Pre-proposals
Facts for Submission
Budget-Disclaimer
Administrative Systems
Types of Expenditures
Cost Share
Indirect Cost
Current Indirect Cost Agreement
Tax Exempt Documents


Pre-proposals:
Pre-proposals are sometimes submitted by a department as a preliminary step towards obtaining funding from a sponsor. Departments are encouraged to work with both Grants and Contracts Administration and the Research Development & Compliance in the development of the pre-proposal, however an authorized signature is not required prior to submittal.

All pre-proposals leaving the University of North Dakota should be clearly marked as such, and should include the following statement:
“This pre-proposal does not obligate the University of North Dakota to this project. Upon request of the sponsor, a formal and properly authorized proposal will be submitted.”

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Facts for Submission:
Cognizant Audit Agency
Thomas Suttles, Audit Manager
DHHS/OIG/Office of Audit Region VII
2425 Hyde Park Road
Jefferson City, MO 65109
Telephone: (578) 893-8338

Federal Identification Numbers
Employer Identification Number (EIN OR FEIN) = 45-6002491
DUNS Number = 10-228-0781
CAGE Code = 4B858
North American Industry Classification System (NAICS) = 611310

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Budget-Disclaimer:
The budget disclaimer should be used whenever a budget is submitted in greater detail than what is in our Budget Outline:

"Due to limitations within the University's accounting system, bolded budget line items represent how the University proposes, reports and accounts for expenses. Supplemementary budget information, if provided, is for proposal evaluation."

Use the forms attached to the Grants & Contracts Forms page to submit budget outlines:
Link to Budget Outlines on the Forms Page

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Administrative Systems:
The University of North Dakota has established systems for the effective administration of programs sponsored by external agencies. As with all sponsored programs, the Principal Investigator will be responsible for the overall administration and progress of the project.

The GCA office is responsible for submitting all required financial reports to all sponsoring agencies. Support for all expenditures including original invoices, payment vouchers, etc. will be maintained by the University.

The University of North Dakota is included in the statewide single audit in accordance with OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations. A report is issued every other year.

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Types of Expenditures:
Certain types of expenditures merit general discussion relating to grants and contracts. These include salaries, travel, food purchases/entertainment, consultants, subcontracts, and equipment/renovations.

Salaries
Salary amounts are determined by the following factors:
1. Approved University rate for the individual or an estimated amount for a comparable position if the position will be filled at a later time. Offices to be consulted:
Faculty - Vice President for Academic Affairs
Staff - Personnel Services
2. Amount available on the project based on allowable salary divided by the number of months. The total salary budgeted on the grant/ contract may not be paid over a period of time less than that stated in the budget, i.e., at an accelerated rate.
3. The beginning and ending dates of the project funding will determine the allowable dates of employment.
4. Effort reporting is a requirement on all grants/contracts/cooperative agreements. Records are maintained documenting both funded time spent on a project and nonfunded (cost share) time spent on a project. This is accomplished via the Personnel Activity Confirmation System (PAC). Any questions relating to effort reporting should be directed to the Grants and Contracts Administration Office (also see #6).
5. The regulations from the sponsor may be more restrictive than those of the institution, in which case the more restrictive rules will prevail. Overtime is not allowable on some grants/contracts even though it is allowable under institutional policy. Overload for faculty is only allowable on federal agreements with the prior written approval of the Agency.
6. Functions of the GCA Office is to properly administer sponsor funding. After the fact salary adjustments are always carefully monitored due to sponsor requirements. If an adjustment is necessary, the correction should be done in a timely manner (within 90 days). A UND Retroactive Distribution Request form has been developed to assist in submitting the necessary information (link to Payroll). No corrections should be requested after effort has been certified on a PAC form.

National Institutes of Health (NIH) Salary Cap
NIH will only support the following regardless of institutional salary.

Travel
University regulations apply to all grant or contract travel unless there is a restriction from the sponsor which would provide a lesser amount of reimbursement. When multiple sources of funding are used by an individual, the normal process requires travel to be funded from the same source as the salary funding for the person. For example:

1) John Doe has two research grants and also has a teaching appointment. John is paid 100% from appropriated funding (his time is provided to the projects as a cost share). He is traveling to a conference that relates to both sponsored projects. The travel expense should be split between the research projects in a ratio that approximates the benefit to be received by each.
2) Mary Smith has a research project that pays 100% of her salary. She has been asked by a colleague to travel to a conference on a topic unrelated to the topic area of her research project. Her travel expense would be paid from a different grant than her own. This would create problems for the funding source that is currently paying Mary's salary. Options to address this problem include obtaining sponsor approval to make the payments as planned, reducing her salary to correspond to the portion of time she is traveling on the other grant, being paid salary from the other grant to replace the lost salary on her own grant, or being paid partial salary from local or appropriated funds for the displaced salary. The key issue that must be addressed is that payments from any grant must directly relate to the purpose for which each sponsor provided its funding.

Food Purchase/Entertainment (separate from travel reimbursements)
University regulations apply to all grant or contract food purchases unless there is a restriction from the sponsor which provides a lesser amount. Generally, food purchases are not an allowable expense on grant funds. Exceptions exist, for example, in situations where the purpose of the funding is to provide a training session and lunch is to be provided to the participants. In all cases, the need for such costs should be specifically identified in the proposal and explicitly provided for in the budget. A few sponsors give the recipient organization complete flexibility in how grant money is spent. These are the exception, not the rule. The safest approach to take, if such costs are necessary to the successful completion of the project, is to specifically identify and request them. Entertainment expenses are not allowable on grant/contract funding.

Consultants
Consultant fees are usually an allowable cost on grant/contract funding. The amount that may be paid to a consultant will be based on University policy and/or sponsor restrictions. The normal situation that occurs involves an outside consultant providing services of a highly specialized nature. The Accounting Services Office has information available to assist in evaluating whether an employer-employee relationship or whether it is an independent consultant. University employees may, in unusual circumstances, be utilized as consultants on sponsored projects. If federal funds are to be used to pay the consultant fee, all of the following criteria must be met:
1. The consulting must be across departmental lines or at a separate or remote location.
2. The work performed must be in addition to the regular departmental work load.
3. The University employee/consultant must be specifically listed in the grant/ contract budget or approved by the sponsoring agency in a separate letter. If all of the criteria are met, an Employee/Consultant Certification Form, an Increased Income Approval, and a Notice of Appointment must be processed to obtain the appropriate University approvals and facilitate the payment to the individual.

Subcontracts
In situations where a portion of the work required under a grant/contract agreement is to be performed by an entity other than the University, a subcontract should be executed. Generally, the use of a subcontract should be provided for in the approved proposal and accompanying proposal budget. If a specific entity is identified in the proposal there should be a Statement of Work and a Budget with an authorized signature, provided to UND prior to proposal submittal. Additional forms and certifications may be required depending on the agency. A Sole Source Subcontract form would also need to be filled out at the time the award is made. The process of identifying the appropriate subrecipient may require a competitive selection process. The award document issued to the University will contain the specifics under which the subcontract will be performed. The subcontract document will be drafted by GCA in consultation with the Principal Investigator. Usually, both parties to the subcontract must sign before the subcontract will be effective. For the University, an official authorized signature is required on subcontracts. GCA staff will coordinate obtaining the appropriate signatures. Work may not be initiated until appropriately authorized.

Equipment/Renovations
Capital expenditures are usually allowable on grants/contracts; however, special approvals or restrictions are often required by the sponsor. Grants and Contracts Administration will provide the necessary information specific to the source of funds to be used for these types of expenditures. If capital expenditures will be needed, they should be specifically provided for in the approved proposal and the accompanying budget. This will minimize the need for additional approvals prior to the purchases.
Please Note: Capital equipment is defined as having a purchase price of $5,000 or greater.

General Purpose Expenditures
Items normally considered Facilities and Administrative Costs (F & A Costs). The salaries of administrative and clerical staff as well as costs of items such as office supplies, postage, local telephone and memberships should normally be treated as
F & A costs. The following criteria should be met in order for these costs to be allowed as direct charges to Grants, Cooperative Agreements or Contracts.
1. The costs are specifically identified and requested as part of the original/modified budget or accompanying narrative (for example, salaries or individuals involved can be specifically identified with the project or activity); and
2. Sufficient justification is included to demonstrate major project or extraordinary service; and,
3. The charges are not specifically disallowed in the resulting award or modification; and
4. If not included in the current award, subsequent explicit approval from the awarding agency has been received unless the federal agency has issued the award under expanded authority.

Expanded Authority
If the grant or cooperative agreement falls under Expanded Authority, costs normally charged as F & A cost will be allowed if sufficient written justification is included to demonstrate the cost would not be incurred except for the project.

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Cost Share:

Cost Share and Similar or Parallel Work

Cost Share
Program or project costs that are not supported by the sponsor. Cost-share can include cash and in-kind when such contributions meet the established criteria in OMB Circular A-110. (This would include costs that are reported to the sponsor and those that are not reported but are tracked for internal purposes.)
• Cash cost-share: Cash that is contributed specifically (excluding donations) to cover the actual costs of the sponsored project.
• In-kind cost share: Contributions proposed by a third party (ies) in the form of effort or goods with a dollar amount specified. These amounts must be verifiable by the third party, are necessary for proper and efficient accomplishments of project or program objectives, are not reimbursed with federal or federal flow-through dollars or used as cost-share with other federal funds, and are allowable under the applicable cost principles.
• Mandatory Cost Share: Cost share that is part of the sponsor's requirement. The sponsor requries a 25% match of the award.
• Voluntary Committed Cost Share: Cost Share that is provided for in the proposal but is not required by the sponsor. An example would be where the PI commits 20% of his/her time during the academic year with no compensation. The 20% effort must be captured during the academic year.
• Voluntary Uncommitted Cost Share: Faculty effort that is over and above that which is committed for in an award. Using the Voluntary Committed Cost Share example, if the faculty member in fact put forth 30% effort during the academic year we would only need to caputre the 20% efort as the additional 10% effort was not proposed.

Similar/Parallel Work
Projects that have similar technical backgrounds, but each project is a stand-alone project (this is used when conveying expertise in an area) and should include only funded projects. This should be specifically identified as to not convey a cost-share requirement. It cannot be stated that these projects will benefit the proposed project because that implies cost share.
• If presented on the budget page, it is preferable to use a horizontal dividing line to separate the project budget from the budgets of the similar/parallel projects.
• Similar/Parallel projects section should be labeled as Similar/Parallel Projects/Programs/Work as appropriate.
• Information may include (but not limited to):
Project title
Sponsor
Period of Performance
PI or Project Manager
Funded Amounts and/or Awarded Amounts (identified appropriately)
• If dollar amounts are noted, they should be traceable to a specific UND fund number or documentation from a third party. If dollars amounts are applicable to a UND fund, the total expenses from that fund should be attributable to the similar/parallel project (not just a portion of the expenses from that fund).
• The Similar/Parallel projects section will not be totaled with the budget section, however, each section can have separate totals.
• The information in #2 can be included on a separate page(s)/section(s) if page(s)/section(s) are titled or referred to appropriately as Similar/Parallel Projects.

Third Party Participants
A party (ies) that choose to lend their expertise, facilities, or personnel to a project but not be accountable for reporting the cost of that expertise, facilities, or personnel.
• An example would include a letter of technical support from the third party participant with no dollar amounts included and a statement indicating that this is not a commitment nor will they put a dollar amount on the proposed expertise, facilities, or personnel.

Note: Do not use the words “complimentary,” “collaborative,” “matching” or “related to” to indicate the non-cost sharing portion in a proposal.

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Indirect Cost:
It is the policy of the University of North Dakota to recover full indirect cost as defined by the applicable federal negotiated rate agreement. It is recognized that some sponsors have existing policies that preclude payment of indirect cost or provide only for partial reimbursement. To the extent that the policy of the sponsor has been verified, the University accepts the limitation on indirect cost recovery. In the interest of having current information available regarding these exceptions, Grants and Contracts Administration requests these sponsors provide a copy of their policy statement regarding payment of indirect cost, the applicable budget guidelines for funding recipients, or other evidence of their existing position on payment of indirect cost.

In dealing with federal funding (direct or flow through), it is possible that the enabling legislation for the program has some restrictions on the payment of indirect cost. The citation for the law should be obtained (verbal is okay) from which we can copy the legislation and verify the restriction.

During the conversations with sponsors concerning Indirect Cost, it is important to emphasize our desire to clearly understand their rules and to obtain definitive information for future use in the proposal process and subsequent award administration. In addition, since indirect cost is the reimbursement of real expenses, the verification of sponsor policy is an important step in our process of insuring that indirect costs are recovered to the greatest extent possible.

For those situations where less than the full Indirect Cost is being requested, a waiver must be obtained prior to submittal of the proposal. Waivers are determined on a case by case basis.

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