Grant Policies and Procedures

The University must manage all external funds in accordance with all applicable federal, state and local laws and regulations, as well as with the specific terms and conditions of any Gift or Sponsored Award. While both Gifts and Sponsored Awards (usually in the form of a grant agreement or contract) are often awarded in response to a proposal with a specific work plan or activity, the mechanisms used to manage these respective types of funds differ greatly, and are primarily determined by the requirements of the Donor or Sponsor. Consequently, it is important to properly classify such awards.

The purpose of this Policy is to provide a framework to facilitate the appropriate classification of private support received by the University as either a gift or a sponsored award. This categorization is essential for ensuring that the appropriate office or department manages the funding in a manner consistent with such classification and for ensuring that it is treated correctly for tax and accounting purposes.

The purpose of this Policy is to require a comprehensive pre-submission review of all Proposals to ensure that they are complete and accurate and to establish a process in order to: 

• Ensure that the Principal Investigator, acting on behalf of the university, is compliant with (i) all relevant federal and state regulations, and (ii) all relevant university policies; 
• Avoid over-commitment of the university resources and faculty and staff time; 
• Ensure that proposals, when awarded, will not create unforeseen financial burdens for the university;
• Avoid situations where an award is declined because the university is unable to meet the commitments set forth in the proposal; 
• Ensure an appropriate match between a sponsor goals and the Principal Investigator’s interests; 
• Ensure that all proposals receive appropriate review and awards are accepted by the Authorized Organization Representative (AOR) who has the authority to sign on behalf of the university;
• Avoid potential criminal, civil, and administrative penalties that could be enforced against the Principal Investigator and/or the university; and
• Minimize the possibility of audit findings.​

The purpose of this Policy is to ensure that Sponsored Projects are led by qualified Principal Investigators who have the technical competence and administrative experience to assume responsibility for successful accomplishment of all aspects of the Sponsored Project.  It is the policy of the University that only Eligible Personnel may serve as Principal Investigators since there must be direct accountability to the University, the Sponsor, and any governmental regulators.

Facilities and Administrative (F&A) or commonly known as overhead, indirect costs, and they are real costs to the university. These costs are difficult to assign to any one specific project without extensive cost accounting procedures. F&A costs cover normal business operations of an institution. Federal granting agencies and most non-governmental entities recognize the existence of such costs. Examples of these costs include: (a) the costs of using the buildings and equipment; (b) accounting, personnel, standard computing, and purchasing expenses; (c) general mail, printing, and copying expenses; (d) library services; and (e) administration.

The University’s current federally negotiated indirect cost rate is 57.6% which should be applied to all salaries, wages and benefits for on campus projects. Many foundations, as well as some state and federal agencies no longer allow the full negotiated rate, but rather allow modest overhead costs to be added to a grant budget.  It is the university policy to charge maximum allowable overhead costs to sponsored research and programs.

Facilities and Administrative Negotiated Rate for Arcadia University (Effective July 1, 2020)

Facilities and Administrative Negotiated Rate for Arcadia University (Ended June 30, 2020)

The purpose of the Financial Conflict of Interest Policy is to promote objectivity in research by establishing guidelines for reporting and resolving financial conflicts of interest for research. This policy is intended to comply with regulations regarding financial conflicts of interest (“FCOI”) for Public Health Service (“PHS”) funded research, 42 C.F.R. Part 50, Subpart F and 45 C.F.R. Part 94 (the “Regulations”). Therefore, this policy applies to each Investigator who is planning to or is participating in PHS-funded research.

FCOI Requirements and Procedures

Principal Investigators/Project Directors and investigators who are involved in proposal submission or award implementation must:

1. Read Financial Conflict of Interest Policy (FCOI);
2. Read Conflict of Interest Policy for Faculty, Staff, Independent Contractors and Volunteers;
3. Submit the Significant Financial Interest (SFI) Disclosure Form 1 at the time of submission of Routing Documents to OSRP and yearly thereafter. In addition, an updated SFI form must be submitted within 30 days of obtaining a new SFI (Significant Financial Interest);
4. Disclose any engagement with entities located outside the US and its territories for which compensation has been or will be received in the 12 months preceding or following the proposal submission.
5. FCOI Training might be required for some submissions.

Arcadia’s FCOI Training Requirement

Principal Investigators/Project Directors and investigators who are proposing involvement in sponsored programs by PHS and non-PHS agencies that accepted FCOI PHS Regulations must complete the online training provided by Collaborative Institutional Training Initiative (CITI) training prior to submission of the proposal to the funding agency. The certificate is valid for 3 years from the date of issue and will need to be retaken during the 4th year.

To access training:

1. Go to the CITI Program website.
2. Click on “Register” if you are a new user, otherwise enter your user id and password.
3. Under “Select Your Organization Affiliation” type Arcadia University into the search box and select it from the pop-up box.
4. Click “Continue to Step 2”.
5. Continue completing each step.
6. Create a username and password according to the instructions provided, and click submit.
7. Continue completing the registration page and submit
8. Select the appropriate course; submit.

At the completion of the training modules you will receive a certificate. Please retain this certificate for your files and provide a copy to OSRP.

This Policy is intended to ensure responsible stewardship of sponsored funding at Arcadia University. The Federal government’s Office of Management and Budget’s (OMB) Guidance for Grants and Agreements at Title 2 of the Code of Federal Regulations, Part 200, Subpart E, entitled “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Cost Principals”),” sets forth principles to be followed by federal funding agencies for the uniform administration of grants, cooperative agreements, and other funding instruments. The University, as a recipient of Federal grants and funds, agrees to efficiently and effectively administer awards through sound management practices that are consistent with the provisions of the Sponsored Award and its terms and conditions. To ensure continued Federal funding for Sponsored Projects and activities, the University must adhere to the requirements set forth in the Cost Principles and all other requirements set forth in Title 2.  The Cost Principles establish the allowability of certain costs for reimbursement from the Federal government related to certain Federal programs and Sponsored Projects at the University and prohibit reimbursement for certain unallowable costs from Federally funded sources.

This Policy is intended to ensure responsible stewardship of Sponsored Awards to the University. As required by the United States Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 C.F.R. § 200.331, Subrecipient and contractor determinations, prior to passing through funds to other entities, the University shall use its judgment in making case-by-case determinations of whether a party receiving funds will be in the role of a Subrecipient or a Contractor. As presented in the associated Subrecipient Monitoring Procedures, prior to issuing a Subaward, the University shall evaluate each Subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions from the Pass Through Entity based upon a data-informed risk assessment questionnaire and apply a monitoring level appropriate to the degree of risk for the Subrecipient. Monitoring activities, if any, shall be presented in the Subaward, which shall include elements required by 2 C.F.R. § 200.332, Requirements for Pass Through Entities. The University shall monitor the Subrecipient’s activities to ensure that the Subaward is in compliance with applicable Federal statutes and regulations and the terms of the Subaward.

Federal Subaward Procedures and Subrecipient Monitoring Guidelines

Arcadia University believes that research misconduct has no place in the academic setting. Arcadia faculty, staff, and students are expected to conduct research in accordance with the highest ethical standards and all relevant regulations. Research misconduct is damaging to the reputation of the university and undermines the integrity and credibility of scholars.

This is a University-wide policy which applies to the research proposed, conducted or reported at Arcadia University by all Arcadia related individuals, i.e. those with the appointment or official affiliation with the Arcadia University including faculty members and staff, as well as part time and adjunct faculty, visiting scholars, members of the research staff, other teaching or research staff with consulting appointments, postdoctoral scholars, technicians, as well as US and foreign students, volunteers, contractors, consultants, subcontractors and  sub awardees, and their employees  involved in research at Arcadia University or elsewhere as a part of the University duties regardless of the funding source.  This policy applies to the research undertaken in fulfillment of a course requirement if there is an expectation of publication, presentation or dissemination outside the University.

Research Misconduct is defined (42 CFR § 93.10) as any fabrication, falsification or plagiarism in proposing, performing or reviewing research or reporting research results. Research misconduct does not include honest error or differences of opinion.

This policy describes the procedure for Arcadia University to comply with the requirements of the Federal Office of Management and Budget’s (OMB) 2 CFR §200.430 which covers compensation for personal services, including requirements for effort certification at educational institutions. The main purpose of effort certification is to verify that salaries and wages supported by sponsored funding were distributed in accordance with the actual level of effort provided.

Effort certification is required for every University employee whose salary or wages are either directly charged to a sponsored account or whose salary or wages are allocated as cost-sharing for a sponsored account. Certifications of effort must be performed in an accurate and timely manner in order to confirm that percentages of pay were truly allocated in accordance with percentages of effort actually performed by an individual.

• Effort Certification Procedure

The Export Control policy (“Policy”) applies to all University Members whose activities, including but not limited to, research activities, grants, contracts and cooperative agreements, may trigger export controls. Export controls are designed to ensure that sensitive information, technology, software, biological and chemical agents, and equipment are not utilized for purposes other than their intended use.

It is the responsibility of all University Members to be aware of and comply with these laws and the University’s policies and procedures. Violation of this Policy may have severe criminal, civil and administrative sanctions, including possible disciplinary action.

The purpose of this Policy is to ensure compliance with the Davis-Bacon Act (DBA) codified as 40 U.S.C. 3141-3148. Under the provisions of the DBA, contractors and subcontractors must pay their laborers and mechanics directly employed upon the site of the work no less than the locally prevailing wages and fringe benefits for corresponding work on similar projects in the area. This Policy includes contractors and subcontractors performing on federally funded contracts in excess of $2,000 for construction, alterations, repairs (including painting and decorating) and also, including craft positions such as plumber, carpenter, cement mason/concrete finisher, electrician, insulator, laborer, lather, painter, power equipment operator, roofer, sheet metal worker, truck driver, and welder.

The purpose of this Policy is to ensure that Cost Transfers to and from Departmental Budgets and sponsored accounts take place according to the specified guidelines set forth in this Policy. The University recognizes that Cost Transfers are sometimes necessary to correct a bookkeeping or clerical cost misclassification in the original charges, and to allocate closely related work that may support more than one Sponsored Project. Frequent, late, or inadequately explained Cost Transfers raise serious questions about the propriety of the transfers and call internal controls into question. This may result in audit disallowances and monetary paybacks including penalties and fines.

Please contact OSRP if you have any questions and we will work with you and the Office of the General Counsel on these matters.