3.10.4 Control of Sponsored Research/External Funds

Comprehensive Standard 3.10.4: Control of Sponsored Research/External Funds

The institution maintains financial control over externally funded or sponsored research and programs.

USF Sarasota-Manatee Focused Report Response

The University of South Florida Sarasota-Manatee (USF Sarasota-Manatee) maintains appropriate financial control over externally funded or sponsored research and programs as a member of the USF System. Research & Innovation is one of the shared USF System services that affords “an economy of scale” (Memorandum of Delegation, June 2009). The USF System Governance Policy, Attachment A, Section III, lists the responsibilities of the System Office of Research & Innovation and the responsibilities of the USF System institutions, including USF Sarasota-Manatee, as outlined below.

Research and Innovation: Develops and negotiates USF System research policies with agencies, foundations, and companies regarding USF System-wide research awards, in collaboration with member institutions/entities. Promotes and coordinates new initiatives, seeds interdisciplinary research and economic development opportunities, and engages in public-private partnerships both domestically and internationally. Provides leadership for development of policies for the USF Research Park and business incubators across the USF System. Provides assistance to faculty, staff, and students at all USF System institutions in locating research funding, preparing proposals, and training in research project administration, including assistance in developing intellectual property patents, licenses and start-up companies. Manages research integrity, compliance and animal facilities. Processes and monitors USF System research grants and contracts.

Each institution/entity is responsible for ensuring that faculty act in accord with the grant and contract award; disclosing new intellectual property and conflicts of interest; adhering to integrity and compliance policies; attending appropriate training; determining that all commitments included in grant and contract proposals submitted by faculty can be met by the institution/entity within available resources and facilities; processing and monitoring institution-based research grants and contracts.

At USF Sarasota-Manatee the primary person responsible for meeting the above institutional responsibilities under the USF System Governance Policy is the Regional Vice Chancellor for Academic & Student Affairs with support, as needed, in fiscal matters from the Regional Vice Chancellor for Business & Financial Affairs. Attached is an example of the Regional Vice Chancellor’s sign-off (Dr. Terry Osborn) on a Sponsored Research Proposal Authorization Form.

Among other functions, the USF System provides training, both in-person and online through TRAIN  (The Research Administration Improvement Network) for principal investigators and administrators at USF Sarasota-Manatee to ensure that they follow all current research administration policies and procedures and meet all federal and state compliance requirements. Meetings with principal investigators and college research administrators at all institutions within the USF System, including USF Sarasota-Manatee, ensure that the applicable research compliance requirements are conveyed and followed. As a recipient of Federal research funds, the USF System certifies periodically the percentage of effort spent on research projects. The USF System, including USF Sarasota-Manatee, uses the PeopleSoft Global Employment System (GEMS) module for recording, monitoring, and reporting time and effort certifications on a semester basis.

The USF System maintains the following policies regarding externally funded and sponsored research:

USF System Policy Policy #
 Administration of Sponsored Research Subagreements  USF Policy 0-302
 Research and Research Grants  USF Policy 0-304
 Individual Conflicts of Interest in USF System Research Projects  USF Policy 0-309
 Sponsored Research Cost Sharing  USF Policy 0-313
 Financial Closeout of Fixed-price Sponsored Award Agreements  USF Policy 0-314
 Export Control Compliance  USF Policy 0-316

A list of recent grants at USF Sarasota-Manatee is contained in the USF Sarasota-Manatee Grant Report.

Off-Site Committee Report – Non-Compliance

The Compliance Certification states that “The University of South Florida Sarasota-Manatee (USF Sarasota-Manatee) maintains financial control over externally funded or sponsored research and programs as a joint responsibility of the Regional Vice Chancellor for Academic and Student Affairs and the Regional Vice Chancellor for Business and Financial Affairs.”  However, all narrative, documentation and discussion is related to the USF System with no connection to the USF S-M campus. The Off Site Committee could not identify any sponsored activity.


USF Sarasota-Manatee’s original submission narrative is shown below.
  

Compliance Partial Compliance Non-compliance

NARRATIVE

The University of South Florida Sarasota-Manatee (USF Sarasota-Manatee) maintains financial control over externally funded or sponsored research and programs as a joint responsibility of the Regional Vice Chancellor for Academic and Student Affairs and the Regional Vice Chancellor for Business and Financial Affairs.

USF System Office of Research & Innovation

The USF System Office of Research & Innovation is under the authority of the Senior Vice President for Research, who is selected by and reports directly to the USF System President. The Senior Vice President has been officially delegated authority by the USF System President to serve as the Institutional Official in matters of research, research compliance, and the protection of intellectual property. The Senior Vice President for Research & Innovation is responsible for overseeing the application of research policies and procedures and the management of external programs and research funds. Financial control of externally funded sponsored research projects is the joint responsibility of the Senior Vice President for Research and the Senior Vice President & Chief Financial Officer.

USF System Division of Sponsored Research

The USF System Division of Sponsored Research  is responsible for the development and pre-award administration of sponsored research activities at all USF System campuses, including coordination and management of external and internal contracts and grants, interdisciplinary research programs, and inter- and intro-institutional proposals and contracts. A Sponsored Research Administrator, who reports to the Division of Sponsored Research on the USF Tampa campus, has been assigned to support USF Sarasota-Manatee. This Administrator provides support to USF Sarasota-Manatee researchers who are searching for grant opportunities; applying for support from local, state, and federal agencies; and implementing and evaluating sponsored research projects.  Additionally, the Division provides post-award financial services in support of USF System sponsored research awards and activities, including the necessary budgetary and financial controls, monitoring, and oversight to ensure the integrity and continued success of the research program.

USF System Office of Research Financial Management

The USF System Office of Research Financial Management provides post-award financial services in support of USF sponsored research awards and activities. This unit provides the necessary budgetary and financial controls, monitoring, and oversight to ensure the integrity and continued success of the research program. The responsibilities of Research Financial Management include new award set-up, internal and external grant and contract monitoring, cost-sharing facilitation, effort-reporting coordination, billing notices, financial report development and submission, final award closeout, Facilities and Administrative (F&A) recovery reconciliation, reporting, audit coordination, and coordination of the federal F&A Cost Study.

Policies and Procedures

The USF System Office Research & Innovation Policies and Procedures adhere to and promote compliance with federal regulations that govern the use of external funds according to the requirements of the Office of Management and Budget Circular A-21, Cost Principles of Educational Institutions, as evidenced by the University’s approved Cost Accounting Standards Board (CASB) Disclosure Statement. As a recipient of federal research funds, the USF System is required to certify periodically the percentage of effort spent on research projects. This process is described in  Clarification or Change in Procedure #020: Monitoring Effort for Federal Sponsored Awards, Research. The USF System uses a PeopleSoft GEMS module for recording, monitoring, and reporting time and effort certifications on a semester basis. Personnel in Research Financial Management are dedicated to this process.

External sponsors impose a variety of reporting requirements with which the USF System must comply as part of the terms and conditions of a grant or contract and subcontracts. USF System policies supply the infrastructure for oversight and compliance with agency reporting requirements. USF System Policy 0-100, Authority to Sign Contracts and Other Documents, provides clear guidelines regarding the authority to sign contracts, agreements, letters of understanding, and other documents regarding legal assurances, commitments, and obligations on behalf of the USF System and its constituent units (colleges, departments, programs, etc.).

In addition to the official USF System policies, Research & Innovation Policies and Procedures are posted on the webpage of the Office of Research & Innovation to provide guidance for extra compensation, gifts and sponsored research funding, tuition payments, etc.

Training

The Division of Sponsored Research provides training for research administrators and principal investigators through The Research Administration Improvement Network (TRAIN). TRAIN maintains online resources for faculty, staff, and students.

SUPPORTING DOCUMENTATION AND EVIDENCE

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