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VIII. Awards From Federal Agencies

Much of the information in this section comes from government circulars issued by the White House Office of Management and Budget (OMB) and published at the U.S. Government Printing Office.

CFR 220 sets forth the rules governing the eligibility and calculation of costs in support of sponsored research, development, training and other works produced in agreement with the United States Federal Government.

CFR 215 sets forth standards for obtaining consistency and uniformity among federal agencies in the administration of grants to and agreements with institutions of higher education, hospitals, and other nonprofit organizations.

Award Payment

For federal grants, including subgrants through other institutions, payment is normally made on a billed basis and handled through the Accounting Office.

Budget

Budgets for proposals to government agencies should be developed in accordance with the federal regulation as outlined in CFR 215.

Direct Costs

Equipment and Supplies – According to the federal government, equipment is any item needed to carry out your project that costs more than $5,000. Anything per unit cost that is less than $5,000 should be included under supplies (e.g., computers). Please note that equipment purchased should be American made “where practical” and anything costing more than $100,000 must be purchased using a competitive bidding process.

Participant Support Costs – Federal regulations prohibit diversion of these costs (e.g., student stipends, travel, tuition) to other categories and the costs must be separately tracked.

Travel – Use federally-determined domestic and international rates in estimating travel costs.

Subcontracts – Federal agencies require that both the contractor and subcontractor adhere to Office of Management and Budget requisites regarding accounting and audit procedures. It is the responsibility of the faculty members to obtain assurance from the subcontractor that compliance with federal regulations will be maintained. Failure to do so makes the primary contractor liable. Subcontracts on federal grants may not be issued to any person or entity appearing on the U. S. Government Excluded Parties List System.

Indirect Costs

Negotiated Indirect Cost Rate – Per college policy, a 37 percent federal negotiated indirect cost rate applies to all grant application budgets unless the funder indicates a lesser rate must be used or that the organization does not fund indirect costs.

Cost Sharing

Federal agencies may require the institution to demonstrate its participation through the contribution of a portion of the funds required for the overall project. Potential cost share items include: faculty salary, related fringe benefits, the difference between the college's negotiated indirect cost rate and the cost rate allowed by the funder, and other non-federal grant support. General supply and expense items should not be included. UC Berkeley provides an excellent guide to cost sharing, no cost sharing (as required by NSF) and the language to use for this in budget narrative.

Unallowable Costs

The following costs from CFR 220 are listed as not allowable:

  • Alcoholic beverages
  • Alumni activities
  • Bad debt
  • Commencement and convocation cost
  • Contingency provisions
  • Costs of criminal and civil proceedings
  • Donations and contributions
  • Entertainment costs
  • Fines and penalties (failure to comply with federal, state or local laws & regulations)
  • Fundraising and investment costs
  • Goods or services for personal use of college employees
  • Housing and personal living expenses
  • Interest
  • Lobbying
  • Meals other than budgeted travel costs
  • Student activities (unless specifically provided for in the sponsored agreement)
  • Travel – Airfare costs in excess of the customary standard commercial airfare (coach or equivalent) are not allowed except under very specific conditions such as the medical needs of the traveler. These conditions must be documented.

Compensation

Any faculty member receiving compensation from a federal grant must record their work on time and effort report forms. The effort shown is not based on a 40-hour work week nor on FTE. Effort is an employee's total activity within her or his college appointment. For faculty, this includes all research, teaching and administrative duties. However, it excludes any income obtained outside one's duties at Linfield. Effort is expressed in percentages and must total 100 percent.

Contracted Services

The procurement of contracted services must follow federal guidelines, which are outlined in the document: Linfield Federal Procurement Procedures. Please note that services costing more than $100,000 must be purchased using a competitive bidding process.

Data Management Plan

A proposal to apply for funding from the National Science Foundation must include a two-page Data Management Plan describing faculty plans for managing data and sharing the products of research. Guidance for developing a plan is available through the NSF Frequently Asked Questions resource and the Linfield faculty grants website.

Deadlines

New methods of online submission for most federal funding requests are sometimes difficult and time consuming, and some requests are rejected for minor infractions and must be resubmitted. For this reason, anyone expecting to submit a proposal online should begin the process at least a week in advance to allow for errors, electronic issues, and general delays that are common with this system. The Director of Foundation and Corporate Relations is available to assist you with any submission problems or challenges.

Expenditure of Funds

Charges must meet the requirements of Office of Management and Budget CFR 215 regulations, WHICH MEANS ALL EXPENDITURES MUST BE SIGNED OFF BY ANOTHER PERSON AT THE COLLEGE. No payment may be made to a vendor or individual included in the U.S. Government’s Excluded Parties List System.

Equipment Purchase

The procurement of equipment must follow federal guidelines, which are outlined in the document: Linfield Federal Procurement Procedures. Please note that equipment purchased should be American made “where practical” and anything costing more than $100,000 must be purchased using a competitive bidding process. The selection of any computer or video equipment should be reviewed by Integrated Technology Services before purchased. All equipment and supplies purchased through grants funds are the property of Linfield College.

Excluded Parties List System

Any persons, business or organizations receiving federal funds through Linfield College must not listed as excluded from payment on the federal government's Excluded Parties List System.

Financial Conflict of Interest

Per college policy, in compliance with federal regulations, any faculty member holding a federal grant must complete a Financial Conflict of Interest (FCOI) form should that person determine that a potential conflict of interest has occurred. A conflict of interest is a convergence of an individual's private interests and his or her professional obligations to Linfield such that an independent observer might reasonably question whether the individual's professional actions or decisions are determined by considerations of personal gain, financial or otherwise. For the National Science Foundation and National Institutes of Health, FCOI forms must be submitted for review prior to submitting an application. Applicants to the National Institutes of Health must receive FCOI training, per agency rules.

No-Cost Extension/Non-Competing Continuation Grant

In the event of a no-cost extension or a non-competing continuation grant, it is the responsibility of the faculty member to inform Human Resources when employees charged against the grant are to be paid past the initial termination date. In addition, for continuation grants the faculty member must submit new Temporary Employment Hire forms for all personnel and dates of employment to be charged to the new grant year. This should be done prior to the starting date of the continuation so that salaries can be properly applied against the correct budget number.

Rebudgeting

Certain federal agencies have provided expanded authority to the recipient institution to change a budget without receiving prior approval. This includes the reallocation of budget line items, pre-award setup costs limited to 90 days prior to start date of the award, and a one-time only no-cost extension for up to one year. Prior approval from the granting agency is required for the changes in 1) student support, 2) subcontracts greater than $25,000, 3) building construction, 4) F & A rate, 5) scope of work, and 6) changes in principal researchers/project directors.

Responsible Conduct in Research

As of January 2010, the National Science Foundation requires Responsible Conduct in Research training by specified individuals including student researchers. The required RCR Training must be completed, and a copy of the certificate of completion should be attached to the Personnel Action Form requesting payment. In compliance with this regulation, Linfield has developed a Responsible Conduct in Research Policy.

Subcontracts

If you received a federal grant, all subcontractors must state in writing that they will abide by the federal regulations governing grants. A subcontract agreement will be drawn up by the Grant Administrator and obtain the signature of the authorized representative of the subcontracting entity. Subcontractors submit bills to the faculty member who then routes the statements to Accounting. Subcontracts may not be issued to anyone or any organization on the U. S. Government Exclusion Lists cited above.

Technical and Financial Reports

The faculty member is responsible for the timely submission of all technical reports, in accordance with the terms of the grant. The Accounting Office is responsible for all financial reports, in accordance with the terms of the grant. Unless otherwise specified in the grant terms, final reports are normally due within three months of the termination of the grant.

Travel Regulations

U.S.-flag air carriers must be used for U.S. government-financed commercial foreign air travel if service is available. To learn more about this policy and checklist of exceptions to this rule, consult this federal document.