Section 4. University Policies and Procedures

Centers and Institutes

The University of West Florida Board of Trustees has approved 14 Institutes and Centers (I&C) that have been established for the purposes of research and education, coordinating international relationships, advancing public policy, and providing research and instrumentation facilities and services. Institutes and Centers focus on domains of knowledge that reside within a discipline or are cross-disciplinary in scope. I&C are university entities established to coordinate intra- and inter-institutional research, service, and/or educational/training activities that supplement and extend existing instruction, research, and service at the university. In some cases, I&C are established to provide infrastructure needed to coordinate support activities across the State University System (SUS). These are organizational mechanisms that can be used to provide greater depth in teaching and/or research to a narrower band of problems within a discipline, or to apply a broader vision to problem sets that cross traditional knowledge boundaries. I&C status provides visibility for, and tangible evidence of, a formalized structure for an activity that strengthens its credibility to funding agencies as well as to other external sponsors.

The SUS classifies I&C as either (1) State of Florida (formerly known as Type I) or (2) university (formerly known as Type II or III). The SUS policies and procedures for establishing, reviewing, and disbanding I&C is covered in State University Procedures for Institutes and Centers - 7/04. The State University System Division of Colleges and Universities Policy Guideline for Institutes and Centers (Policy Guideline #PG 04.07.27) provides additional guidance on this topic.

All UWF I&C must be approved first at the University level. Proposals for new I&C require collaboration with other University departments who have interests in the area of knowledge proposed and then be approval by the President after initial review and approval of the respective chairs, deans, vice president (where appropriate), the Director, Research and Sponsored Programs (DRSP) and the Associate Vice President for Research and Sponsored Programs (Associate Vice President). Appendix D of this manual contains University procedures for approving, classifying, operating, reviewing, and disbanding institutes and centers.

Once the department and college reviews have occurred, signified by the signatures of the chair and dean (and vice president where appropriate), the proposal should be forwarded for review by RSP. In general, the primary critical review should occur at the College and Departmental level; RSP may solicit constructive suggestions from the Sponsored Research Advisory Committee (SRAC) for integrating the I&C objectives with existing University programs. Proposals that are approved by the Associate Vice President and DRSP will then be forwarded to the Office of the Provost. The Provost or his designee will coordinate the final review by appropriate governance bodies and transmit the proposal to the University President who may approve on behalf of the UWF Board of Trustees.

Faculty who are affiliated with a I&C may choose to submit their grant or contract applications via their home department or via their I&C. If the anticipated scope of work does not involve the resources or support of the I&C, it is appropriate to submit through the home department. If the work will require the expertise, collaborative efforts, resources and support of the I&C, it is appropriate to submit through the I&C. When submitting via the I&C, a project needs signatures from the home department chair, if applicable, as well as the I&C director and respective dean(s) or vice president(s). I&C are entitled a percentage of F&A cost returns on individual research and training grants as the sponsoring unit in lieu of the faculty member’s academic department.  For complete guidelines and procedures and the appropriate forms, refer to Appendix D.

Classified Research

The University permits faculty the opportunity to engage in classified research. However, the primary mission of any major research university is to disseminate information and advance knowledge in all academic fields. University researchers should be as free as possible to seek new knowledge without constraints, and to share their findings with other scholars.

Before submitting a proposal to a sponsor to conduct classified research, the researcher must submit the proposal for review to the RSP Facility Security Officer (FSO).  RSP will review the proposed research activity to determine if it is acceptable as appropriate academic research. Consideration will be given to the restrictions on publications, use of graduate students, the humanitarian nature of the research and the appropriateness of the scientific inquiry within a university environment.

RSP will make a recommendation to the President of the University and the final decision of acceptance or rejection of the proposed research will be made at that level.

Researchers should be aware that the approval of classified research requires both a facility security clearance (UWF clearance is currently inactive) and personal security clearances for any personnel who would have responsibility for and/or access to classified information.  These applications are complex and faculty should allow a minimum of 90 days prior to the need to receive or access classified material or to apply for a funding opportunity which requires clearance in order to be eligible for application.  For additional information and details, contact the FSO at (850) 474-2825.

Export Control Restrictions

All projects which include federal funds may be subject to export control restrictions. Regulations promulgated and enforced by the U.S. Department of Commerce (DoC) through the Export Administration Regulations (EAR), and the U.S. Department of State through the International Traffic in Arms Regulations (ITAR) prohibit the unlicensed export of specific technologies for reasons of national security or protection of trade. If UWF research involves such specified technologies, the EAR and/or ITAR may require the university to obtain prior approval from U.S. Department of State or Department of Commerce (DoC) before allowing foreign nationals to participate in the research, partnering with a foreign company and sharing research—verbally or in writing—with persons who are not United States citizens or permanent resident aliens.

The vast majority of on-campus research projects can be conducted in a manner fully consistent with the principles of freedom of inquiry and open exchange of knowledge. However, UWF recognizes that in a very few cases the pursuit of knowledge may involve critically important but sensitive areas of technology and knowledge where the immediate distribution of research results would not be in the best interests of society. In such cases, exceptions to the policies regarding publication, classification, and access by foreign students and scholars may be made, but only in those very rare instances where the area of work is crucially important to UWF’s educational mission and the exception is demonstrably necessary for the national good.

For the complete procedures and forms related to Export Control, please refer to Appendix E or contact the University FSO at (850) 474-2825.

Consultant/Contractual Services on Grants

Consultant payments on sponsored projects must represent compensation to individuals who are independent of the university and who render independent services. Consultant payments may not be made by faculty to colleagues where an employer/employee relationship exists. Rather, in these situations colleagues should be compensated for services via the University personnel/payroll system according to percent effort of committed time; or donate their services as part of their intra-institutional collaboration as a professional courtesy. This expectation is part of the OMB Circular A-21 Cost Principles for Educational Institutions and OMB Circular A-133 Audits of States, Local Governments, and Non-Profit Organizations.

On the whole, it is expected that consulting needs can be satisfied from resources within the University community. When outside consulting services are needed for a grant or contract, all of these conditions must be met:

1. There must be evidence that the services provided are essential and cannot be provided by persons receiving salary support under the sponsored project.
2. There must be evidence that a selection process was employed to secure the most qualified person available.
3. There must be evidence that the charge is appropriate considering the qualifications of the consultant, normal charges, and the nature of the services rendered.
4. Federal programs limit the amount per hour/day/annum that may be charged as a consultant fee. The rate can be found on OPM's Information on Federal Pay and Leave Web page under the "Salary Tables".
5. If an outside consultant is employed, the individual must be established in the UWF Procurement and Contracting system as a vendor. Refer to the guidelines for the requirements for a Consulting and Professional Services contract (see Procurement and Contracts). This may be the most efficient method of procuring the services. If the third party is not eligible to be established as a vendor through this method, a subaward or subcontract agreement must be entered into with the individual’s normal employer for services and related costs. Refer to Subcontracting/Subagreements later in this Section.

Cost Accounting Standards

These standards are required when an institution's Federal grants reach $25 million dollars and additional procedures will be added once UWF approaches this amount.

1. Cost Sharing (Matching)

Only mandatory cost sharing (matching or institutional contributions/support) should be submitted to sponsoring agencies. Mandatory cost sharing requirements are defined for a specific program when an agency offers a request for proposals, the award document or by the agency guidelines. When there is mandatory cost sharing, a copy of the RFP, regulations or guidelines must be submitted with the proposal along with a written commitment from the individual authorized to commit the resources. Any mention of Voluntary cost share within a proposal, Facilities and Resources description or Budget Narrative commits the University of West Florida to the resources identified as cost share even though it may not have been required by the grantor.

      Criteria for Cost Sharing Commitments

• Cost sharing or matching funds must be verifiable from the University's records.
• In-kind, third party contributions offered as cost sharing require a commitment letter on company letterhead signed by an individual who is in a position to commit the in-kind contribution. After-the-fact reporting to the University will be necessary.
• Commitments must not be included as contributions for any other project or program.
• Commitments are necessary and reasonable for proper and efficient accomplishment of project or program objectives.
• Commitments are allowable and allocable under the applicable cost principles.
• Cost sharing commitments may not be from other funds supported by the Federal Government under another award, except where authorized by Federal statute to be used for cost sharing or matching.
• Costs are described in the approved budget and/or terms of the sponsored agreement when required by the awarding agency.
• Cost sharing provisions of OMB Circular A-110 are met.

2. General Information

Cost sharing is a term that describes circumstances whereby the University is not reimbursed for allowable costs of performing a project because the requested or approved budget does not cover the full costs associated with the specific project. Therefore, cost sharing (also known as matching, or in-kind contributions) represents that portion of the project costs not paid for by the sponsor.

Matching funds may be cash or in-kind contributions. They may include a dollar-for-dollar match to purchase equipment or renovate a facility.

In-kind contributions may be donated time, space, equipment, etc.

Caution: The value of a third party in-kind contribution must be established and verified at the time of proposal submission and documented at the post award stages. For example when the contribution is in the form of personal services, the contributor must certify that the amount being provided as in-kind is comparable to the individual's regular rate of compensation. When in-kind contributions are other than personal services, the fair market value of the item must be established, consistent with OMB Circular A-110 procedures.

Cost sharing may be mandatory, voluntary committed, or voluntary uncommitted.

Caution: Voluntary committed cost sharing offered in a proposal may be accepted by the sponsoring agency and become a condition of the award, thereby making it mandatory cost sharing.

Mandatory cost sharing may be a requirement of the grant documents or may be a condition of a specific solicitation. It will normally appear in the RFP/RA/NOFA or award document from the agency. Mandatory cost sharing expenses must be reported back to the sponsoring agency in a Financial Report.

Voluntary committed cost sharing is created if a proposal included cost sharing when none was required. Even if that cost sharing is not in the budget awarded by the agency, the PI and the University are "committed" to providing the project with the indicated support. Voluntary committed cost sharing expenses are not reported back to the sponsoring agency; however, it is still required that the University track and document these costs as they are subject to audit.

Voluntary uncommitted cost sharing is cost sharing that is neither mandatory nor committed. It represents contributions to a sponsored project that do not come from the awarding agency. Voluntary uncommitted cost sharing expenses are not reported back to the sponsoring agency, however they SHOULD still be recorded through the Effort Reporting Systems or through manual cost sharing entries.

When the University accepts an award with mandatory or voluntary committed cost sharing, the University is making an agreement with the sponsor that is subject to audit. The University is committing to provide the stated cost sharing during the period of performance of the sponsored project.

Cost sharing must be an allowable cost. This means that grant and contract costs must be allowable under OMB Circular A-21, OMB Circular A-110, and University procedures. Any cost that would be unallowable on the grant or contract will also be unallowable as cost sharing for that grant or contract. For example, administrative support is not normally allowed as a direct charge to a Federal grant, therefore it is an unallowable cost regardless of the source of support and cannot be used for cost sharing purposes. Sponsoring agencies may have various guidelines with regard to cost sharing. For example, the U.S. Department of Education (ED) may only allow 8% of MTDC/TDC as F&A on a training grant. The difference between the current U.S. Department of Health and Human Services (DHHS) approved F&A rate and 8% cannot be used as cost sharing without prior approval of the Secretary of the U.S. Department of Education.

Cost sharing must be identifiable and verifiable. The Principal Investigator (PI) or departmental business manager will be responsible for identifying and verifying mandatory and voluntary committed cost sharing by obtaining the required documentation for cost sharing at the time of proposal submission and sending the information with the proposal to Research & Sponsored Programs. The responsibility for entering cost sharing that was met during the project into the University's effort reporting system is at the department level. RSP is responsible for entering, from data provided by the departments into the University's cost sharing system.

Research & Sponsored Programs will track all cost sharing in the University's accounting system and provide official reporting for such cost sharing. It will be the responsibility of the (PI) to ensure that the cost sharing commitment is met on a grant or contract and to provide RSP Office the documentation necessary to track cost sharing commitments.

3. The Impact of Cost Sharing on the University's Federal Facilities & Administrative Rate

Cost sharing dollars in aggregate have a negative impact on the University's Facilities and Administrative (F&A) cost rate. As cost sharing dollars from various units throughout the University accrue in the accounting system, the total amount is incorporated into formula used in the negotiation of the University's F&A cost rate. As the denominator increases, the percent rate decreases, resulting in a lower Facilities and Administrative rate (F&A cost rate).

Employment of Relatives on Grants/Contracts

When faculty plan to employ a spouse, child or other close relative on government sponsored projects, the agency must be fully informed about the nature of the relationship and the qualifications which make the services particularly desirable. Furthermore, under University of West Florida policy (See UWF Policy HR800), no such related person can be employed unless the President or President's designee has determined prior to the appointment that there is no conflict of interest (6C-5.945, Florida Administrative Code).

Financial Conflict of Interest (CI)

The University’s faculty is made up of highly trained professionals, many of them of national and international reputation, representing a substantial reservoir of human resources. Services of this group are available to the various sectors of society for the mutual benefit of industry, government, the academic community and society at large. Outside employment and activities are encouraged, provided they do not detract from the full and competent performance of a faculty member's duties. In light of this, faculty whose activities are paid from grants or contracts should be aware of potential conflict of interest situations.

The University's policy on conflict of interest is found in UWF Policy HR800 and applicable collective bargaining agreements. The cited policy explains the University's Policy. In addition, Academic Affairs has information pertaining to Conflict of Interest and Outside Employment Policy and a disclosure form.

Federal regulations require that the university manage, reduce, or eliminate any actual or potential conflicts of interest that may be presented by the compensated outside activities and other financial interests of persons involved in sponsored research projects funded by the National Science Foundation (NSF), and the Department of Health and Human Services (DHHS in NIH, NIDA, etc.).  In addition, granting agencies may have their own conflict of interest requirements which have to be adhered to such as NIH.  These federal regulations are designed to prevent bias in the design, conduct, or reporting of research projects.  Principal investigators and others working on projects funded by DHHS or NSF must abide by these requirements.

Any employee submitting a grant or contract proposal to the DHHS or NSF through the university or conducting research or educational activities pursuant to such a federal grant or contract at the university as an "investigator" must report any "Significant Financial Interest" that would reasonably appear to be affected by the proposed or funded research activities, including interests maintained in entities that would be so affected. An "investigator" is defined as the principal investigator, co-principal investigator, or any other employee responsible for the design, conduct, or reporting the proposed or funded research or educational activities. For the purpose of determining a Significant Financial Interest, an "investigator" also includes an employee's spouse and dependent children.

A "Significant Financial Interest" refers to salary or other payments for services, such as consulting fees and honoraria; equity interests, such as stocks and stock options; and intellectual property rights, such as patents, copyrights, and royalties. A Significant Financial Interest does not refer to salary or other remuneration from the university; income derived from seminars, lectures or teaching engagements sponsored by public or nonprofit entities; income derived from service on advisory committees or review panels for public or nonprofit entities; or salary, royalties or other payments that, when aggregated for the investigator and his or her spouse and dependent children, is not expected to exceed $10,000 over a 12 month period for example. An equity interest that, when aggregated for the investigator, spouse, and dependent children, does not exceed $10,000 and does not represent more than a five percent ownership interest in any entity is also not considered a Significant Financial Interest.

Significant Financial Interests must be disclosed at the time of the submission of the proposal, but approval of the outside activities and financial interests (with conditions if warranted) need not occur until the project has been funded. The federal regulations also require that the disclosures be made annually during the course of the research, or as new reportable significant financial interests are obtained. The employee must file a new report if a new Significant Financial Interest is obtained, which is consistent with the university's requirement that any material changes to outside activities and financial interests must be reported during the academic year. Review and approval or disapproval of the interests disclosed during the course of a research project must be accomplished within 60 days.

The department chairperson/or supervisor and the dean/director are responsible for reviewing each disclosure to determine if there is a potential conflict of interest. Under the federal regulations, if a Significant Financial Interest may directly and significantly affect the design, conduct, or reporting of the research, a conflict will be deemed to exist. The university, through the department chairperson/supervisor and dean/director, is required to manage, reduce or eliminate the conflict. Conditions that might be imposed in such cases include public disclosure of the conflict, modification of the research design, or monitoring of the research by independent reviewers. If adequate measures are not feasible, the employee may have to discontinue the compensated activities or divest him or herself of the financial interest, or discontinue the research. The employee must abide by the conditions under which the research is permitted.

In order to certify compliance with these federal regulations, RSP procedures requires that all investigators and other key personnel on HHS and NSF proposals fill out and sign a Conflict of Interest/Outside Employment Disclosure Form before the proposal is submitted by RSP to these agencies. This form may be accessed through the Appendix B Proposal Processing Menu. The form should be part of the package submitted for review and approval through the usual departmental, college and unit approval process using the Internal Routing Form (IRF). It is the principal investigator's responsibility to ensure that Disclosure of Significant Financial Conflict of Interest form for all investigators (including co-principal investigators and other employees responsible for the design, conduct, and reporting of the research) are obtained on a timely basis in order to meet proposal application deadlines. RSP requires at least three business days to review proposals.

Regardless of whether or not a conflict exists, the proposal will be submitted to the agency . The form is kept on file in RSP and is not sent to the agency. However, an institutional certification that the University's policy is active and in compliance with the federal regulation will be transmitted to the agency.

Procedure for Form Review and Approval

Research and Sponsored Programs (RSP) is responsible for recommendations for only grants and contracts related to CI disclosures. The following process will be used for reviewing and approving CI forms. 

1. Provost's Office (PO) will log out and forward original CI forms to the RSP office.
2. RSP personnel will include the PO on their twice daily delivery/pick-up schedule.  Personnel doing the delivery/pick-up will sign the PO log to ensure receipt/delivery of the CI form.  RSP will include the CI forms on the RSP DocuTracker system.
3. RSP personnel will review (reviewers) the CI form for potential grant-related conflict of interest.  If no grant-related conflict of interest is found the document will be initialed and submitted to the Director of Research and Sponsored Programs (DRSP) who will so note, initial, and return to the PO for her action.  If a potential conflict is found, the reviewer will identify and explain the potential conflict in a written note, make a copy of the written note and CI form, and forward the original CI form and note to the DRSP.  The DRSP will either recommend the Provost sign the CI form or recommend remediation of the potential conflict.  The original CI form, the original potential conflict note, and the DRSP recommendation will be forwarded to the PO.  The Provost Office will retain copies of document for files and forward original to Office of Human Resources.
4. Reviewers assigned to jointly review the CI form for potential conflict of interest are the Assistant Director (AD) and the Grants Specialist Supervisor (GSS).  In their absence the function may be delegated to one of their subordinates.  The Director of Research and Sponsored Programs (DRSP) will approve the grant-related CI document for signature of the Provost by placing initials next to the Provost signature line.  If the CI form is not grant-related it will be noted and the CI form will sent to the PO for action.  In the event of absence of the DRSP the initialing function may be delegated to either the AD or GSS.
5. Review of the CI form will include identification of any contracts or grants that the CI submitter is working on that may create potential conflicts of interest, an internet check of any specific relationships that may be potential conflicts, historical records which may identify potential conflicts, and other records as may be appropriate. 

F&A Costs Recovered from Sponsors

The F&A cost rate is negotiated with DHHS (UWF’s cognizant audit agency) and reflects the rate of reimbursement for real, audited, facilities and administration costs incurred in the conduct of research. Included among these costs are: depreciation and use allowance costs of buildings and equipment, maintenance and repairs, janitorial services and utilities, hazardous waste disposal; libraries; and general administrative costs such as sponsored programs administration, departmental and general administration (accounting, purchasing, legal services, personnel compliance). These costs are "indirect", or general research support costs, because they are not included in the "direct" portion of the budget allocated for specific project research and typically cannot be ascribed to an individual project. They relate to the conduct of research in general, regardless of the source of funding, and therefore must be applied to all grants and contracts.

All grants, contracts and agreements accepted from any sponsor to fund University research should be charged the full on-campus or off-campus F&A cost rates established for federal awards. Any exception to this procedure must be in writing and approved by the Dean, DRSP, Associate Vice President for Research and the Provost prior to submitting the proposal to the outside agency.  A sample of a form or memorandum for this request is available in Appendix B Proposal Processing Menu.

It is recognized that some private foundations, and even some programs of federal and state funding agencies, have an established policy that restricts the rate of F&A cost payment. Some other organizations will pay no F&A costs to an institution. UWF can accept funds from these organizations as long as their written policy is provided to RSP at the time a proposal or application is submitted and the University agrees to cost sharing.

Several faculty have long standing research awards with sponsors that were negotiated initially with a lower F&A cost rate than the standard rate. In these cases, the Director or Assistant Director of RSP will work with the funding agency, faculty member, department or cognizant college office in the interim to identify a source of cost sharing that can be acknowledged in the proposal as a means of reducing the administrative component of the award by, for example, lump sum payments using a short-form letter of agreement. Also, it will be expected that over a reasonable time period, these rates will be increased and brought in line with the prevailing F&A cost rates.

Allocation of F&A Costs

Since The University of West Florida is a state institution, reimbursement for its operational expenses should logically go back to the State, which initially advanced the costs incurred for federally funded projects. However, the Florida Legislature has implemented a far-sighted policy which allows each state university to retain 100% of the recovered F&A cost funds (FS 1004.22). In addition to funding RSP’s operating costs, these overhead funds are used for a variety of internal support programs and scholarly awards.

1. F&A Cost Returns

Each year (RSP) returns a portion of F&A cost earnings directly to principal investigators (10%), the department (10%), and the colleges associated with the grant(s) (10%). Funds must be used for the support of research and research-related activities. This return generally occurs in September of each year and is based upon the F&A costs recovered from sponsors in the preceding fiscal year (July 1-June 30).

Some general notes on the distribution process are:

1. When a grant or project has more than one PI, the distribution is made only to the lead PI. It is then at the discretion of the PI who is primarily responsible for the project management to determine if any portion of this share should be made available to other contributors.
2. If a unit (or individual) has changed reporting authority by being assigned to a different department or college, the funds are distributed to the units under which the funds were earned. Future distributions will be modified to show the change in oversight and administration. Please notify us if this has occurred.
3. When a PI has left the University due to any reason, the PI's portion of the distribution is made to the appropriate administrative officer (dean or vice president) responsible for oversight of the unit. It is expected that the Dean/VP is best able to determine the appropriate use of the funds by the department/college. Please notify us if this has occurred.

2. Internal Support Programs

RSP supports and provides incentives for research activity at The University of West Florida by investing a portion of the University's F&A costs recovered from sponsors in the internal support programs (Scholarly and Creative Activities Committee (SCAC) Summer Research, Small Grants, and Thesis/Dissertation support programs).

Scholarly and Creative Activities Committee (SCAC)

The purpose of the Scholarly and Creative Activities Committee (SCAC) is to promote and make recommendations concerning the scholarly and creative activities of the faculty and graduate students.

Specific Responsibilities

• Promote programs of scholarly and creative activities within the University
• Recommend policy and procedures on scholarly and creative activities to ensure compatibility with the role and scope of the University Mission.
• Recommend the allocation of funds to proposed faculty scholarly and creative activities and projects.
• Select the recipient of the annual Faculty Research/Creative Activities Award.
• Review and ensure adherence to Board of Trustees and other University guidelines and regulations on copyrights, patents and other intellectual property.
• Review University policy and procedures for establishing, reviewing and disbanding institutes and centers, and review proposals for establishing new institutes and centers.
• Review applications and recommend the allocation of funds to students to support research required for completion of theses and dissertations in the various colleges.

Membership Representation

The SCAC consists of eight elected faculty members, voting, four from College of Arts and Sciences, two from College of Business, and two from College of Professional Studies.

MORE COMPLETE INFORMATION, GUIDELINES, POLICIES, AND APPLICATIONS FOR GRANTS CAN BE FOUND ON THE SCAC WEB SITE.

Institutional Prior Approval

The University of West Florida has established an institutional prior approval system required by federal agencies and authorized by the Federal Demonstration Partnership (FDP). Under this system, authorized officials in RSP provide prior approval for some pre-award costs and post-award changes on sponsored projects as permitted under FDP and other sponsoring agency guidelines. In short, approvals for certain actions can be granted within the university rather than the participating agency.

Institutional Review and Signature

Certain administrators at UWF have been authorized by the University President to enter into research and training agreements or submit proposals on behalf of the University (see UWF Signature Authorization Policy). At the proposal stage, this signature, along with those of other appropriate University officials (i.e., principal and co-principal investigators, department chair, dean/director, and vice president, if necessary) indicates the willingness and capability of the University to guarantee proper accountability and administration of funds. A PI's signature alone on proposals, grants and other agreements does not commit the University's resources and cannot be accepted in lieu of the authorized institutional officials in RSP.

All proposals must have institutional review and appropriate signatures via the IRF Form in Appendix B Proposal Processing Menu.  Letters to sponsors requesting changes to an awarded grant or contract must be countersigned in RSP but do not require the IRF form, unless it will involve a change of PI or key personnel. Such changes include no-cost extensions, rebudgeting, transfer of grants to new institutions, etc.

Institutional Expenditure Pre- and Post-Award Approval

The University of West Florida has established an institutional approval system for projects prior to the receipt of the award document or the final execution of a contract when it is highly probable that such approval is anticipated. In order to request advance authorization, the PI should have confirmation of the sponsor’s intent to fund and a date approved for beginning period of performance. OMB Circular A-21 allows federal agencies and funds authorized under the Federal Demonstration Partnership (FDP) conditions to approve expenditures up to 90 days prior to the beginning of the period of performance for pre-award start up costs with the agency’s approval. Under this system, approval must be authorized by the responsible officials (PI, director/chair, dean/vice president, and provost). Approval of the request includes the commitment to reimburse the Sponsored Research Trust for any unrecovered costs. Refer to Appendix B. UWF Proposal Routing and Forms Process/Documents.

Institutional Approval of Requests to Modify Budget

OMB Circular A-21 and OMB Circular A-110 also provides for federal agencies to allow for rebudgeting of funds under certain conditions without agency approval. These actions may be done internally with review and concurrence of RSP Post-Award unit unless prohibited by specific agency or award guidelines which prohibit it. Some conditions which prohibit internal approval and require agency authorization include:

1. Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval).
2. Change in a key person specified in the application or award document.
3. The absence for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
4. The need for additional Federal funding.
5. The transfer of amounts budgeted for indirect costs to absorb increases in direct costs, or vice versa, if approval is required by the Federal awarding agency.

Federal Demonstration Partnership

The Federal Demonstration Partnership is a cooperative initiative among 10 federal agencies and 96 institutional recipients of federal funds; its purpose is to reduce the administrative burdens associated with research grants and contracts. FDP is a unique forum for individuals from universities and nonprofits to work collaboratively with federal agency officials to improve the national research enterprise.

The University of West Florida was one of the original Florida SUS institutions which participated in the development of this initiative. Projects awarded with FDP Terms and Conditions provide more flexibility in managing the day-to-day operations. More information on UWF procedures related to FDP may be found in Section 7 of this manual.

Release Time

All personnel working on sponsored projects must be relieved of their regular duties by the department chair or other responsible individual for the period of time and percentage of effort devoted to the sponsored project. If such personnel continue to be paid from departmental funds while working on a sponsored project, the portion of their salary and fringe related to the project represents cost sharing to the project. However, if personnel are appointed to and paid from the sponsored project, "salary savings" occur within the departmental budget and can be released for other purposes within the University, subject to administrative approval. Refer to Section 3. Preparing a Budget/Direct Cost Categories/Salaries and Wages.

The faculty member is expected to be released from the portion (percentage) of the full-time contact hour equivalency. Salary and fringe for this portion is recaptured as a percentage of salary savings. This percentage may vary depending on the individual’s assignment. For example, Professor A has an assignment for a given semester to teach 9.0 contact hours (3 courses) and to provide advising, research and service for the remaining 3.0 contact hours of the required 12.0 contact hours required for a fully-funded FTE position. Professor A is released from one course but is expected to continue previously assigned advising, research and service. The contact hour equivalent of 3.0 contact hours equals a percentage of effort of 25% of the 100% effort assignment. Professor B has the same work assignment but is released from one course and any additional expectation of other departmental research or scholarly activity so the contact hour equivalent released is 4.0 contact hours to equal 33% effort of the 100% effort assignment. Whenever an appointment is made to a sponsored research activity, the faculty member’s work assignment should be made taking into account this consideration or amended if the commitment occurs after the work assignment is accepted.

Both release time and cost sharing of a faculty member’s effort are subject to reporting according to the appropriate contact hours through the Faculty Activity Report System (FARS) and should also be reported as the equivalent percentage of effort on the Personnel Activity Report System (PARS) forms. The contact hours required to generate a 1.0 FTE for a faculty member who has responsibilities related to the FTE generation of E&G funds and the percentage of the individual’s cost effort (prorated 100% effort) should be reconciled at the end of each reporting period. For assistance in determining the appropriate contact hour or cost effort equivalents, contact the college budget managers or RSP at (850) 474-2825 or (850) 474-2827.

Scientific Misconduct

Institutional Policy. It is the policy of the University that individual faculty members are expected to maintain high ethical standards in the conduct and reporting of their research. Should alleged incidents of misconduct in research occur, reporting of such possible violations is a widely shared responsibility and it is the duty of the faculty and administration to respond in a fitting manner to resolve issues arising from such alleged misconduct.

Faculty Responsibilities. Faculty members at the University of West Florida are expected to maintain ethical standards in the conduct and reporting of scientific and scholarly research. The faculty and other research staff have responsibilities for ethical conduct in research not only to the University, but also to the community at large, the academic community, and those private and public institutions to which members of the faculty are bound by affiliation or contract.  This responsibility extends to the students or employees directly under the faculty members' supervision.

Basic Principles Governing Investigations of Alleged Misconduct in Research. If allegations of misconduct in research are made, the procedures implemented may vary depending on the type, seriousness and technical nature of the alleged misconduct. The faculty and its representatives will be guided by the following principles:

• The rights of individual faculty members, students, and all employees of the University must be protected to the greatest extent possible, whether they be accused or whether they be the accusers, during the process of investigation and fact finding.
• The principles of "due process" shall govern any formal disciplinary proceedings initiated in response to a finding and charge by the investigation authority of misconduct in research.
• Confidentiality shall be maintained throughout an investigation to the extent possible in conducting a thorough investigation and consistent with the laws of the State of Florida.

Definition of Misconduct. Scientific or scholarly misconduct is defined as the violation of accepted standards of scientific or scholarly research in carrying out research or reporting the results, such as the intentional misrepresentation, concealment, "stealing," plagiarism, fabrication, or selective reporting or the omission of conflicting data. Failure to comply with federal requirements affecting specific aspects of conducting research, misappropriation of federal funds, failure to comply with the Institutional Review Board or the Institutional Animal Care and Use Committee policies and procedures, or other inappropriate actions in research which are in violation of existing University rules or policies are addressed under such rules or policies.

The full policy is available online at https://nautical.uwf.edu/UnitApp/Publication/Pub.cfm?PubFormatID=1052 or call RSP at (850) 857-6378.

Subcontracting/Subrecipient Agreements

In the preparation of a proposal, anticipated subcontracting costs are identified in detail as direct cost items. If the need for a subcontract arises during the conduct of research, written approval may be required from the sponsoring agency before the subcontract can be issued. In either case, the University as a prime recipient of external funds is responsible for the appropriate fiscal management of the subcontract for compliance with OMB Circular A-21 and OMB Circular A-133 and state and university regulations and policies. All subcontracts must be approved by RSP. See Section 7. Subcontracts for procedures related to proposing, selecting, preparing a subcontract and monitoring after the award is received.

Intellectual Property

The UWF Intellectual Property Policy - July 2002 is augmented in Section 13 with additional forms and information relative to copyrights and trademarks. Section 14 provides the procedure for the Protection of UWF Intellectual Property which requires periodic certification and off-campus archiving of UWF's copyrighted software.