I’d also want to modify F. under “Sponsored Project.” If services require approval or monitoring (IRB, IACUC, export control, what have you), it should be under
the sponsored project umbrella even if the funds come in under a gift transaction. We might not have any responsibility to report back to the donor, or to return any unspent funds, but we would still have a duty to ensure that appropriate precautions were
in place, and that the services being provided were covered by an approved protocol—and most foundations aren’t set up for that sort of monitoring.
It’s the departmental funds that are tricky on that point. If it’s the department’s own money (e.g., some kind of annual allocation to a faculty member or center),
then they’d still need to be compliant with the applicable approval and monitoring processes for the work being done, but the funds could potentially still be tracked through their regular departmental accounting procedures. But if the department was being
paid by an outside source, then I think the work would still need to be classed as a sponsored project and tracked that way. It’s one thing if somebody just wants to pay to run spectral analyses on some sample compounds. It’s something else if they want to
introduce those compounds into animal or human subjects.
Michael Spires, M.A., M.S., CRA
Principal Proposal Analyst
Office of Contracts and Grants
Woodbury 401, 572 UCB
University of Colorado Boulder
Boulder, Colorado 80309-0572
O (303) 492-6646
F (303) 492-6421
E
xxxxxx@colorado.edu
W
www.colorado.edu/ocg
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org]
On Behalf Of Carolyn Elliott-Farino
Sent: Tuesday, January 31, 2017 6:35 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Sponsored Program or Auxiliary Service
Dara,
Excellent question. We are about to start grappling with this ourselves. We have handled a variety of external funding activities through our office but now have
to carve out the “departmental sales and service” activities. It’s in quotes because defining that is where the rubber will meet the road.
It figures that the chart is from UMN – that’s the place to go to for policies! I like the chart, but would need to modify some of the definitions for our institution.
For example, a non-profit awards a grant to a researcher and there is no direct economic benefit, no milestones, nor must the U return the funds. A final report is required, but it is not “extensive.” To me that is under our mission, not the Foundation’s,
but at UMN that would go to the UMN Foundation. Maybe it would be a project that would be referred to the working group.
“Services” is listed under both sponsored project and external sales. I would modify SP E. to say, “The contract is for services and requires the University to
separately account for the funds in its accounting system.” With a contract, we often receive some funds up front, and/or bill per milestones. We have entered into an agreement to provide services for X dollars and have a responsibility to provide such services,
no matter the cost. We would have a budget to guide the project and help ensure that we use the funds received to perform the services. For those reasons, we would set up a project account to manage the funds and ensure the deliverables are met and not spend
more than what was awarded.
Those are quick reactions – I think the document does a great job clarifying how funds should be handled, but for our purposes I’d need to revise it, revise
being the operative word. I wasn’t aware this was out there, so thank you for your question and sharing this chart because it will be helpful for my institution as we move forward with some changes in the next few months.
Carolyn
Carolyn Elliott-Farino
Executive Director, Office of Research
Kennesaw State University
xxxxxx@kennesaw.edu; 470-578-6381
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org]
On Behalf Of Dara Little
Sent: Monday, January 30, 2017 6:36 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Sponsored Program or Auxiliary Service
Hi Sandra, all –
Sorry, I wasn’t clear (late in the day!). The policy is to establish proper institutional buckets and procedures for managing all external funds coming into the university.
In my perfect world I’d get us to something like this:
http://www.ospa.umn.edu/announcements/documents/GiftGrantExternalSaleBucketPosterVersion6.pdf
Dara
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org]
On Behalf Of Sandra Nordahl
Sent: Monday, January 30, 2017 5:25 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Sponsored Program or Auxiliary Service
Hi Dara,
I think the key is in your last sentence of the second paragraph. Are you entering into an agreement to provide an integral component of the sponsored program activity or are you purchasing
item(s) or services that can be provided from a variety of vendors and those vendors provide the product service to several clients as a course of business. Refer to Uniform Guidance 200.330, subparts (a) and (b). I hope this helps!
Sandra
Sandra M. Nordahl, CRA
Director, SR Contracting and Compliance
and Facility Security Officer
San Diego State University Research Foundation
5250 Campanile Drive
San Diego, CA 92182-1934
email: xxxxxx@foundation.sdsu.edu
Twitter: @SMNSandiego
voice: 619.594.4172
fax: 619.582.9164
www.foundation.sdsu.edu
and
Past President
Society of Research Administrators International
www.srainternational.org
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Please consider the environment before printing this email.
On Mon, Jan 30, 2017 at 2:52 PM, Dara Little <xxxxxx@niu.edu> wrote:
I’m spearheading an institutional policy to differentiate between sponsored programs, gifts, and sales/auxiliary programs.
The gift piece is well in hand but I would like to hear from folks who have had success in defining contracts that come through as a sponsored award versus those that are managed at the unit level as part of their routine sales and services.
Any advice appreciated. Feel free to email me off-list.
Thanks,
Dara
Dara C. Little, MPA, CRA
Assistant VP for Research and Sponsored Programs
Sponsored Programs Administration
Division of Research and Innovation Partnerships
Northern Illinois University
DeKalb, IL 60554
(Direct) 815-753-9285 (Main) 815-753-1581
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