Sponsored Project Application, Acceptance, and Administration Policy (Policy 46)

PURPOSE 

Governors State University (“GovState” or “University”) solicits major types of external funding including but not limited to grants and sponsored awards (collectively, “Sponsored Awards,” defined below). The purpose of this policy is to ensure the University complies with federal, state, and sponsoring agency requirements for the application, acceptance, and administration of Sponsored Awards. 

1. Sponsored Awards: A grant, contract, or other method of funding pursuant to which the University receives financial or other types of support from an external third party (such as a federal or state agency or private foundation or company) in exchange for the University satisfying express or implied conditions for purposes including, but not limited to, research, instruction, or service activities. Notwithstanding any other provision of this Policy, the term “Sponsored Awards” shall not include gifts made to the University or Governors State University Foundation (“Foundation”) where the proceeds of such gift is unrestricted or where the conditions are not subject to reporting requirements. 
2. Principal Investigator: A University employee who is responsible for performance of the activities specified in the Sponsored Award, either directly or indirectly. 
3. Sponsor: An external third party agency making a Sponsored Award. 

1. APPROVAL PROCESS 
   1. To facilitate compliance, all applications for Sponsored Awards must be processed and coordinated through the University’s Office of Sponsored Programs and Research. 
   2. All applications for Sponsored Awards, and resulting contracts or grants, must be made in the name of the University and must be approved and/or signed in advance of submission by the Provost or his/her designee. The Provost is authorized to sign resulting grant instruments and/or contracts as well.
   3. University employees may conduct preliminary negotiations with prospective Sponsors with the prior knowledge and approval of the Office of Sponsored Research but are not authorized to bind the University to accept a Sponsored Award (except the Provost or his/her designee).
2. Compliance
   1. The University shall comply with all applicable law, federal, state, and local, and Sponsor requirements, in the application for, administration of, and fulfillment of Sponsored Awards. All employees working on a Sponsored Award application or award are responsible for complying with applicable law, regulations, Sponsor requirements, and University policy, including but not limited to (as applicable):
      1. the award instrument issued by the Sponsor; 
      2. 2 CFR 200, Uniform Guidance (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards); 
      3. other federal regulations; and 
      4. University policies.
   2. If the Sponsor conditions its award on the waiver of established University policies, such as reimbursement of indirect cost, rights of publications, or rights to intellectual property generated by the research, the University may accept such conditions if required by law or if a waiver is found to be clearly in the interests of the University and the public. Unless a project falls into a limited number of pre-established exceptions, Principal Investigators must petition for such a waiver/reduction on a case-by-case basis. Waivers/reductions are not granted for an entire type or class of project.
3. Role of Office Sponsored Programs and Research 
   1. The Office of Sponsored Programs and Research coordinates proposal submissions to Sponsors, monitors awards for compliance, and provides advice and assistance to faculty and staff in the proposal development process, including finding funding opportunities. 
   2. The Office of Sponsored Programs and Research obtains the appropriate authorized signatures for Sponsored Award applications and resulting grants and contracts. The Office of Sponsored Programs and Research reviews all applications to ensure all sponsor requirements are met and that all application components are provided as part of the submission.
4. Role of Principal Investigator
   1. The Principal Investigator named in each Sponsored Award bears primary responsibility for all aspects of that award, including but not limited to financial management, effort reporting, subrecipient monitoring, award closeout, and compliance with all specific award terms and applicable federal Office of Management and Budget (OMB) requirements.
5. Receipt and Accounting of Funds
   1. Sponsored Award funds will be deposited, disbursed, monitored, and reported according to GAAP (Generally Accepted Accounting Principles) through the appropriate University financial offices.
6. Role of Office of Institutional Advancement
   1. If the proposed Sponsor is a foundation, individual, or corporation, the Office of Institutional Advancement will be notified by the Office of Sponsored Programs and Research of the proposed application. The two offices will coordinate the effort, including aiding with the budget development and the submission.