Forms, Policies & Procedures

Here you will find a repository of forms, policies and procedures related to research at the University of Delaware. This repository draws on sources throughout campus to provide quick and easy access to these resources in a variety of formats, such as html, MSWord and Adobe PDF. We encourage you to explore and use the tools provided to narrow your search by word, resource type or category in order to learn more about the content that governs research at UD.
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RO Forms, Policies, and Procedures Search 2019
Forms, Policies and Procedures (2 Procedures Entries)
Procedure: Contracts and Grant Management, Research Administration
Direct Charging Procedure
Procedure

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:
      5. 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.

 

Procedure Details:

OWNER: UD Research Office

RESPONSIBLE OFFICE: UD Research Office

ORIGINATION DATE: February 7, 2020

Procedure Source Share



Procedure: Contracts and Grant Management, Research Administration
Record Retention Procedure
Procedure

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:
    5. 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
    6. 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.
    7. 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.

 

Procedure Details:

OWNER: UD Research Office

RESPONSIBLE OFFICE: UD Research Office

ORIGINATION DATE: February 7, 2020

Procedure Source Share



ASSISTANCE

Compliance Hotline
Phone: (302) 831-2792

UD Research Office
210 Hullihen Hall
Newark, DE 19716
Phone: (302) 831-2136
Fax: (302) 831-2828
Contact us

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