Policies and procedures are developed to maintain meaningful compliance and grant oversight for NU and all faculty and staff, thus limiting exposure to legal liability and improving the efficiency and impact of programs and services funded through externally sponsored projects. Relevant grant policies are excerpted below for quick reference, organized under pre-award, post-award, and research policies. Complete, updated policies can be found in the NU Policy and Procedures Manual and should be reviewed early in the proposal process.
Office of Sponsored Programs & Research (OSPR)
OSPR@nu.edu
Authorized Organizational Representative
Purpose
The purpose of this policy is to define Northcentral University's Authorized Organizational Representatives for all grants and sponsored projects.
Policy
The Office of Grants and Sponsored Projects (OGSP) is a designated signatory for all proposals submitted on behalf of the University at the time of application submission that have been approved and authorized by the University President, Legal Counsel, and Board of Trustees.
The Authorized Organizational Representative with authority to sign grant proposals, grant awards, and grant-related contracts on behalf of Northcentral University resides with the University President, Provost, Vice Provost, Associate Dean of Graduate Studies, and Chief Financial Officer.
Eligibility to Apply for Externally Sponsored Projects
Purpose
The purpose of this policy is to define Northcentral University’s expectations for staff and faculty eligibility for involvement with externally sponsored projects.
Policy
A Principal Investigator/Project Director on a grant received by Northcentral University must serve in one of the following roles at the university:
All the above university employees must have the approval of their supervisor in order to serve as a Principal Investigator/Project Director. Furthermore, all applicants must meet eligibility requirements and submission limits of the specific opportunity and/or sponsor.
Grant Submission
Purpose
The purpose of this policy is to define Northcentral University’s grant submission procedure for team members.
Policy
All externally sponsored project applications will be submitted through NU’s Office of Grants and Sponsored Projects (OGSP). The OGSP designated grant administrator has authority to review, approve, and sign grant applications at the time of application. Federally funded grant applications will always be submitted through the OGSP. In this submission situation, the OGSP will manage all aspects of the electronic submission.
Submissions prepared for state, foundation, and private corporations will be determined by the OGSP working closely with the PI/PD. The OGSP will be responsible for all submissions unless otherwise expressed by the funding agency or decided upon by the OGSP. PI/PDs are not authorized to submit proposals on behalf of the University without approval from the OGSP.
PI/PDs shall ensure all final proposal documents are provided to the OGSP ten (10) business days prior to the application deadline.
Indirect Cost Policy
Purpose
This policy outline NU's procedures for calculating and identifying facilities and administrative costs for federal and non-federal grant budgets.
Policy
Indirect costs, also known as facilities and administrative costs (F&A costs), are the institutional or infrastructure costs of managing and running programs that cannot be directly attributed to a program or activity. The indirect cost rate reimburses the college for that fraction of its indirect costs that the granting agency agrees to bear.
Procedure
Federal agencies require colleges and universities to use indirect cost rates negotiated with a government entity. This is referred to as a federally negotiated indirect cost rate agreement, or NICRA. Because NU has not yet negotiated for a federally negotiated indirect cost rate, a 10% de minimis indirect cost rate will be used with all federal agencies.
For all other grant budgets, NU will apply a 10% indirect rate or the highest amount allowed for requests to non-federal agencies that permit indirect cost recovery. Keep in mind many non-federal agencies do not allow for indirect costs.
File Retention
Purpose
The purpose of this policy is to define Northcentral University's grant file retention process and to ensure records and documents are adequately protected and maintained.
Policy
The purpose of file management is to ensure compliance with funding agencies, limit exposure to legal liability, and maintain institutional record of NU sponsored activities and projects. In accordance with federal policy regarding file retention, the University maintains programmatic files for a term of five (5) years; and will comply with each funder’s file retention term requirement as necessary. If any litigation, claim, or audit is started prior to the standard retention period, records shall be retained until all litigation, claims, or audits have been resolved.
The PI/PD providing project oversight shall ensure all required files are provided to the Office of Grants and Sponsored Projects for accurate and appropriate file maintenance. A master file for each University grant transaction shall be maintained by the Office of Grants and Sponsored Projects. Records will be adequately protected against loss or other damage.
Required grant documents maintained in NU master file
Acceptance of an Award/Notice of Award
Purpose
The purpose of this policy is to define Northcentral University's process after receipt of a Notice of Award.
Policy
In the event an award is received from a funding agency, it is the responsibility of the Principal Investigator or Project Director (PI/PD) to ensure the Notice of Award is received by the Office of Grants and Sponsored Projects (OGSP) within two (2) days of receipt to ensure a timely response from the University.
A representative from the OGSP shall consult with the assigned PI/PD to review award details and identify any special conditions that may need to be addressed prior to acceptance. The OGSP shall route the grant award package to NU authorized designees for signature, approval, and return a signed copy to the funding agency, the PI/PD, and a copy to be retained on file in the OGSP.
Project Close-Out
Purpose
The purpose of this policy is to define Northcentral University's Grant Close-Out process and responsibilities for faculty and staff.
Policy
Beginning at least ninety (90) days prior to the end of the grant term, the project principal investigator or project director shall alert the Accounting Department and OGSP of the impending closeout referencing the specific grant title, award/contract number, and budget object code. This action officially notifies relevant internal departments and begins the process of closeout, whereby the PI/PD, OGSP, and Accounting will collaborate to ensure all requirements and deliverables are met according to the terms and conditions of the sponsored award.
Time and Effort Reporting
Purpose
The purpose of this policy is to ensure compliance with federal regulatory requirements for compensation for personal services per 2 CFR Chapter II Part 200 Subpart E §200.430 of the Uniform Guidance.
Policy
Northcentral University is required to document work performed by professorial and professional staff on externally sponsored activities per federal regulations (2 CFR Part 200.430). In accordance with federal guidelines, NU's time and effort reporting forms track the percentage of distribution of activities totaling 100% of the employee's work effort during the time period reported. In the use of any methods for apportioning salaries, it is recognized that, in an academic setting, teaching, research, service, and administration are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate. However, the reporter should make the best effort to present a reasonable account for all of the activities for which the employee is compensated. NU uses after-the-fact activity records as its method to document time and effort.
NOTE: Failure to track time and effort is often the primary cause for repayment of federal funds.
Responsible Conduct of Research
Purpose
The purpose of this policy is to describe National Science Foundation (NSF) and National Institutes of Health (NIH) requirements regarding responsible conduct of research.
Policy
In 2007, Congress passed the America COMPETES (Creating Opportunities to Meaningfully Promote Excellence in Technology, Education, and Science) Act, which required that "each institution that applies for financial assistance from the National Science Foundation (NSF) for science and engineering research or education describe in its grant proposal a plan to provide appropriate training and oversight in the responsible and ethical conduct of research to undergraduate students, graduate students, and postdoctoral researchers participating in the proposed research project.''
Similarly, the 2009 National Institutes for Health notice NOT-OD-10-019 requires that all trainees, fellows, participants, and scholars receiving support through any NIH training, career development award (individual or institutional), research education grant, or dissertation research grant must receive RCR training. This requirement also applies to all faculty, including new faculty, mid-career faculty and senior faculty, and professional and scientific employees receiving funding from these sources. Plans to meet the RCR requirements must be specified in the principal investigator's proposal application.
NIH established a new expectation for the format of the training, subject matter, faculty participation, duration and frequency of instruction. The 2009 update specifies that online courses can be a valuable supplement, but they are not considered adequate to address the RCR requirements except in special instances of short-term training programs or unusual and well-justified circumstances. Acceptable training plans generally include a minimum of eight (8) substantive hours of face-to-face instruction over the following subject matter:
Conflict of Interest
Purpose
The purpose of this policy is to ensure compliance with federal regulatory requirements for compensation for personal services per 2 CFR Chapter II Part 200 Subpart E §200.112 of the Uniform Guidance.
Policy
If an external sponsor is a federal agency or department, it is mandatory to comply with federal laws and regulations (See 2 C.F.R. 200.112). The University, the non-federal entity, must disclose in writing any potential conflict of interest to the federal awarding agency or pass-through entity in accordance with applicable federal awarding agency policy and must disclose, in a timely manner, in writing to the federal awarding agency or pass-through entity all violations of federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the federal award.
Sexual Harassment (for federally funded projects - NSF, NIH)
Purpose
The purpose of this policy is to describe National Science Foundation and National Institutes of Health requirements regarding sexual harassment.
Policy
The NSF has a no-tolerance policy for sexual harassment, other forms of harassment, and sexual assault, within the agency, at awardee organizations, field sites or anywhere science or education is conducted. As such, the NSF includes a term and condition concerning harassment as part of its award acceptance requirements, which pertains to Principal Investigators (PIs) and co-Principal Investigators (co-PIs) of NSF-funded projects, including co-PIs at subawardee institutions.
For NSF grants awarded to Northcentral University, NU’s Authorized Organizational Representative (AOR) must notify that agency of any finding/determination if an NSF-funded PI or co-PI has violated NU’s policy, statutes, regulations, or executive orders relating to sexual harassment, other forms of harassment, or sexual assault. The AOR also must notify that agency if an NSF-funded PI or co-PI is the recipient of administrative action (e.g., placed on leave) for an alleged violation of NU’s policy, statutes, regulations, or executive orders relating to sexual harassment, other forms of harassment, or sexual assault. Per NSF guidelines, a finding/determination not only includes violating NU’s own sexual conduct policy, but also a conviction of a sexual offense in a criminal court of law.
