Forms, Policies & Procedures

Protection of Potable Water Supply

1. SCOPE OF PURPOSE
   To ensure potable water supply systems are designed, installed, maintained and utilized in such a manner as to prevent contamination from nonpotable liquids, solids or gases.
2. POLICY

   Potable water supply system shall be designed, installed and maintained in such a manner as to prevent contamination from nonpotable liquids, solids or gases being introduced into the potable water supply through cross-connections or any other piping connections to the system. The Facilities Planning and Construction Department shall ensure new facilities and renovations comply with the requirements of The IBC Plumbing Code or the latest plumbing code adopted by the City of Newark. The Facilities Management Department shall ensure facilities are maintained in accordance with this code. …

For more information regarding this policy and backflow prevention contact the Facilities Management Department or the Department of Environmental Health and Safety.

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

Radioactive Material and Machines Capable of Producing Ionizing Radiation

1. SCOPE OF PURPOSE
   To ensure all activities related to sources of ionizing radiation are conducted in compliance with U.S. Nuclear Regulatory Commission regulations and license conditions, Delaware Radiation Control Regulations, and University Regulations.

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

Record Retention Procedure

1. SCOPE OF PROCEDURE
   This procedure outlines record retention responsibilities of Principal Investigators (PIs), Department/College Administrators, Research Office Pre-Award and Post-Award Teams, and other responsible parties involved in the administration of sponsored programs.

   All University faculty and staff who are responsible for administering externally sponsored grants and contracts should be familiar with this procedure.

2. DEFINITIONS
   1. Sponsor or Sponsoring Agency – An external entity responsible for providing project funding if UD’s proposal is accepted and an official award agreement is subsequently executed.
   2. Record – Documentation pertinent to the programmatic and financial management of an externally-sponsored award.
   3. Record Retention Period – The required amount of time for which records must be maintained for a particular externally-sponsored award.
3. PROCEDURE STATEMENT
   The purpose of the Research Office Record Retention Procedure is to ensure record retention and destruction for sponsored programs is conducted in accordance with UD, federal, and sponsor requirements. This mitigates potential UD financial and compliance risk by:
   • Ensuring UD’s ability to provide adequate support documentation to internal parties and authorized external entities when appropriate, especially during audit activities.
   • Establishing a limited time period for record retention, thereby mitigating UD exposure to late audit requests or potential information breaches by unauthorized external entities.

   It is the procedure of the University of Delaware (UD) to retain and dispose of documentation associated with sponsored programs in accordance with applicable sponsor requirements, as well as federal regulations per Uniform Guidance including:

   • §200.333 Retention Requirements for Records
   • §200.334 Requests for Transfer of Records
   • §200.335 Methods for Collection, Transmission, and Storage of Information
   • §200.336 Access to Records
4. STANDARDS AND PROCEDURES
   1. PIs, Department/College Administrators, and Research Office employees are responsible for retaining award records for sponsored programs. This includes financial records, supporting documents, statistical records, and other UD records pertinent to the award. Records must be maintained for active awards and archived for expired awards based upon standards outlined in this procedure.
   2. UD is obligated to provide authorized external parties (such as sponsors or auditors) with access to award records and documentation for the purpose of audits, examinations, excerpts, and transcripts. This includes timely and reasonable access to UD personnel for the purpose of interview and discussion related to such documents. Inability of UD to provide necessary records to sponsors or other authorized parties upon request may result in adverse financial or compliance impacts, such as potential disallowance of unsupported project costs
   3. It is the preference of UD (and federal sponsors) that award records be maintained in electronic rather than paper formats when practicable. Copies of original records, either in paper or electronic format, may be substituted for original records, so long as they remain unaltered and readable.
   4. D. PIs, Department/College Administrators, and Research Office employees are responsible for maintaining primary support documentation for sponsored programs in local Shared Drives as well as other electronic systems. The table below outlines common award records and storage methods maintained under this procedure:

   STORAGE METHODS FOR AWARD DOCUMENTATION
   Document Type	Storage Method
   Proposal Documentation submitted to the sponsor such as budgets, budget justifications, scope of work, subaward documents, abstracts, etc.	PeopleSoft Attachments Cayuse Webforms (Proposal Approvals) Local Shared Drives Sponsor Web-Based Portals (ex: Proposal Submissions)
   Official Award Notices and contractual documents issued to UD from the sponsor.	PeopleSoft Attachments Local Shared Drives Sponsor Web-Based Portals (ex: Grants Management)
   Programmatic Support Documents pertinent to the award administration including detailed budgets, institutional approvals, and important correspondence.	PeopleSoft Attachments Local Shared Drives Webforms (ex: Proposal Approvals, Budget Adjustments)
   Financial Reports and Invoices submitted to the sponsor to report expenditures and/or request payment.	PeopleSoft Attachments Local Shared Drives Sponsor Web-Based Portals (ex: Federal Financial Reports, Payment Management Systems)
   Financial Backup supporting award expenditures and reporting such as account reconciliations, receipts, cost transfer forms, and expense approvals.	PeopleSoft Attachments Local Shared Drives Webforms (ex: Automated Closeout Reports, Journal Vouchers, Cost Transfers, Purchase Orders) Concur/Works (ex: Expense Approvals) Effort Reporting System
   Technical Reports and Deliverables submitted to the sponsor to report research program outcomes.	Local Shared Drives Sponsor Web-Based Portals (ex: Technical Reports) Webforms (ex: Automated Closeout Reports)
   Compliance Protocols and approvals related to sponsored research programs (e.g. human and animal subjects).	IRBNet (ex: IRB/IACUC Protocols) Local Shared Drives

   5. Records should be disposed of upon expiration of the required record retention period for an award in order to limit excess audit risk and potential information breaches to UD. Unless a longer duration is required by the sponsor, or per other exceptions outlined in the table below, it is UD’s procedure to retain records for four years after an award’s end date. Destruction of such records should follow UD protocols to ensure they are no longer needed for reference.

   EXCEPTIONS TO THE STANDARD FOUR-YEAR RECORD RETENTION PERIOD
   Exception Scenario	Retention Period	Exception Description
   Sponsor or Award Specific Retention Period	Per Sponsor Requirements	Retention requirements may vary depending on award guidelines, terms, and conditions set by the sponsor. These may be stricter than the standard four-year retention period and will be evaluated on a case by case basis. PIs and their Department/College Administrators should contact the Research Office with any questions regarding the specific record retention requirements applicable to their award.
   Litigation, Claim, or Audit	Until Resolution	If any litigation, claim, or audit is started before the expiration of the four-year period, the records shall be retained until all litigation, claims or audit findings involving the records have been resolved and final action has been taken.
   Written Notice for Extension	Per Written Notice	UD will comply with any official written notice by a Federal sponsor, cognizant agency for audit, oversight agency for audit, cognizant agency for indirect costs, or pass-through entity to extend the record retention period.
   Final Financial Report Submitted ≥1 Year After the Award End Date	3 Years After Final Financial Report Submissions	If under rare circumstances, the final financial report was submitted or revised ≥1 year past the award’s expiration date, the award will be retained for 3 years after the final financial report was submitted to the sponsor.
   Real Property and Equipment	3 Years After Final Disposition	Records for real property and equipment acquired with Federal funds must be retained for three years after final disposition.
   Records Transferred	Not Applicable to UD	When records are transferred to or maintained by a Federal sponsor or pass-through entity, the record retention requirement is not applicable to UD.
   Program Income Transactions	3 Years After the Applicable Fiscal Year End Date	In some cases, UD must report program income after the period of performance. When this requirement exists, the retention period for the records pertaining to the earning of the program income starts from the end of UD’s fiscal year in which the program income is earned..
   Facilities and Administrative Cost Rate Proposals	3 Years After the Date of Proposal Submission, or 3 Years After the Applicable Fiscal Year End Date	For facilities and administrative cost rate computations or proposals, cost allocation plans, and any similar accounting computations of the rate at which a particular group of costs is chargeable (such as computer usage chargeback rates or composite fringe benefit rates): If submitted for negotiation, a three-year retention period for supporting records starts from the date of such submission. If not submitted for negotiation, a three-year retention period starts from the end of the fiscal year covered.

Refrigeration Units

1. SCOPE OF PURPOSE
   To outline the University’s policy regulating the purchase and use of refrigeration units utilized in laboratory, research or other risk areas. The purchase of refrigeration units used exclusively for the refrigeration of items intended for human consumption are not included in this policy.

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

Registered University Trademarks and Service Marks

1. POLICY
   The University reserves the right of proprietorship of a number of symbols of identification of the University used in connection with a variety of consumer goods or services related to athletic, business, and educational events or activities of the University. These trademarks and service marks, in the form of emblems and logos, are registered with the State of Delaware and/or the United States Federal Trademark and Patent Office. Original documentation for each mark is on file in the University Archives and copies are maintained in the Office of the University Secretary 126 Hullihen Hall.
2. The use of University trademarks and service marks is prohibited without the express permission of the University of Delaware. All inquiries should be directed to the Office of Communications and Public Affairs.
3. University employees are directed to the UD Brand Style Guide for further information about use of the registered University marks.

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

Removal of Dangerous Material

1. SCOPE OF PURPOSE
   To protect the health and safety of individuals when dangerous materials which could present an imminent danger to life and health are found in University buildings. …

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

Research Misconduct

1. SCOPE OF PURPOSE
   The Federal Office of Science and Technology Policy (OSTP) defines research misconduct as “fabrication, falsification, plagiarism, or other practices that seriously deviate from those that are commonly accepted within the scientific community for proposing, performing, or reporting research results.” It is the policy of the University of Delaware to abide by the OSTP policy in all University research. Any intentional distortion of research data or intentional distortions of information or conclusions derived from research data constitutes misconduct in research and is prohibited by University Policy. …

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

Research Office Accounts Receivable Monitoring, Collections and Write-offs Procedure

1. OVERVIEW
   The University of Delaware is responsible for requesting and collecting funds related to externally sponsored grants and contracts. Ensuring timely receipt of these funds is an important function of the Research Office Billing Team in close coordination with Principal Investigators (PIs), Department/College Administrators, other central administrative offices, and sponsors.

   The Research Office Billing Team completes billing and collections activities for sponsored research programs. These activities are conducted in accordance with sponsor payment terms set forth in contractual agreements. Contractual payment terms generally require the University to submit invoices or cash drawdowns for payment by the sponsor. While the University receives most sponsor payments reliably, there are scenarios which may place receivables at-risk for nonpayment. Common scenarios which require extra attention from the Research Office include:

   • Issues or questions identified with a submitted invoice. Such instances typically require support documentation or a revised invoice be provided to the sponsor.
   • Incorrect or outdated sponsor billing contacts and/or address information. Such instances require follow-up to ensure invoices reach the correct sponsor contact/office for payment.
   • Unwillingness or inability of a sponsor to fulfill their obligation to pay the University in accordance with contractual payment terms. Such instances require internal escalation and may result in a stop work order depending on risk factors involved.

   The goal of this procedure is to minimize financial loss resulting from uncollectible accounts receivables for sponsored research programs at the University. As such, this procedure sets forth guidance for the Research Office Billing Team to proactively:

   • Monitor and collect outstanding accounts receivables in a consistent, timely manner.
   • Write-off accounts receivables balances deemed uncollectible by the University.
2. DEFINITIONS
   1. Invoice or Cash Drawdown: A formal billing statement requesting a sponsor pay the University in accordance with contractual payment terms.
   2. Accounts Receivables (AR): A monetary balance owed to the University by means of an invoice or cash drawdown. Any unpaid accounts receivables are considered “outstanding”.
   3. AR Aging Report: A list of outstanding accounts receivables categorized by age (total days old) in the University’s financial system. Regular AR aging reports are generated for review:
      1. Monthly for the Research Office Billing Team
      2. Quarterly for the Research Office and Finance
      3. Semi-Annually for the Board of Trustees Finance Committee
   4. AR Monitoring: Administrative activity related to regular review and tracking of outstanding accounts receivables.
   5. Dunning Letter: A formal notice sent to the sponsor requesting payment for outstanding accounts receivables.
   6. Uncollectible AR Balances: Outstanding accounts receivables balances which have virtually no chance of being paid by the sponsor.
      1. The University designates balances as uncollectible after thorough collections efforts have made without receipt of payment from the sponsor.
   7. AR Write-Off: The process of removing uncollectible AR balances from University financials.
3. RESPONSIBLE PARTIES
   All University faculty and staff who are responsible for administering externally sponsored grants and contracts should be familiar with this procedure.

   The Research Office Billing Team (Billing Coordinators and the Assistant Director of Billing and Receivables) manages billing, collections, and write-off activities for all sponsored projects in close coordination with other central offices, PIs, and departments/colleges. Specific roles and responsibilities are outlined in the matrix below:

    

   Accounts Receivable Monitoring, Collections, and Write-offs Procedure	Responsible Party P = Primary, S = Secondary, O = Oversight, I = Input
   	Research Office		Departments/Colleges
   Action	Billing Coordinators	Assistant Director of Billing and Receivables	Department/ College Administrators	Principal Investigators
   Complete invoices and cash drawdowns per payment terms in the award agreement	P	P, O	I	I
   Monitor outstanding accounts receivables via the AR Aging Report	S	P	I	I
   Follow-up with sponsors to determine payment status of outstanding AR	P	S, O	S	I
   Send Dunning Letter(s) to request payment from sponsors for outstanding AR	P	S, O	I	I
   Escalate outstanding AR to other individuals (ex: AVP Research Administration, Deans, General Counsel, Finance)	S	P	I	I
   Complete write-offs for uncollectible AR balances in coordination with other central offices/leadership	I	P	I	I

    

4. PROCEDURE GUIDANCE
   Accounts receivables monitoring, collections, and write-off activities will occur per steps outlined in the timeline below, based on the aging category of outstanding receivables. It is critical that communications from the Research Office, PIs, and departments/colleges be both timely and consistent with the steps below to realize high collection rates and maintain a positive working relationship with the sponsor. Below is a standard timeline to guide these activities:

    

   Aging Category	Collection Resolution Steps
   30 days Current AR	No collections action is required for AR items outstanding for 30-days or less, as these are considered current by the University.
   31-90 days Billing Coordinator Follows-Up via Email	Billing Coordinators will: Include past due amounts on subsequent invoices. Request the sponsor provide payment status for all outstanding AR items when submitting subsequent invoices for payment. Document collections efforts and sponsor correspondence via receivables comments in the University Financial System. The Assistant Director of Billing and Receivables will: Review outstanding AR collections via the monthly AR Aging Report.
   91-120 days Billing Coordinator Follows-Up via Email, Phone, and Dunning Letter	Billing Coordinators will: Include past due amounts on subsequent invoices. Request the sponsor provide payment status for all outstanding AR items when submitting subsequent invoices for payment. Take additional steps to contact the sponsor via phone calls, follow-up emails, and other contact points. If 2-4 weeks pass by and no response is received regarding outstanding items, issue a Dunning Letter to formally request sponsor payment. Document collections efforts and sponsor correspondence via receivables comments in the University Financial System. The Assistant Director of Billing and Receivables will: Review outstanding AR collections via the monthly AR Aging Report.
   121-180 days Billing Coordinator Follows-Up via Email and Escalates Items to the PI and Department/College Administrator	Billing Coordinators will: Include past due amounts on subsequent invoices. Request the sponsor provide payment status for all outstanding AR items when submitting subsequent invoices for payment. Alert the PI and Department/College Administrator of unsuccessful collections efforts. Request them to contact the sponsor for resolution. Document collections efforts and sponsor correspondence via receivables comments in the University Financial System. The PI and/or Department/College Administrator will: Contact the sponsor to request payment status of outstanding AR and copy the Billing Coordinator. Notify the Billing Coordinator of any other attempted correspondence and/or resulting information obtained. The Assistant Director of Billing and Receivables will: Review outstanding AR collections via the monthly AR Aging Report.
   181-365 days Billing Coordinator Follows-Up via Email; Assistant Director Escalates Items to the AVP Research Administration and consults University General Counsel	Billing Coordinators will: Include past due amounts on subsequent invoices. Request the sponsor provide payment status for all outstanding AR items when submitting subsequent invoices for payment. Document collections efforts and sponsor correspondence via receivables comments in the University Financial System. The Assistant Director of Billing and Receivables will: Review collections and outstanding receivables via the monthly AR Aging Report. Alert the PI, Department/College Administrator, College Business Officer, Dean, and AVP Research Administration, and Finance of unsuccessful collections efforts. Coordinate with appropriate parties to determine if work should continue based on financial risk. Consult with University General Counsel to determine legal recourse if deemed necessary.
   >365 days Assistant Director Escalates to Dean, AVP Research Administration, and Finance; University Determines Write-Offs for Uncollectible Balances	The Assistant Director of Billing and Receivables will: Review collections and outstanding receivables via the monthly AR Aging Report. Alert the PI, Department/College Administrator, College Business Officer, Dean, AVP Research Administration, and Director of Cost Accounting of unsuccessful collections efforts. Coordinate with appropriate parties to determine if outstanding AR balances are uncollectible. If all collections efforts fail, including applicable legal recourse, the AR balance will be deemed uncollectible and be written off by the University. All write-offs must be approved by both the Research Office and Finance prior to processing.

5. ADDITIONAL SCENARIOS

   Below are additional scenarios requiring actions outside of the above standard timeline:

   1. Sponsor Refusal to Pay Due to Identified Billing Issues: The sponsor may refuse payment due to a billing issue, such as unallowable costs included, additional backup required, and/or format updates needed for an invoice. In these instances:
      1. The Billing Coordinator will work to resolve any billing errors via a revised invoice and/or provide additional backup detail to the sponsor.
   2. Sponsor Refusal to Pay Due to Inadequate Work Performance: The sponsor may refuse payment due to inadequate work performance (pending deliverables, reports, and other technical functions for which the University is contractually obligated). In these instances:
      1. The Billing Coordinator will notify the Assistant Director of Billing and Receivables and request the PI and Department/College Administrator reach a resolution with the sponsor within 2-weeks time:
         1. If resolution is not reached in 2-weeks, the Billing Coordinator will send a reminder to the PI and Department/College Administrator.
         2. ii. If resolution is not reached in 4-weeks, the Billing Coordinator will send a reminder to the PI and Department/College Administrator, copying the PI’s Chair, Dean and/or College Business Officer.
      2. Depending on risk factors involved, a meeting may be scheduled with the AVP Research Administration and other appropriate parties to discuss whether work should continue.
   3. Sponsor Refusal to Pay Due to Unwillingness/Inability: If a sponsor refuses to pay due to their belief that the receivable is not their obligation, or due to their inability to pay, the PI and Assistant Director of Billing and Receivables should be notified immediately.
      1. The Assistant Director of Billing and Receivables will escalate the situation to the AVP Research Administration and appropriate parties will review the validity of the claim, determine whether additional work should continue based on applicable risk factors, and consult with University General Counsel for legal recourse.
      2. If a sponsor has defaulted on a debt, the AVP Research Administration will consult with the VP Research, Innovation, and Scholarship to determine if further contract assignments should be accepted by the University.
      3. A stop work order may be issued based on University review of risk factors involved.
         If the PI continues work after issuance of a stop work order, the PI and his/her department will become wholly responsible for all additional deficits that occur after the date of the stop work order.

Residual Balance Transfer

1. POLICY

   The Residual Balance policy sets forth the final disposition of residual balances on Fixed-Price, Fixed-Rate, and Non-Refundable grants and contracts at the University of Delaware (UD) in which no designation was made by the sponsor as to the use of any unexpended balance.

   This policy sets forth the requirements for justification, approval, and management of unexpended balances for Fixed-Price, Fixed-Rate or Non-Refundable contracts. If assurances and justifications are provided per this policy, an unexpended balance may be transferred to the appropriate residual account defined by the administering department.

   Residual balances will be distributed proportionately between direct costs and F&A costs, with the direct cost amount being transferred to the administering department. The F&A costs will be transferred to the Central F&A pool.

   All residual balance requests require a Residual Balance Transfer form be completed and submitted to the Research Office for processing.

Related Links

• Residual Balance Transfer Form

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

Residual Balance Transfer Request Form

Use this form if a residual funding balance remains on a fixed-price sponsored program after all allocable direct and F&A costs have been charged, the PI may use this form to request the residual amount be transferred to a non-sponsored departmental account per the Residual Balance Policy. Residual balances will be distributed proportionately between direct costs and F&A costs, with the direct cost amount being transferred to the administering department. Email completed forms to your Sponsored Research Accountant for final Research Office approvals and processing.

Related Links

• Residual Balance Transfer Policy

Respiratory Protection

1. SCOPE OF PURPOSE
   To establish uniform administrative procedures and minimum requirements related to respiratory protection. …

N.B. As used in this Policy the term employee includes students.

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

Safe Use and Storage of Compressed Gas Cylinders

1. PURPOSE
   To establish a policy on safe use and storage of compressed gas cylinders.
2. POLICY
   To implement a safety policy on the use and storage of compressed gas cylinders so as to reduce the risk to students, staff, faculty, and the general public. To ensure the safe handling and storage of compressed gas cylinders at the University, the following rules shall be followed: …

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