Forms, Policies & Procedures

Cost Shares for Equipment

Research Office equipment cost share dollars are available when proposals either require equipment cost share or the project budget exceeds the available funding in the area of equipment. Research Office policy allows for one-time requests of up to $50,000. Up to $50,000 for each of the years of funding proposed may be requested in case of large scale proposals of strategic significance to UD and that involve multiple academic units. All sums requested from the Research Office must also be matched in the equivalent amount by the college/unit (i.e., $50K from the Research Office requires an equal $50K from the college/unit).

Cost share letters and or commitments, including equipment, require sufficient justification and often a long lead time for approvals. PIs should start this conversation with their respective department chairs, or college research office/deans as early as possible. All proposals that require such commitments and/or letters of support from UD leadership (President, Provost, VP Research) should follow the steps outlined here. Please route all such requests via email to researchdev@udel.edu. Decision time on requests depends on the amount requested and the status will be conveyed back to the PI usually within a few days.

Formal approval for Research Office match of the cost share occurs at the time of the proposal submission through inclusion in the grant budget. The Proposal Approval Form will automatically be routed to those responsible for the cost share approval and for commitment to cover additional cost overrun attributed multi-year equipment match funding.

For further questions about Equipment Cost Share policy, please contact your Contract and Grant Administrator.

Cost Sharing Policy

1. POLICY
   The University engages in cost sharing when it is in the best overall interest of the University, limited to situations in which it is mandated by the sponsor per solicitation or policy guidelines, or deemed appropriate in light of specific and compelling circumstances.
2. SCOPE OF POLICY
   This policy establishes the requirements and procedures for proposing, approving, administering, and documenting Cost Sharing on Sponsored Projects, including all contributions, such as cash and in-kind, that a recipient makes to an award at the University of Delaware (“UD” or “University”). This policy also sets forth requirements to ensure compliance with federal regulations (Office of Management and Budget (OMB) Circulars A-110 and A-21 or Uniform Guidance 2 CFR 200). This policy applies to all University departments, units, faculty, staff and students.

Related Links

Cost Share for Equipment Policy

The complete policy and more can be found on the General Counsel’s web site.

Department Safety Committee Policy

1. PURPOSE
   This policy is developed to provide guidance to Department Safety Committees by establishing uniform administrative procedures and minimum requirements. It is the Department Safety Committee’s charge along with the Department of Environmental Health and Safety to provide the University Community with a safe and healthful work environment. It is also the intent of the Department Safety Committee to assure compliance with all University Safety Policies.
2. SCOPE OF POLICY
   1. Establishment of Committees
      While all departments are encouraged to have Safety Committees, departments designated by the Director of Environmental Health and Safety shall establish Department Safety Committees. A list of current department safety committees can be found at Environmental Health and Safety web site.
   2. Establishment of Contacts
      Department heads or his/her designee will serve as the Safety contact in all University departments who do not have safety committees. These contacts will receive communications from the Department of Environmental Health and Safety regarding safety issues and serve as the safety liaison for their department. A list of current department safety contacts can be found at Environmental Health and Safety web site.
   3. Membership
      Department heads shall appoint Safety Committee members and designate a Chairperson. The names of committee members shall be forwarded to the Director of Environmental Health and Safety each year by June 30. Terms shall be at the discretion of the Department Head.The Director of the Department of Environmental Health and Safety or their designee shall serve as an ex officio member on all Safety Committees.Department Safety Committee membership should, when applicable, include representatives of the professional staff, faculty, salaried staff, hourly employees and students.
   4. Meetings
      Department Safety Committees shall meet periodically at a frequency determined by the committee, but not less than four times per year. By June 30 each year Safety Committee Chairs shall communicate to the Director of Environmental Health and Safety the months in which meetings are planned for the next fiscal year. Minutes shall be recorded. Minutes should include members attending, members absent, disposition of old business and new business covering items identified under Minimum Requirements (section IV).
   5. Annual Report
      Individual departments shall submit an annual report of their committee’s activities to the Department of Environmental Health and Safety. The reports are to be submitted using the forms developed by Environmental Health and Safety which can be found at Environmental Health and Safety web site. These reports are due by June 30 for the previous year. A summary of these reports is presented to the Risk Management Advisory Council annually.

The complete policy and more can be found on the General Counsel’s web site.

Direct Charging Procedure

1. SCOPE OF PROCEDURE
   This procedure outlines University of Delaware (“UD” or “University”) requirements for allocating direct costs to sponsored projects, and applies to all University departments, units, faculty, staff and students involved in externally sponsored research.
2. DEFINITIONS
   1. Direct Costs – Costs which can be identified specifically with a particular sponsored project and which can be directly assigned to such activities, relatively easily and with a high degree of accuracy.
   2. Facilities & Administrative (F&A) Costs – Costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives.
   3. Cost Principles – Fundamental conditions for ensuring costs are permissible on a sponsored project, including:
      1. Allowability or Allowable – Costs must be permissible under the terms and conditions of the award, including the authorized budget and applicable regulations
      2. Allocability or Allocable – Costs must provide a sole benefit to the sponsored project or provide proportionately assignable benefits to the sponsored project.
      3. Reasonableness or Reasonable – Both the nature of the goods or services acquired and the amount paid must reflect the action that a prudent person would have taken at the time the decision to incur the cost was made.
      4. Consistency – Application of costs must be given consistent treatment within established University policies and procedures; costs for the same purpose must be treated and classified the same way under like circumstances.
   4. Allocation – The process of assigning a cost, or a group of costs, to one or more sponsored projects and/or cost objectives.
   5. Principal Investigator (“PI”) – The individual designated in a grant or contract to be responsible for ensuring compliance with the academic, scientific, technical, financial and administrative aspects and for day-to-day management of the sponsored project (grant or contract).
   6. Sponsored Projects – Externally-funded activities in which a formal written agreement (i.e., a grant, contract, or cooperative agreement) is entered between the University and the sponsor.
3. PROCEDURE STATEMENT
   The purpose of this procedure is to ensure University compliance with applicable cost principles and federal regulations set forth for allocating direct costs per Office of Management and Budget (OMB) Circular A-21 and Uniform Guidance 2 CFR 200. Key guidance under this procedure includes:
   • Direct costs must meet conditions for allocability, allowability, reasonableness and consistency established under federal regulations.
   • A cost is allocable to a sponsored project if the goods or services involved are chargeable or assignable to that sponsored project in accordance with relative benefits received.
4. STANDARDS AND PROCEDURES
   1. Direct vs. F&A Cost Considerations
      1. Uniform Guidance establishes principles to help determine the applicability of costs to federal grants, contracts, and other agreements. It prescribes which costs are allowable for recovery from the government and, of the allowable costs, whether the educational institution should treat them as direct or facilities & administrative (F&A) costs
      2. Common examples of F&A costs include:
         1. Administrative/Clerical Staff
         2. General Office Supplies/Equipment
         3. Postage
         4. Communications (ex. Cells Phones, Telephones, Internet)
         5. Facilities Operations & Maintenance
      3. Costs that are normally considered F&A costs may be allowable as direct costs if they meet all the following criteria:
         1. An unlike circumstance exists in which a sponsored project requires resources beyond those normally expected for a typical research project;
         2. The cost can be associated with the specific sponsored project with a high degree of accuracy;
         3. The costs are not also recovered as indirect costs; and
         4. The awarding agency has explicitly approved the cost as a direct expense in the awarded budget or per written prior approval.
      4. If costs that are normally considered F&A costs are allocated as direct costs to a sponsored project, but do not meet approval criteria per section (3)(d) above, sufficient supporting justification is required to ensure the costs are allowable on the sponsored project. Otherwise, the costs will be deemed unallowable and must be removed from the sponsored project. An after-the-fact explanation attesting to the benefit to the award is insufficient justification to treat these expenses as direct costs on federal awards.
   2. Direct Cost Allocation Methodologies
      1. Direct costs may be allocated only if they advance the work of the sponsored project(s) in the same proportion as the cost.
      2. Direct cost allocations on sponsored projects should not be based on budget, funding or availability of funds, as these factors are not evidence of the allocability of a cost.
      3. Direct Cost Allocation Principles:
         1. If a cost benefits one sponsored project, it should be charged in its entirety to the sponsored project.
         2. If a cost benefits two or more sponsored projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the sponsored projects based on the proportional benefit.
         3. If a cost benefits two or more sponsored projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then, notwithstanding paragraph (d) of this section, the costs may be allocated or transferred to benefitted sponsored projects on any reasonable documented basis.
         4. Where the purchase of equipment or other capital asset is specifically authorized under a federal award, the costs are assignable to the federal award regardless of the use that may be made of the equipment or other capital asset involved when it is no longer needed for the purpose for which it was originally required.
      4. Examples of Cost Allocation Methodologies:

      GENERALLY ACCEPTABLE
      Allocation Basis	Example
      Effort	A research assistant spends 80% effort on Project A and 20% effort on Project B. The research assistant uses supplies totaling $3,000/month on the two projects. Usage is directly related to the amount of effort devoted to each project, therefore, $2,400 (80% of $3,000) is charged to Project A and $600 (20% of $3,000) is charged to Project B.
      FTEs	There are 5 FTEs employed on Project A and 8.5 FTEs employed on project B.  These are the only two sponsored projects that are performed and managed in the lab, and the monthly supplies total $5,500.  Project A should be charged $2,037.04 (5/13.5 x $5,500) and Project B should be charged $3,462.96 (8.5/13.5 x $5,500).
      Usage	The monthly cost of supplies/expendables to maintain a lab computer system is $1,000. The computer system is used solely for projects A and B. The computer operating system keeps a log of users and their time on the system. A reasonable base to allocate the expense would be computer user hours. Project A assistants have 100 combined user hours a month and project B assistants have 80 combined user hours a month. The cost allocated to project A is $560 (100 user hrs. /180 total user hrs. x $1,000). The cost allocated to project B would be $440 (80 user hrs. /180 total user’s hrs. x $1,000).
      Number of Experiments	A PI uses syringes to conduct experiments on two of his research grants. The syringes are only good for one experiment and then they must be thrown away. The PI keeps a log of how many experiments are performed on each project per week. Syringes are ordered every two weeks at $1.05 per syringe. The log indicates the following: Project A: Week 1: 25 Experiments, Week 2: 39 Experiments Project B: Week 1: 19 Experiments, Week 2: 16 Experiments The total cost of the syringes is $103.95 (99 experiments x $1.05/syringe). Project A should be charged $67.20 (64 experiments x $1.05/syringe) and Project B should be charged $36.75 (35 experiments x $1.05/syringe).
      Square Footage	A student is paid a salary of $1,500 a month to clean glassware in two laboratories that are conducting similar research. In this example, the square footage of the laboratories could be used as a reasonable basis. Lab A is 1,600 square feet and Lab B is 1,200 square feet. Lab A is charged $855 (1,600-sq. ft/2,800 sq. ft x $1,500) and Lab B charged $645 (1,200-sq. ft/2,800 sq. ft x $1,500).
      Reasonable Determination without Undue Effort or Cost	The lab has two ongoing sponsored projects and purchases a $3,000 apparatus to be used equally on both projects, so both Project A and Project B are each charged $1,500 (50%).  Since Uniform Guidance allows for proportions to be determined without undue effort or cost, the supporting justification explaining the reasonable determination is generally acceptable.
      Other Quantitative Rationale	The PI provides a quantitative rationale that is both reasonable and adequately supported with documentation, whereby the total cost can be divided based on a percentage calculated using the quantitative rationale.

      GENERALLY QUESTIONALBE OR UNACCEPTABLE
      Allocation Basis	Example
      Restocking	Restocking materials and supplies is an acceptable practice only if the usage of materials and supplies is tracked or logged and included with the supporting documentation for the transaction. If the usage is not tracked or logged, it is infeasible to adequately support that restocking transactions are allocable to the sponsored project. If the usage is not included with the supporting documentation, there is insufficient support to determine that materials and supplies benefitted the sponsored project.
      Offset	Costs were charged to Project A one month, and the next month costs were charged to Project B to offset what should have been split allocations each month between the two projects.
      Available Funding	27% of costs were allocated to Project A to zero out the remaining available balance, and the remaining 73% of costs were allocated to Project B. An exception to this would be if the entire cost was allocable to the sponsored project, but a portion of the cost was allocated to non-sponsored project funding (ex., start-up funds).
      Unreasonable Determination without Undue Effort or Cost	The lab has three ongoing sponsored projects and purchases a $3,000 apparatus to be used on each project, so Project A is charged $1,350 (45%), Project B is charged $450 (15%), and Project C is charged is charged $1,200 (40%). This is generally an unreasonable determination without additional documentation to support the specific percentages selected for the split allocation.

   3. PI/Department Responsibilities
      1. Determine the appropriate allocation methodology to use to allocate direct costs consistent with the benefits received to each sponsored program.
      2. Maintain documentation supporting allocations and review/update the methodologies as necessary.
      3. Review sponsored research projects on a regular basis (at least monthly) to ensure that all direct costs charged are correct and appropriate.
      4. Ensure that all personnel engaged in financial administration of federally-funded sponsored projects are familiar with the University direct charging procedures.
   4. Research Office Responsibilities
      1. Develop and implement direct charging procedures in accordance with the regulations outlined in Uniform Guidance 2 CFR 200, Subpart E – Cost Principles.
      2. Assist in the interpretation and implementation of the direct charging procedures.
      3. Periodically review justifications and/or supporting documentation provided for direct cost allocations to sponsored programs to ensure documented adherence to the direct charging procedures.

Driver’s Requirements and Verification

1. PURPOSE
   To provide reasonable assurance that each individual who operates any motor vehicle on university business possesses a valid license of the appropriate classification and to minimize the University’s liability in motor vehicle accidents.

Questions pertaining to Driver’s Licensing and classification can be referred to the Delaware Division of Motor Vehicles.

Questions pertaining to insurance coverage can be referred to the Office of Risk Management, 302-831-2971.

Related Links

Drug/Alcohol Testing – Commercial Driver’s Licenses and Safety Sensitive Functions Web Policy

The complete policy and more can be found on the General Counsel’s web site.

Drug/Alcohol Testing – Commercial Driver’s Licenses and Safety Sensitive Functions

1. POLICY
   The University of Delaware recognizes the importance of safety protocols for employees operating University Commercial Motor Vehicles and other employees performing safety sensitive functions and intends to follow all laws, rules and regulations applicable to such activities through application of this policy.
2. SCOPE OF POLICY
   This policy applies to the Employees Subject to Testing and is intended to comply with the Omnibus Transportation Employee Testing Act of 1991 (“OTETA”) and in accordance with Title 49 Code of Federal Regulations, Part 382 and 391, Subpart H.

   Employees Subject to Testing – Full-time, part-time, miscellaneous wage, casual wage, temporary or seasonal employees, who possess a commercial driver’s license (CDL) with the intent of operating a University commercial motor vehicle (this includes any rented leased, or personal vehicle used as a requirement of their job function) requiring such license, as well as employees performing safety sensitive functions, are subject to testing. All Departments are required to advise the University’s Department of Transportation’s (DOT) On-site Coordinator of all employees required to possess a CDL, as a condition of employment.

Related Links

Driver’s Requirements and Verification Web Policy

The complete policy and more can be found on the General Counsel’s web site.

Effort Certification Procedures

Each department assigns an effort administrator who has the procedural responsibility to oversee the reports for that department.

A. Each department assigns an effort administrator who has the procedural responsibility to oversee the reports for that department.

B. Reports are required from every employee whose salary is either directly charged to a sponsored project or used as match/cost sharing for a sponsored project during a particular effort reporting period.

C. For faculty on academic contracts, there are three effort reporting periods. Period 1 includes effort provided during the fall semester of the academic year. Period 2 includes effort provided during the spring semester, and Period 3 includes summer research activity performed during the months of June through August. The following chart describes the three periods for academic faculty: Click to view the sample chart.

D. Following each reporting period, a web based electronic application will produce web views for review. This application will allow interaction (via web journal) to modify transactions through cost transfer submissions. Every certification must be reviewed by a designated Effort Administrator (each unit has one assigned staff member for this role) and the employee personally (unless that employee has terminated or retired from employment with the University in which case an employee with suitable means of verification evaluates effort in lieu of the particular employee). If an employee has an active HR status but is not capable of certifying their own report, the report may be completed by providing certifications (with suitable means of verification) from both the Effort Administrator and the Effort Manager or another Research Office

designee.

E. To facilitate accuracy in initial payroll allocations, the Labor Allocation Module (LAM) allows for timely changes made to an employee’s payroll distribution plan. A LAM calculator exists to assist in the accuracy of percentages to distribute.

F. It is expected that all certifications will be in “completed” status within 90 days of the end of the reporting period. Electronic copies are retained in the Research Office for the retention period required by the sponsored agreement, usually three years after the closeout or final payment of the project.

G. Email notification will be sent to effort administrators listing reports 40 days old in an effort to remind administrators of this responsibility. Notification of delinquent reports still outstanding beyond the 90 day certification period and again at 120 days past the last day of the effort certification period will escalate to the Department Chair, Assistant Dean and Dean. If any reports remain incomplete 150 days past the end of a reporting period, notification will be sent to the Associate Deputy Provost for Research Administration for review and action as necessary. If any reports remain incomplete 180 days past the end of a reporting period, notification will be sent to the Deputy Provost for Research & Scholarship for review and action as necessary. The effort administrator is responsible for completing these reports. Cost disallowances on sponsored projects resulting from the failure to complete an effort report will be removed from the sponsored project to a non-sponsored project.

H. In the event that an error was made during the routing process, the research office has the authority to create revised effort reports which must be completed within 30 days of release. These will be stamped with ‘[REVISION]’ so as to identify the report as such. In order to request a revision the effort administrator must have an adequate justification. Any changes must comply with all other UD policies and federal regulations.

University of Delaware Effort Certification Procedures

I. Routing is as follows:

a. Research Office creates the report (in batch three times annually, or one at a time as needed) (report is now in ‘UNSENT’ status)

b. Effort Administrator reviews and ‘forwards’ to employee (report is now in ‘IN PROGRESS’ status

c. Employee reviews and either clicks yes, I agree (‘review and certify’), or no I do not agree (‘forward’), and the system will require a comment stating what is wrong with the report. Either way it is routed back to the effort administrator.

d. Effort administrator selects ‘review and certify’ (if approved by employee in c.) or takes necessary action to correct the errors identified by the employee (if not approved in c.).

e. If approved in c and ‘review and certify’ in d., the system will set the certification report to ‘COMPLETE’status.

f. Once action is taken in step ‘d’, effort administrator will ‘forward’ back to the employee until the employee is satisfied that this report reflects the effort expended during that effort reporting period.

Revised July 2013

*If employee is terminated or otherwise incapable, someone with suitable means of verification may act as a substitute.Employee will REVIEW AND CERTIFYProxy* will REVIEW AND CERTIFY for otherwise incapable employeesEmployee supervisor * will REVIEW AND CERTIFY for Terminated employeesEA FORWARDS to Effort ManagerWith request for exceptionEffort Manager REVIEWS & CERTIFIES

Effort Certification Reporting

1. POLICY
   Certifications of Effort on Sponsored Projects are required for every University employee whose salary or wages are directly charged to a Sponsored Project account or whose salary or wages are used as cost sharing for a Sponsored Project. Individuals must account for 100 percent of activities which are part of their IBS.
2. SCOPE OF POLICY
   This policy addresses the University of Delaware (“UD” or “University”) obligation to ensure compliance with the applicable federal regulations, Office of Management and Budget (OMB) Circular A-21 requirements or Uniform Guidance 2 CFR 200, for effort reporting and applies to all University departments, units, faculty, staff and students.

Related Links

General Counsel Page for this Policy

The complete policy and more can be found on the General Counsel’s web site.

Emergency Management Policy

1. POLICY
   The State of Delaware can be threatened by emergency and disaster situations both natural, such as flash floods, hurricanes, winter storms and fires, and man-made, such as hazardous materials accidents, nuclear releases, civil disorders and terrorist threats.

   Because the University of Delaware differs in size, complexity, and function from public agencies in the State of Delaware and the County of New Castle, it is prudent for the University to develop an emergency management program of its own to focus on disaster preparedness, response, recovery and mitigation.

Questions related to this policy should be directed to: Executive Director of Campus and Public Safety

The complete policy and more can be found on the General Counsel’s web site.

Emergency Notification Policy

1. POLICY
   The University of Delaware is responsible for providing accurate and timely information to the campus community and the public during emergencies. The University is also responsible to students, faculty, and staff when they express concerns about personal safety and security, and consistent with University policies concerning the release of personal information. This Emergency Notification Policy specifies policies and procedures for facilitating the communication of critical emergency information. The policy utilizes the best science and technology available in order to ensure that the University can notify both University and other interested parties of an emergency and provide appropriate direction on how to avoid potential harm.
2. SCOPE OF PURPOSE
   The University’s approach to crisis incidents follows the Phases of Emergency Management as addressed in the full University Emergency Operations Plan (EOP) and Critical Incident Management Plan (CIMP). These documents can be found online at www.udel.edu/safety/plans.

The complete policy and more can be found on the General Counsel’s web site.

Emergency Response/Fire–Other Emergencies

1. SCOPE OF PURPOSE
   To establish uniform procedures throughout the University for the provision of reasonable life safety for employees, students, and guests of the University in case of a fire or other emergencies.

The complete policy and more can be found on the General Counsel’s web site.

Equipment Screening Policy

1. POLICY
   All proposed purchases of equipment using federal or federal flow-thru funds having a requisition cost of $5,000 or more are subject to the screening program to determine if like equipment exists on campus and is available for use.
2. SCOPE OF PURPOSE
   To meet Federal government requirements for the purchase of equipment funded in sponsored programs.

The authority to enforce this policy lies within the Procurement Services Department. Any questions may be directed to (302) 831- 2161 or procurement@udel.edu.

The complete policy and more can be found on the General Counsel’s web site.