Each sponsored project at the University of Minnesota is conducted within a framework of regulations, policies, and procedures, including

• sponsor policies,
• Regents' and University policies, and
• departmental and collegiate guidelines.

Rather than detail each regulation, policy, procedure, or guideline, this handbook gives general explanations and refers to particular documents. Policies and procedures specific to sponsored projects can be found at http://www.ospa.umn.edu/policiesandprocedures/index.html. Other University and Regents policies and procedures are accessed from the University's policy library (http://www.policy.umn.edu).

Sponsor policies

Sponsor policies - Federal
The federal management circulars, the agency's regulations, and the award agreement govern conduct of the project.
 
Federal management circulars
These circulars establish a basis for policy in the management of federally sponsored projects. They include:
 
• OMB Circular A-21, Cost Principles for Educational Institutions, outlines allowable costs and also prescribes the manner in which universities must determine their indirect cost charges.
• OMB Circular A-110, Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, sets forth administrative procedures, such as financial reporting, the handling of program income, payment requirements, standards for financial management, federal requirements for cost sharing, rebudgeting, and prior approval.
• OMB Circular A-133, Audits of Institutions of Higher Education and Other Nonprofit Institutions, outlines audit requirements for universities and other nonprofit institutions which receive federal funds.
• Cost Accounting Standards (Appendix A in OMB Circular A-21) dictate accounting procedures the University must use in dealing with federal funds.
• Federal Acquisitions Regulations state processes University researchers and administrators must use in acquiring materials on federal contracts.


Copies of these documents and other regulations are available at http://www.research.umn.edu/regulations/policies/federal.html.

The agency's guidelines
While these circulars establish the principles for project management, each agency may differ in policy application. Some agency guidebooks are available at http://www.research.umn.edu/regulations/policies/federal.html. Others can be obtained from the agency.

The award agreement
Each award comes with an agreement which states terms and conditions specific to that particular project.  

 

Sponsor policies - Nonfederal
The specific award agreement, together with University policy, usually guides the project's conduct. State agencies, foundations, and private businesses may also publish their own funding guidelines, which are available from the sponsor.

University policies

Regents policies
Regents policies provide an umbrella under which all other University policies operate, and apply to all University activity regardless of sponsor or source of funds. Several of these policies involve compliance with regulations involving human subjects, animals, and hazardous materials. Others define University standards for integrity in areas where misunderstandings could develop.

University policies
While the Regents have established some general principles, the University administration has developed its own policies and procedures which complement them and help administer other institutional functions. These policies are approved at senior levels of the University, change infrequently, and set a course for the foreseeable future.

In many cases, sponsors allow recipients to administer certain aspects of programs according to the policies established by the recipient institution. This is true of both federal and nonfederal sponsors. There is an explicit understanding that University policies under such circumstances will be applied equally to the administration of sponsored and University resources.

Regents and University research-related policies are outlined below:

Academic Misconduct
The University expects that all endeavors will be conducted with absolute integrity. Academic misconduct involves:

• fabrication or falsification of data, research procedures, or data analysis;
• destruction of data for fraudulent purposes;
• plagiarism;
• abuse of confidentiality; or
• other fraudulent actions in proposing, conducting, reporting, or reviewing research or other scholarly activity.


Because allegations and instances of academic misconduct are extremely serious matters, the University has developed policies and procedures to help faculty and staff prevent, identify, and resolve these matters. The Regents' Academic Misconduct policy defines academic misconduct, which is to be distinguished from honest error and ambiguities of interpretation. They also outline procedures for investigating and resolving allegations of misconduct.

Animal Care and Use
All animals at all University campuses, labs and field stations are under the protection of the Institutional Animal Care and Use Committee (IACUC), which can be reached at (612) 626-5654. That committee inspects animal facilities and reviews proposals for animal use. PIs submitting proposals that involve the use of live vertebrate animals must complete the Animal Usage form BA22 and submit it to the IACUC for review and approval. Failure to file the Animal Usage form could result in delays in the processing of a proposal or in the beginning of the project. For further information, contact the RSPP.

Enforcement of the policy and related federal regulations is the responsibility of RSPP. The RSPP web site at http://www.research.umn.edu/subjects/ provides resources and information.

Charging of Direct and Facilities and Administrative (Indirect) Costs
Costs are charged to a project both directly and as part of the overhead, or "facilities & administrative (indirect) cost rate." This policy and its procedures establish practices for defining, charging, and coding direct and facilities & administrative costs to University accounts. It explains when a F&A reduction or waiver might be needed and outlines the process for obtaining the reduction. The policy also includes information for sharing ICR among collaborating collegiate units.

Charging Sponsored Project Costs Outside the Award Period (Preaward policy)
Costs cannot normally be incurred to a project until the project officially starts. Under certain circumstances, however, it may be necessary to incur costs on the project between budget periods or before the award process is completed. This policy outlines the requirements for establishing a CUFS account that is used as a preaward or advance account and for charging preaward costs.

Code of Conduct
The Board of Regents has established a Code of Conduct outlining its expectations for the standards of professional conduct and integrity which all members of the University community must uphold.

Commercialization of Intellectual Property Rights
This policy asserts the University's claim on technologies invented by its employees, students and other individuals using considerable University resources and outlines how net income from the University's intellectual property will be distributed. It permits the University of commercialize the invention, allows the vice president for research to commit up to $250,000 to assist commercialization, and in certain circumstances, lets the University own a controlling equity interest of a start-up company to commercialize the invention.

Cost Transfer Policy (formally entitled "Processing Internal Accounting Transactions")
Expenses must be charged to a project in a timely and accurate manner. However, there are legitimate reasons for needing to adjust or correct expenses already recorded on the general ledger. This policy details how and when charges can be moved on to and off of sponsored accounts.

Education in the Responsible Conduct of Sponsored Research and Grants Management
The University established a program to address the current and continuing educational needs of all personnel involved in externally and internally funded research, instructional and public service activities. This policy provides guidelines for maintaining the program.

Effort Certification
By federal law, personnel working on sponsored projects must certify the time they spend working on projects. This policy provides instructions for correcting certifying effort spent on a project.

Individual Conflict of Interest - Regents' Policy and Individual Conflict of Interest Policy - Administrative Policy
Conflicts of interest can be harmful if individuals compromise or appear to compromise their professional judgment in carrying out University activities because of external relationships that affect their financial interest or those of any family member or associated entity. Some of the disclosures the University requires include:

• Financial interests held by employees and their immediate families that exceed $10,000 per year or 1 percent ownership of an enterprise.
• Members of employees' extended families who hold an executive position or more than 10 percent ownership of an enterprise.
• Technology transfers through patents or licensing to a business in which the employee has a financial interest.
PIs must obtain approval from their department heads and, if necessary, their deans before proposals are submitted. Conflicts of interest must also be disclosed during the course of reporting research results.

Institutional Conflict of Interest - Regents' Policy and Institutional Conflict of Interest Policy - Administrative Policy
Because it is critical to the mission and reputation of the University to maintain the public's trust, University research, teaching, outreach, and other activities must not be compromised or perceived as biased by financial and business considerations. In addition, because of its numerous and complex relationships with public and private entities, the University must be aware of any relationships involving financial gain that may compromise or appear to compromise its integrity. Therefore, these policies were established to provide an oversight process to manage, reduce or eliminate institutional conflicts of interest.

Managing Program Income Earned on Sponsored Projects
Program income is any income generated by the project, such as income from the sale of pamphlets and other materials. This policy outlines how to handle these funds.

Offering Cost Sharing, Matching, and In-Kind Contributions on Sponsored Projects
Occasionally, it may be necessary to offer sponsors voluntary services or materials as part of a project's total costs. However, it is essential that the use of cost sharing be kept to a reasonable level so as not to overburden departmental and institutional resources.This policy and its procedures outline how to properly include and report cost sharing and matching funds, and to indicate when the approval of the department head, dean or other administrators is required.

Openness in Research - Regents' Policy and Openness in Research - Administrative Policy
Absent compelling reasons, the University shall not accept restrictions on participation in University research or on the dissemination of the results of University research. There may be situations when the University must have flexibility to depart from this standard in order to serve a public interest. These policies clarify the circumstances in which certain restrictions in a research agreement can be accepted by the University while still preserving the principle of open research. The administrative procedure outlines the process for a researcher to use to request an exemption from this standard and provides guidance for University faculty and staff to use in evaluating these requests. The Regents' policy also addresses the University's right to publish and an outside party's right to publish results of an investigation. It also covers proper giving of credit, rules governing use of brand and trade names and publicity of the investigation results.

Outside Consulting and Other Commitments - Regents' Policy and Outside Consulting and Other Commitments - Administrative Policy
While the University encourages research and entrepreneurship, it expects that full-time employees will devote their loyalty, time, and energy to University duties. Professors with 100 percent of effort devoted to research, teaching, and public service have a conflict of commitment if they also work elsewhere. These policies help prevent these conflicts by listing acceptable non-University commitments and outlining the process for obtain prior approval for consulting activities.

Reporting and Addressing Concerns of Misconduct
Employees have a responsibility to report violations or suspected violations involving improper activities or noncompliance with policy, applicable laws and regulations. This policy details how reporting and investigation of improper activity are handled in a confidential manner. It also explains how to report non-compliance with law, regulation or University policy and improper financial activities.

Research involving Human Subjects
Government regulations regarding human subjects revolve around three basic principles:

• Subjects must be fully informed of all aspects of the sponsored project.
• Risks and benefits must be balanced and assessed by independent experts.
• Selection of subjects must be just, to assure appropriate distribution of risks and benefits.

These principles and related government regulations are implemented through the Regents policy on the Research involving Human Subjects. All research protocols involving human subjects must be submitted to and reviewed and approved by the Research Subjects' Protection Programs (RSPP) before any research begins. The RSPP web site at http://www.research.umn.edu/subjects/ provides resources and information.

In addition, University faculty and staff have a legal obligation to maintain the confidentiality of paid research subjects (see policy on Paying Human Subjects and Maintaining Confidentiality and 1099 Reporting). The payment process must maintain confidentiality while meeting Internal Revenue Service (IRS) reporting requirements and conforming to the University's standard accounting and payment practices.

Research involving Recombinant DNA and Hazardous Biological Materials
This policy states that regardless of sponsor, all research involving recombinant DNA technology (making DNA by separating and splicing together DNA from several different species) must comply with Guidelines for Research Involving Recombinant DNA Molecules issued by the National Institutes of Health. Protocols involving other hazardous biological materials such as biological toxins or infectious agents must also comply with this regulation. Before any grant application using these materials is submitted, the PI must file a registration form with and receive approval from the Institutional Biosafety Committee. Contact the Biosafety Committee for complete information by calling (612) 626-5621, or visit DEHS' web site at http://www.dehs.umn.edu.

Reservation and Delegation of Authority
The University's Board of Regents is commissioned by the State of Minnesota's Constitution to govern the University. Through the Delegation of Authority policy, the Regents transfer many administrative responsibilities to various University officials.

Submitting and Accepting Sponsored Projects
This policy defines who can be a principal investigator for purposes of receiving grant funding. It also defines relationships between principal investigaors, the University, and the sponsored project and delegates authority for many sponsored project-related functions to the Associate Vice President for Research and Director of Sponsored Projects Administration (SPA). All requests for sponsored support (proposals) must be endorsed by, and awards accepted by, this Director or a designee of this individual.

Using Controlled Substances for Research
In conducting research with controlled substances, University authorized employees must comply with federal and state laws and regulations regarding their uses, storage requirements, inventory maintenance, and substance disposal. This policy and its procedures give instructions for receiving, using, storing and disposing controlled substances.

Using Legend and Investigational New Drugs for Clinical Research
This policy is intended to promote the safe handling of drugs used in clinical research, reinforce the protections afforded human subjects who are administered drugs under research protocols, help detect and prevent diversion of drugs for unauthorized purposes, and assure compliance with applicable laws and internal requirements related to the use of legend and investigational drugs for research purposes.

• are not enforced by SPA, and
• can only be more restrictive than the other categories of regulations, policies, and procedures outlined in this section.