at the University. In addition to licensing technology to existing companies, ORDA's technology transfer office, along with the Office of Economic and Regional Development and the Southern Illinois Research Park, can assist researchers in starting their own businesses to commercialize their patentable inventions.

Special considerations for grants and contracts:

Funding agencies may require prior approval of the terms and conditions of agreements concerning patentable discoveries and copyrightable materials resulting from the research they have sponsored. Research grants and contracts between the University and the sponsor should set forth each party's obligations and rights and the procedures to be followed if patentable discoveries or copyrightable materials result from the research. Any points not negotiated in the award agreement with the sponsor are subject to University policy. The University and the agency sponsoring a research project also can negotiate licensing options as part of a grant or contract..

For more information, see the full text of the Intellectual Property Policy and the Technology Transfer web site.

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10.13  Research Faculty

Overview below | Full text of policy here

Research faculty positions are non-tenured/non-tenure-track term appointments devoted full time to research. Salaries are ordinarily funded from external research grants generated by the individuals themselves. Research may be independent or in collaboration with one or more other faculty members on campus. These collaborators may support the candidate until external funding is secured, or during short gaps when funding is not available. Since the individual is expected to secure external research funding, appointment is on a temporary basis. Renewal will be denied if, in any consecutive 24-month period, the individual does not have one or more major external grants on which he/she serves as principal investigator or co-principal investigator with direct costs in sufficient amount to provide for his/her salary as PI or co-PI.

Each department or academic unit establishes guidelines concerning qualifications for appointment, criteria for promotion, salary increases, access to departmental space and support funds, recommendations for service on or chairing of graduate student committees, and departmental voting privileges for research faculty. These guidelines must be approved by the appropriate deans and vice chancellor. Graduate faculty status follows established procedures.

See the full policy for more details. Information on the hiring process for faculty is available in section 8 of this guide.

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10.14  Research Misconduct

Overview below  |  Full text of policy here

SIUC expects all researchers to adhere to the highest ethical standards in their work. See ORDA's Responsible Conduct of Research page for guidance.

The University's Policy and Procedures on Research Misconduct and the standing University Committee on Research Misconduct provide the mechanism by which concerns about the integrity or accuracy of a research project can be reviewed and resolved. The policy is designed (1) to allow for the expeditious handling of cases of alleged misconduct, (2) to safeguard the rights of all parties involved in such cases, and (3) to demonstrate the University's commitment to intellectual honesty in conducting and reporting research. It applies to everyone involved in funded or unfunded research activities at SIUC, including students.

The policy defines misconduct as an act of deception, distinct from error. Researchers have the responsibility both to report apparent occurrences of misconduct and to take steps to correct the scientific record when they discover error. Any concerns about a research project or allegations of misconduct may be brought to the attention of the chair of the University Committee on Research Misconduct, the Vice Chancellor for Research and Graduate Dean, or the ORDA director.

For details, see the full text of the policy. Also see the University policy statement Code of Ethics.

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10.15 Researcher Positions: Guidelines for Classification

There are six classifications of A/P research personnel:

  • Researcher I
  • Researcher II
  • Researcher III
  • Assistant Scientist
  • Associate Scientist
  • Senior Scientist

University policy governs the process for requesting new researcher/scientist positions and reviewing or upgrading existing positions.

Guidelines for the Classification of Research Positions, a document posted on the web site of the University Affirmative Action Office, contains these guidelines and also describes general responsibilities and minimum qualifications for each classification. A Researcher Classification Worksheet must be submitted with any request for a new position or reclassification of a current position. Questions about research classifications and salary ranges should be directed to the Office of the Associate Provost for Academic Administration (536-5535).

Minimum salary rates for these classifications are posted online by Human Resources.

Information on the hiring process for A/P staff is available in section 8 of this guide.

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10.16 Software Piracy

The University's Software Piracy Policy has implications for sponsored projects and research, though its purview is far broader. The policy states that unauthorized copying of computer software will not be tolerated and that University employees and students making, acquiring, or using unauthorized copies of computer software may be subject to University disciplinary sanctions as well as to legal action by the copyright owner. See the full text of the policy for more information.

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10.17  Use of University Property

Overview below | Full text of policy here

The use of public property for nonpublic purposes is prohibited by the Illinois Constitution. SIU Board of Trustees policy stipulates that use of University property for the benefit of a third party pursuant to a contractual agreement must advance the public purposes of the University. Consequently, the terms of sponsored project agreements, particularly University/industry research agreements, must be approved by the institution. Likewise, University employees may not use University facilities or property for non-University business without prior approval. See SIUC's conflict of interest policy.

In this connection as well, any services provided by SIUC's centralized research support facilities for the private sector are charged at a campus (subsidized) rate only if the work is part of a grant- or contract-funded research project. Otherwise, the work is charged at a higher commercial rate, which is set to recover the full costs of performing the work, including overhead.

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  Other Sponsored Project Policies and Guidelines


10.18  Best-Effort Performance

Sponsored projects at the University are conducted on a best-effort basis. Principal investigators are expected to organize projects according to the time frames agreed upon as part of the grant or contract and to do high-quality work.

The University does not accept grant/contract awards that stipulate the achievement of specific research results. Accordingly, it will not accept award provisions that provide for withholding of payment or impose other penalties if the sponsor is not satisfied with project results.

Aside from losses arising as a direct result of negligence, the University cannot be held liable to the sponsor for loss or damages suffered by the sponsor either during and as a consequence of the performance of the research, or as a consequence of any actions of the sponsor based upon the results of the research.

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10.19  Classified Research

The University does not accept classified research grants, contracts, or agreements. It will not enter into or renew any grant, contract, or agreement that would prohibit it from disclosing the existence of the award document, the identity of any sponsor of the proposed research, or the nature and potential contribution of the proposed research.

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10.20  Cost-Sharing Guidelines

General Policy:

Excessive cost sharing—in terms of percentage of investigator effort and total SIUC contributed dollars—is discouraged.

Definition:

Cost sharing refers to the resources contributed or allocated by SIUC to an externally (usually federally) sponsored project, over and above the support provided by that sponsor. SIUC shares the cost of these projects in order to support and enhance its institutional research mission.

Types of cost sharing:

  • Mandatory: Mandatory cost sharing refers to that portion of the University contribution to a sponsored project that is required by the sponsoring agency as a condition of obtaining the award.

  • Voluntary: Voluntary cost sharing refers to that portion of the University contribution to a sponsored project which is not required, and which the University contributes at its own initiative. If the proposed cost-sharing amount (such as principal investigator time) is included in the proposal text or award budget, it then becomes a binding commitment and must be documented and reported as if it were mandatory cost sharing.

Costs may be shared via:

  • Matching funds (cash) - funds contributed from unrestricted institutional sources; for example, SIUC funds to purchase equipment. (Note: This must be cited somewhere in the proposal.) Equipment must be purchased during the time of the award, not in advance, unless the agency allows pre-award costs.

  • In-kind contributions - for example, faculty time/salary and graduate assistantships, plus associated benefits, including tuition waivers. Faculty time commitments are given as a percentage of faculty effort during the term of the award, and that percentage must be reported each semester on University Effort Reports.

  • Third-party contributions - either cash or in-kind; may be donations, volunteer labor, or through subgrants, subcontracts, or similar collaborative agreements.

According to OMB Circular A-110, Sec. 23, mandatory cost sharing and in-kind contributions on federal grants must be

  • verifiable from the University's financial records;
  • related to program objectives: necessary and reasonable for proper and efficient accomplishment of the project, and incurred during the award term;
  • allowable under the applicable cost principles (OMB Circular A-21);
  • shown in the approved budget;
  • not paid from or charged to another federally assisted project or program (unless specifically allowed); and
  • not includable within the University's indirect cost rates.

The most appropriate University contribution to federal research projects is University-funded salaries of faculty and other employees directly engaged in the project, plus applicable benefits and indirect costs. University-furnished space and existing equipment on campus are not allowable cost-share contributions, nor are departmental administration expenses (secretarial service, office supplies). Existing equipment may be described in a proposal as "available for use by project researchers at no direct cost to the project."

IMPORTANT:

  • The tracking, reporting, and certifying of cost sharing are subject to audit, particularly as they show up in faculty/staff effort reporting. In the case of volunteer labor, it is important to document the time spent and account for it at a reasonable rate consistent with rates paid for similar work at SIUC. In the case of donated property, the value shall be determined in accordance with the usual accounting policies of the University.

  • Although it is possible that a PI may have submitted numerous proposals that involve more than 100% of his or her effort, the PI, department chair, and college dean must ensure that effort committed to funded projects does not exceed that allowed by the faculty or staff member's appointment.

  • Unrecovered F&A (indirect) costs may be included as part of cost sharing or matching only with the prior written approval of the federal awarding agency.

  • Identifying and providing resources for cost sharing of direct costs (including equipment) is always the responsibility of the PI.

  • Individual agencies may have requirements for cost sharing that differ slightly from each other and from these; check the agency's specific requirements before preparing a proposal budget.

  • Similarly, the weight of cost-sharing contributions in the success of a proposal varies among agencies. The National Science Foundation (which requires only 1% cost sharing) recently adopted the policy that voluntary cost sharing will not be considered in review of proposals, and other agencies are expected to follow suit.

  • SIUC's policy is to grant a tuition waiver to all teaching, research, or administrative assistantships, whether the funding is from an external agency or state funds.

  • For fellowships or traineeships provided by external agencies, Graduate School approval for a tuition scholarship (waiver) must be obtained before the proposal is submitted.

VERY IMPORTANT:

Cost sharing represents real costs to the University.

  • Cost sharing represents a redirection of departmental and college resources from teaching or other departmental activities to support sponsored projects. The PI, department chair, college dean, and other administrators should carefully weigh the cost-effectiveness and the expected benefits of every proposal for cost sharing prior to making the commitment. They also must be careful that effort committed does not exceed that allowed by the faculty or staff member's appointment.

  • The more dollars expended by SIUC in cost sharing, the fewer dollars come back to campus as F&A (indirect cost) returns for internal redistribution as faculty seed grants, travel support, and other research support.

  • The more dollars expended by SIUC in cost sharing, the more "expensive" our research appears to be to the Illinois Board of Higher Education in comparison with that of other state institutions.

  • If cost-sharing commitments are not met, a portion of the grant funds may have to be returned to the sponsor.

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10.21  Facilities & Administrative (Indirect) Costs

The indirect costs, or overhead expenses, of a project are just as real as the direct costs, though less visible. The federal government classifies these expenses as "facilities & administrative (F&A) costs," though you may still see the term "indirect costs" on nonfederal grant application forms. These costs include such things as space and facilities maintenance, utilities, library resources, processing of project-related fiscal paperwork by University service offices (Accounting Services, Purchasing, etc.), monitoring of project expenditures and compliance with government regulations, and numerous other research support services at the University.

It is the University's policy to recover the relevant federally audited F&A (indirect) cost rate (set by the U.S. Department of Health and Human Services) from all agencies that are legally bound by that agreement and from all other federal, state, and private funding agencies that will reimburse the University at the audited rate. The rate varies depending on whether the sponsored project is for research, training, or other activities and whether it will take place primarily on or off campus.

In instances where an agency's official indirect costs reimbursement rate is less than the audited rate, or where an agency does not allow any overhead, a reduction or waiver of indirect costs can only be granted by the ORDA director with the concurrence of the Vice Chancellor for Research and Graduate Dean. The agency must provide a written statement of its public policy on indirect costs reimbursement.

In the case of full indirect cost recovery, the relevant institutional rate is assessed on the project's modified total direct costs (MTDC), which exclude the following budget items: equipment, space rental costs, capital expenses, stipends, tuition waivers, and subcontract amounts in excess of $25,000. If the agency's reimbursement rate is lower than SIUC's federally audited rate, no budget items are excluded from total direct costs unless the agency's policy stipulates otherwise.

Indirect costs are not assessed on equipment grants or on fellowships. In addition, indirect costs may be waived by the University on grants-in-aid that meet the following conditions: the grant-in-aid may not exceed $5,000 per year, and the grant-in-aid is "open-ended" with regard to expenditure of funds, as long as the account is active. A "grant-in-aid" is distinguished from a "grant" by these criteria: (1) the sponsor places no restrictions on the use of funds, other than specifying the research area to be supported; (2) the award is not in response to a formal written proposal; (3) no formal agreement is involved; (4) no report of activities is required by the sponsor (although a technical report available to the sponsor and the general public often is produced); and (5) no financial reporting is required by the sponsor. Where these conditions are met, Grant & Contract Accounting (Accounting Services) will establish a single budget account for each researcher receiving such grants-in-aid and deposit those awards into the common account.

—F&A (Indirect) Cost Rates

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10.22  Limited Proposal Submissions

Certain grant programs limit the number of proposals or letters of intent they will accept from an institution. When this is the case and more researchers want to apply than are allowed, the University must decide which proposals will be submitted to the program.

To facilitate a fair decision process, researchers planning to apply to a limited-submissions program are asked to submit a Notification of Intent to Apply to a Grant Program form to ORDA at least 30 calendar days before the agency deadline.

If the number of notifications received by the 30-day deadline meets or exceeds the program's limit, submissions will be closed. If the number exceeds the limit, a review process will be set up and each potential applicant will be alerted that a 3- to 5-page project description, 1-page budget, and PI curriculum vitas will be due to ORDA 15 calendar days before the agency deadline. The Vice Chancellor for Research will establish a committee to oversee proposal selection. (Exceptions to these deadlines may occasionally be necessitated by holiday breaks and will be announced on ORDA's web site or in Research Matters.)

If the number of notifications received by the 30-day deadline does not exceed the limit, ORDA will take any subsequent Intent to Apply forms on a first-come, first-accepted basis. When the program limit is reached, no further notifications will be accepted and submissions will be closed.

Be sure to check grant program guidelines early on for any submission limits! To guarantee that your proposal will be considered for submission to a limited-submissions program, meet the 30-day notification requirement. ORDA maintains a list of current limited-submission programs for which we have received one or more notifications; checking this list will tell you whether submissions are open or closed.

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10.23  Principal Investigator Eligibility and Responsibilities

Eligibility: Who Can Serve as a Principal Investigator

1. In general, principal investigators (PIs) are faculty members appointed at 50% time or greater. They often serve as fiscal officer of the project as well. Faculty may come from tenured, tenure-track, or non-tenure-track ranks. Emeritus faculty may serve as PI if the chair and dean of their former department and college approve, but for legal reasons they may not serve as fiscal officer.

2. A/P research staff (researchers/scientists): Those holding the title "Senior Scientist" may serve as principal investigator. "Assistant Scientists" and "Associate Scientists" may not serve as PI unless their department chair/center director and dean make exceptions for them. "Researchers" may not serve as PIs.

3. A/P nonresearch staff: These staff may serve as PI if their supervisor approves. The primary criterion is the individual's capability to lead and administratively manage the project. In some cases, a department may decide that the staff member may direct the project but may not serve as the fiscal officer.

4. Postdoctoral fellows, graduate students, and undergraduate students may not serve as PI.

PI Responsibilities

In administering a project, the PI is representing the University and is responsible for upholding the high standards expected of SIUC projects ("best-effort" performance). The overall scientific and administrative integrity of the project, including design and conduct, validity of results, and preparation of manuscripts, rests with the PI. See section 7.3 for detailed information on PI responsibilities.

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10.24  Proposal Submission Policy and Procedures

Signature Authority

Grant proposals and awards are processed through the Office of Research Development and Administration. (See the policy on Institutional Submission of Grant/Contract Application and Acceptance of Awards.) All grant proposals, whether electronic or hard-copy, must be reviewed and approved by ORDA before going to the funding agency. Only the ORDA director or a designee has institutional signature authority.

Even when a funding agency's electronic system gives principal investigators (PIs) the authority to submit their own proposals, for legal reasons ORDA approval is required first. Likewise, proposals that do not require an institutional signature still must be approved by ORDA before the PI submits the proposal to the agency. This is also the case when SIUC is a subcontractor with another institution.

ORDA Deadlines

1. Once you know you will be submitting a proposal, contact the ORDA project specialist assigned to your college at least a week in advance of the agency deadline. If the proposal is to a limited-submission program, you must submit a Notification of Intent to Apply at least 30 days in advance of the agency deadline; see the Limited Proposal Submissions policy.

2. Electronic proposals must be made available for ORDA review at least one working day in advance of the agency deadline. Once the proposal is written, print the completed copy and bring it to ORDA along with the budget, agency forms, and fully signed Proposal/Award Checklist. After reviewing the proposal (see section 5.5 of this guide), ORDA will submit it or will give the PI authorization to submit it, depending on the agency's submission system. Do not submit a proposal without authorization.

Note that ORDA cannot guarantee that the proposal will be submitted if you do not meet this deadline. Last-minute submissions can overload the funding agency's system, and may result in incomplete information being submitted and a whole host of other problems. ORDA cannot be held responsible in these situations.

Furthermore, funding agencies assume a proposal has had adequate review and approval before the institution submits it. Proposals written haphazardly and without adequate review reflect unfavorably on the PI and the institution. When a researcher brings a proposal too late for adequate review, the director of ORDA may agree to sign the proposal to meet the agency deadline but reserves the right to withdraw it from agency consideration if it is found not to meet University guidelines and standards.

3. Non-electronic (hard-copy) proposals: If you want ORDA to handle the photocopying and mailing of the proposal, you must bring it to ORDA for review and signature at least two working days in advance of the agency mailing deadline. (See section 5.5 of this guide.) If you will be handling the photocopying and mailing, the ORDA deadline is one working day in advance.

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10.25  Publication Rights and Proprietary Information

In keeping with the principle of academic freedom (see above), it is the University's general policy that faculty and staff are entitled to full freedom in the publication of research results. In some cases, however, such as industry-sponsored or defense-related research, the University recognizes that certain limited restrictions on the publication or other dissemination of data may be necessary.

Where the sponsor of the research supplies proprietary information to the researcher, for example, the award agreement may include reasonable provisions for the sponsor's review of manuscripts to verify that no such proprietary information is disclosed. (Principal investigators also must take great care to prevent any unauthorized or premature disclosure of proprietary information by the personnel working on their project, since they could be held personally liable for such disclosure.) Other provisions may allow for delay of publication for a limited period of time to protect patent and/or proprietary rights.

Any such prior reviews, publication delay provisions, or related restrictions must be negotiated and agreed upon as part of a sponsored project award; they may not be imposed by the sponsor after the fact. In no case will restrictions be agreed to that would constitute a serious threat to academic freedom. The University may turn down an award or request changes in an award agreement if the terms seem unduly far-reaching or if they would hinder the rights of other SIUC faculty to publish freely in a given area.

In submitting final research reports to sponsors, researchers may protect their own potentially patentable ideas by labeling the relevant sections of the report as proprietary, or confidential. If this situation will apply, the researcher must alert ORDA before submitting the research report. Reports returned by the sponsor as unacceptable because of material so labeled will be subject to an established on-campus review process.

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10.26  Subaward (Subrecipient) Monitoring Guidelines

ORDA has formulated these guidelines for the programmatic and financial monitoring of sponsored project subaward recipients. Principal investigators who have made subawards from their prime award also should read the section on subawards in section 7 of this guide, "Grant Management."

A subrecipient is a third-party organization performing a portion of an SIUC sponsored project. The terms of the relationship are documented in a subaward (subgrant/subcontract or consortium agreement). These guidelines are intended to assist responsible faculty and staff in ensuring (1) that the subrecipient is conducting its portion of the research in compliance with applicable laws and regulations and with the terms of the award and subaward, and (2) that the subrecipient's portion of the project costs is reasonable and allowable. Subrecipient monitoring is required by the federal government for federally funded subawards.

Roles and Responsibilities

1. Principal investigators (PIs) or their departmental grant administrators have primary responsibility for the monitoring of subrecipients to ensure compliance with federal regulations and with the terms and conditions of both the prime award and the subaward.

2. The Office of Research Development and Administration (ORDA) has responsibility for ensuring that subaward agreements contain appropriate federal and other applicable regulations consistent with sound business practices and for collection of subrecipient federal audits, if necessary.

3. Accounting Services' Grant & Contract Accounting division has responsibility for assisting PIs in reviewing invoices from subrecipients, questioning expenditures if necessary, and general cost allowability issues.

4. Resolution of complex subrecipient monitoring issues or the determination of courses of action will be done jointly by the PI, Grant & Contract Accounting, ORDA, and other administrative officials as appropriate.

Federal Regulations

The federal regulations that describe subrecipient monitoring are general, but contain the following core elements of compliance:

  • The routine receipt and review of technical performance reports.
  • The routine review of expenses vs. budget.
  • The option to periodically perform on-site visits, if necessary.
  • The option to perform "audits," if necessary.

It is also important to note that there may be additional sponsor-specific or program-specific requirements that mandate collection and documentation of other kinds of assurances (e.g., on lab animals, human subjects, biohazards, etc.) during the course of a project.

SIUC's Subrecipient Monitoring Guidelines

Certain subrecipient monitoring requirements imposed upon federally funded subawards are set forth in OMB circular A-133.

Verification of the subrecipient's annual audit must be obtained from each subrecipient whose federal funding level exceeds $500,000. This is handled by ORDA. Additional monitoring activity includes the following:

Collection of Technical Performance Reports - Technical Performance Reports should be reviewed and evaluated on a timely basis by the PI, unusual or unforeseen items should be investigated, and reports should be retained on file in the department for ready access by regulators. In some cases, subaward terms may require specified deliverables in addition to, or in lieu of, technical reports.

Review of Invoices and Expenses-to-Budget - For cost-reimbursement subawards, the subrecipient's invoices showing both current period and cumulative expenses-to-budget are generally required. PIs (or their departmental grant administrator) should compare the subrecipient's invoices to the established subaward budgets. Evidence of the regular review of invoices should be in place and retained on file. "Evidence" can be in the form of PI initials or an authorizing signature on invoices, e-mail communications, etc.

Clarification of Invoiced Charges - PIs (or their departmental grant administrator) should request explanations for any "unusual," "miscellaneous," "other," or apparently excessive charges invoiced by the subrecipient. If the explanations received are not sufficient to render a prudent judgment on the allowability of the cost, PIs may request detailed justifications from subrecipients. Examples of detailed justifications that may be requested from subrecipients are:

  • Payroll records/data.
  • Copies of paid invoices showing the cost of items purchased, and Vendor Justification Forms, if required by federal contract.
  • Descriptions of services rendered by consultants, including hourly rates and time reports.
  • Detail of travel charges incurred, stating the purpose, airfare, meals, ground transportation, unallowables, etc.

Costs determined to be unallowable or unreasonable should be disallowed. PIs should work with Grant & Contract Accounting to make such determinations. In extreme circumstances where questionable costs remain unresolved, it may be necessary to have an audit conducted. In such situations, PIs should contact Grant & Contract Accounting and ORDA (see Audits, below).

On-site Visits - On-site visits are a discretionary monitoring procedure. On-site visits conducted by the PI to evaluate both compliance with the scientific objectives of the project and the appropriateness of the subreceipient's administrative systems, processes, and charges should be documented via correspondence, meeting notes, trip reports, etc., and retained on file.

Audits - Discretionary audits of subrecipients are an acceptable monitoring procedure under federal regulations, and all of SIUC's cost-reimbursement subaward agreements contain "right-to-audit" clauses. Formal audits are performed very infrequently, however, and departments should contact Grant & Contract Accounting and ORDA before proceeding.

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10.27  Supervision and Reporting of Research

As a general rule, sponsored research at the University is conducted independently, in accordance with the principle of academic freedom. Technical direction or joint supervision of research is accepted only with the concurrence of the principal investigator. The PI must provide research reports to the sponsor at times specified in the award agreement.

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10.28  Use of University Name

Industry sponsors may not use the University's name in publicity or advertising of any kind unless: (1) prior written approval has been obtained from the SIUC chancellor, or (2) the award agreement contains provisions governing the use of the University's name by the sponsor, in which case the sponsor must comply with all stipulations.

University employees engaged in non-University business may not use the University name or their title in connection with those activities unless they have prior approval. See SIUC's conflict of interest policy.

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Questions/comments about the Sponsored Project Guide? Contact Marilyn Davis
Office of Research Development and Administration
Southern Illinois University Carbondale

last updated 07/23/07

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