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 Office of Research and Program Development
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. In addition,
the GCA office will supply the Principal Investigator
with monthly reports comparing the project's
original budget with expenditures to date.
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. The function 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 three months). A Request
for Salary Correction form has been developed
to assist in submitting the necessary information
(link to form). 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.
Annual
Rate |
Applicable
Dates |
Monthly
Rate=Annual/12 |
Pay
Period Rate=Annual/24 |
$161,200 |
Jan
1, 2001 - Dec 31, 2001 |
$13,433.33 |
$6,716.67 |
$166,700 |
Jan
1, 2002 - Dec 31, 2002 |
$13,891.67 |
$6,945.83 |
$171,900 |
Jan
1, 2003 - Dec 31, 2003 |
$14,325.00 |
$7,162.50 |
| $174,500 |
Jan
1, 2004 - Mar 2, 2004 |
$14,541.67 |
$7,270.83 |
$175,700 |
Mar
3, 2004 - Dec 31, 2004 |
$14,641.67 |
$7,320.83 |
$180,100 |
Jan
1, 2005 - Dec 31, 2005 |
$15,008.33 |
$7,504.17 |
$183,500 |
Jan
1, 2006 - Dec 31, 2006 |
$15,291.67 |
$7,645.83 |
$186,600 |
Jan
1, 2007 - Dec 31, 2007 |
$15,550.00 |
$7,775.00 |
$191,300 |
Jan
1, 2008 - Dec 31, 2008 |
$15,941.67 |
$7,970.83 |
Example-Annual |
|
|
|
Base
Salary |
$200,000 |
|
|
NIH
Salary Cap |
$180,100 |
|
|
Effort=10% |
$200,000
X 10% |
$20,000 |
|
|
$180,100
X 10% |
$18,010
(1) |
|
|
$20,000
- $18,010 |
$1,990
(2) |
|
|
$18,010/$200,000=9.00% |
$1,990/$200,000=1% |
|
Effort=10% |
NIH
Project=9% |
Cost
Share=1% |
|
On
NIH Project |
Salary
% from NIH Project |
Salary % from Non-Federal Funds
|
Note:
Effort will be rounded to whole percents. |
(1)
This is the maximum amount of annual salary
that can be charged to the grant.
The maximum allowable charge per month
would be $1,500.83 ($18,010/12)
and the maximum amount per pay period
would be $750.42 ($18,010/24)
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(2)
Salary in excess of the salary cap. This
amount must be paid from non-federal funds.
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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: The North Dakota Legislature raised
the acquisition cost of capital equipment from
a price greater than $750 to a price $5,000 or
greater effective July 1, 2001.
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.
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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