Grant Writing and Research and Sponsored Programs Policy
Authority: Academic Affairs and Enrollment Management
Date Enacted or Revised: February 2016; Revised March 21, 2022
The Office of Research and Sponsored Programs functions as the focal point of the University’s research activities, including collaborative arrangements with external entities that support the University’s mission. All grants, memoranda of understanding, and contracts using University facilities and/or equipment must be routed through the Office of Research and Sponsored Programs for approval, budget verification, reproduction, overhead rate negotiation, and submittal to the appropriate funding agency. Upon award, all grants and contracts are administered by the Office of Research and Sponsored Programs in collaboration with the principal investigator and the Office of Administrative Accounting. The Office of Research and Sponsored Programs maintains a library of grant and contract sources and provides assistance to faculty in grant/contract preparation and submittal.
Grant Writing for External Grants
McNeese encourages faculty to participate in grant writing to support the institution’s mission for educational, economic development, and applied research activities. Grants must have internal approval prior to being submitted to the funding agency. The following is designed to provide general, but not inclusive, guidelines and procedures for submitting grants for internal approval.
- Grant goals and objectives should support the McNeese State University mission. Proposal authors should consult with the Office of Research and Sponsored Programs for the current forms that must be used to submit the proposal electronically and on hard copy.
- Grant proposals, especially those requiring facility renovation or dedication of space, must first be reviewed by the department head, dean, chief information technology officer, and director of facilities and plant operations.
- Once the department head, dean, chief information technology officer, and director of facilities and plant operations approve, grant proposals are submitted to the Office of Research and Sponsored Programs for review. The director of grants development shall be responsible for securing University-authorized signatures and for forwarding proposals to the granting agency.
- Any special co-submission (e.g., letters of support, required documentation from the University, etc.) shall be obtained by the principal investigator with assistance from the director of grants development as appropriate.
- In-kind institutional matches must be justified and approved by the department head, dean, provost and vice president for academic affairs and enrollment management, and Office of Research and Sponsored Programs. Cash matches must have approved institutional budget lines identified by the department, dean, and provost and vice president for academic affairs and enrollment management to cover costs prior to submitting the grant proposal to the granting agency. For budgetary reasons, indirect costs such as release time, visiting lecturer pay to cover courses, tuition waivers, etc., and cash matches are considered in determining distribution of monies generated by a grant. If overhead monies are received from the granting agency, a portion (up to 50%) of these funds may be distributed to the principal investigator (non-salary), department, and college. Funds may be distributed according to the following: 25% to the principal investigator, 15% to the department, and 10% to the college. Prior agreement and approval in writing by the principal investigator(s), department head, dean, provost and vice president for academic affairs and enrollment management, and vice president for business affairs detailing the proposed grant budget and distribution of funds is required.
- Requests for reassigned time must be justified by the dean and must receive prior approval by the provost and vice president for academic affairs and enrollment management. Reassigned time may be limited to one-quarter regular load for an active external grant as deemed appropriate.
- Grant proposals must adhere to all granting agency guidelines, as well as state and federal guidelines and laws. Once execution of the grant has begun, it is the responsibility of the principal investigator to ensure that all guidelines are met.
- Salary paid by grants may be limited as follows: (a) Depending upon agency requirements, employees who earn salaries from grants during paid sabbatical leave may receive a reduced sabbatical salary. All salary payments to faculty must be approved by the Office of Research and Sponsored Programs, provost and vice president for academic affairs and enrollment management, vice president for business affairs, and Office of Administrative Accounting; (b) Graduate students, undergraduate student researchers, and other non-McNeese faculty paid from grants may be paid at a rate that is competitive with University rates and those in the industry. Salaries paid to non-McNeese faculty as matching funds may also be competitive with standard rates. All salary rates must have prior approval from the Office of Research and Sponsored Programs, provost and vice president for academic affairs and enrollment management, and vice president for business affairs.
- Federal and state grants normally have a pre‑negotiated indirect cost rate, usually based on salaries and wages, which may vary from time to time depending on state and federal guidelines.
- Contracts with external entities such as corporations and private individuals may require a negotiated indirect cost rate. The Office of Research and Sponsored Programs assists with determining the appropriate rate.
Sub-Recipient Monitoring Requirements
McNeese State University is responsible for the programmatic and financial monitoring of its sponsored research award sub-recipients. OMB Circular A-110 A.2 (gg) defines a sub-recipient as “the legal entity to which a sub-award is made and which is accountable to the recipient for the use of the funds provided.”
The following is provided to assist principal investigators in ensuring that sub-recipients conduct their portions of research projects in compliance with laws, regulations, and terms and conditions of awards and sub-awards, and that project costs incurred by sub-recipients are reasonable and allowable.
Roles and Responsibilities
1. It is the principal investigator’s responsibility to assess sub-recipient risk as indicated below and to closely monitor the progress and performance of sub-recipients to ensure compliance with federal regulations and both prime and sub-recipient award terms and conditions.
2. The Office of Administrative Accounting is responsible for reviewing invoices from sub-recipients for appropriate expenditures and for monitoring and maintaining related financial reports.
3. The Office of Research and Sponsored Programs has responsibility for ensuring that the University’s sub-recipient monitoring is compliant with federal and other applicable regulations and is consistent with sound business practices. The Office of Research and Sponsored Programs assists faculty in interpreting applicable regulations and sub-recipient award terms and conditions and executing these guidelines. The Office of Research and Sponsored Programs is also responsible for maintaining documentation of monitoring efforts.
4. The principal investigator must advise sub-recipients of flow down provisions imposed on them by federal laws, regulations, and the provisions of contracts or grant agreements as well as any supplemental requirements imposed by the University (dependent on level of risk as determined by the University). The Office of Research and Sponsored Programs provides information that the principal investigator may reference to describe a federal award to each sub-recipient. Resources may include the Catalog of Federal Domestic Assistance (CFDA) title and number, award name and number, award year (if appropriate), and name of federal agency.
5. The principal investigator must monitor the activities of sub-recipients to ensure that funding provided to the sub-recipient is used for purposes authorized in the sub-award agreement in compliance with laws and regulations, and that performance objectives in the agreement are achieved.
6. The Office of Research and Sponsored Programs ensures that sub-recipients expending $500,000 or more in federal awards during the sub-recipient’s fiscal year have met audit requirements. If the sub-recipient has audit findings, the University will review the findings and review the sub-recipient’s corrective action plan to ensure appropriate and timely steps are taken to correct any problems and, if necessary, make adjustment to University policy or procedure. The principal investigator must require each sub-recipient to permit the University and auditors to have access to the records and financial statements as necessary.
7. In addition to the general elements of compliance noted above, there may be additional sponsor- or program-specific requirements that mandate collecting and documenting other assurances (e.g., on lab animals, human subjects, biohazards, etc.) during the course of a project.
Pre-Award Sub-Recipient Risk Assessment
The following factors should be employed to determine the level of risk a particular sub-recipient presents with regards to the threat of improper stewardship:
- Award complexity, extensiveness of the governing regulations;
- Percentage passed through (the larger the percentage of program awards passed through, the greater the need for sub-recipient monitoring);
- Sub-recipient award size; large awards (annual budgets >$500K) would receive substantial and frequent review and monitoring; mid-sized awards (annual budget $100K – $500K) would receive proportionately less substantial and less frequent monitoring; smaller awards (<$100K) would receive general review with the least frequent oversight;
- Prior experience with the sub-recipient, utilizing a new sub-recipient, or an inexperienced sub-recipient;
- Pre-award negotiation indicators regarding knowledge of expectations or granting agency, federal, or state guidelines;
- Financial/operational reporting accuracy and timeliness;
- Timeliness of response to requests;
- Whether the potential sub-recipient is subject to an A-133 audit or other federal financial review;
- Level of external oversight by auditors or sponsor agency;
- Evidence of effective financial controls within the sub-recipient’s systems and administrative operations through review of the organization’s audit reports, management letter, or other acceptable documentation;
- Sub-recipient location (remoteness from McNeese may mandate more oversight); and
- Sub-recipient organization type (for-profit/not-for-profit/small business, etc.).
The frequency and scope of monitoring procedures should be determined and agreed upon by the principal investigator, Office of Administrative Accounting, and the Office of Research and Sponsored Programs. Initial monitoring decisions are made based on the above review criteria. Risk assessment status can be subject to change pending findings during routine monitoring procedures. If it is determined that a sub-recipient requires closer scrutiny, appropriate measures must be taken to ensure compliance with sub-agreement performance, financial terms and conditions, and with all applicable federal rules and regulations. Administrators at such sub-recipient sites may be asked to complete questionnaires (to be filed at McNeese) documenting internal controls and grants management procedures.
Grant Recipient Time and Effort Reporting Requirements
Faculty and staff participating in active externally sponsored projects must complete the Time and Effort Report Form provided by the Office of Research and Sponsored Programs. The Office of Management and Budget Circular No. A-21 Cost Principles for Educational Institutions establishes principles for determining costs applicable to grants, contracts, and other agreements with educational institutions. Particularly, Section J (10) (c) requires that work performed directly on sponsored agreements and for other work allowable as costs are identified and documented by the institution. The Time and Effort Report serves two purposes:
1. To certify that time for which funds paid to an individual from a grant was actual time spent working on that particular grant; and
2. To certify that time shown as cost sharing was actual time spent working on a particular grant but charged to another cost center.
Individuals must report time and effort if they are paid directly from a grant or if there is a cost match commitment of time on at least one sponsored project. It is the responsibility of the principal investigator of a grant to obtain all Time and Effort Reporting forms for the individuals working on the grant. (Note: Funds from a federal grant cannot be used as cost match to another federal grant.)
The Time and Effort Reporting form is available from the Office of Research and Sponsored Programs.
Grant Accountability and Management
Faculty and employees receiving grants are responsible for comprehensive knowledge of and compliance with policies and procedures for grant management. Federal grants require specific attention to applicable regulations. Principal investigators who include students for grant work are responsible for supervising students. Improper grant management may result in suspension of both current and future grant activities. Many federal or state statutes impact the administration of government grant awards. A list of examples includes the information below; other regulations may apply. Note: Legislative acts are part of the U.S. Code. Executive orders are part of the Code of Federal Regulations (CFR). The following are some legislative acts and executive orders that apply to federal grants.
- Equal Employment Opportunity: All contracts awarded by grantees and their contractors and sub-recipients having a value of more than $10,000 must contain a provision requiring compliance with Executive Order 11246, entitled “Equal Employment Opportunity” as amended by Executive Order 11375, and as supplemented in Department of Labor regulations (41 CFR, Part 60).
- Copeland “Anti-Kick Back” Act (18 U.S.C. 874): All contracts and sub-grants in excess of $2,000 for construction or repair awarded by grantees and sub-recipients shall include a provision for compliance with the Copeland “Anti-Kick Back” Act (I8 V.S.C. 874) as supplemented in Department of Labor regulations (29 CFR, Part 3). The Act provides that each contractor or sub-recipient shall be prohibited from inducing, by any means, any person employed in the construction, completion, or repair of public work, to give up any part of the compensation to which they are otherwise entitled. The grantee shall report all suspected or reported violations to the federal awarding agency.
- Davis-Bacon Act (U.S.C. 276a to a-7): All construction contracts awarded by the grantee and sub-recipients of more than $2,000 shall include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 276a to a-7) and as supplemented by Department of Labor regulations (29 CFR, Part 5). Under this Act, contractors shall be required to pay wages to laborers and mechanics at a rate not less than the minimum wages specified in a wage determination made by the Secretary of Labor. In addition, contractors shall be required to pay wages not less than once a week. The grantee shall place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation and the award of a contract shall be conditioned upon the acceptance of the wage determination. The grantee shall report all suspected or reported violations to the federal sponsoring agency.
- Contract Work Hours and Safety Standards Act (40 U.S.C. 327-330): Where applicable, all contracts awarded by grantees in excess of $100,000 for construction contracts and other contracts that involve the employment of mechanics or laborers, shall include a provision for compliance with sections 102 and 107 of the Contract Work Hours and Safety Standards Act (40 U.S.C. 327-330) as supplemented by Department of Labor regulations (29 CFR, Part 5). Under section 102 of the Act, each contractor shall be required to compute the wages of every mechanic and laborer on the basis of a standard work day of eight hours and a standard work week of 40 hours. Work in excess of the standard work day or work week is permissible provided that the worker is compensated at a rate of not less than 1/2 times the basic rate of pay for all hours worked in excess of eight hours in any calendar day or 40 hours in the work week. Section 107 of the Act is applicable to construction work and provides that no laborer or mechanic shall be required to work in surroundings or under working conditions which are unsanitary, hazardous, or dangerous to their health and safety and health standards promulgated by the Secretary of Labor. These requirements do not apply to the purchases of supplies, materials, or articles ordinarily available on the open market, or contracts for transportation or transmission of intelligence.
- Bayh-Dole Act or Rights to Inventions and Materials Generated Under a Contract or Agreement (CFR 37 401): Public Law 96-517 changed the presumption of title to any invention made by small business, universities, and other non-profit entities through the use, in whole or in part, of government funds to the contract or grantee. Another factor, often overlooked, is that the Act did away with the distinction between grants and contracts, which agencies had often made when dealing with universities, a distinction which a number of agencies rigorously applied in their zeal to retain rights to intellectual property as a contractual obligation.
- Clean Air Act of 1970 (42 V.S.C. 7401 et seq.) and the Federal Water Pollution Control Act (33 V.S.C. 1251 et seq.) as Amended: Contracts and sub-grants of amounts in excess of $100,000 shall contain a provision that requires the recipient to agree to comply with all applicable standards, orders, or regulations issued pursuant to the Clean Air Act of 1970 (42 V.S.C. 7401 et seq.) and the Federal Water Pollution Control Act as amended (33 V.S.C. 125 I et seq.). Violations shall be reported to the federal sponsoring agency and the regional office of the Environmental Protection Agency (EPA).
- Byrd Anti-Lobbying Amendment (31 V.S.c. 1352): Contractors who apply or bid for an award of $100,000 or more must file a certification with the grantee stating that they will not and have not used federal appropriated funds to pay any person or organization for influencing or attempting to influence an officer or employee of any agency, a member of Congress, officer or employee of Congress, or an employee of a member of Congress in connection with obtaining any federal contract, grant, cooperative agreement, loan, or any other award covered by 31 V.S.C. 1352. Such contractors must also disclose to the grantee any lobbying that takes place in connection with obtaining any federal award.
- Debarment and Suspension (E.O. 12549 and 12689): No contracts shall be made to parties listed on the General Services Administration’s Lists of Parties Excluded from Federal Procurement or Non-Procurement Programs in accordance with Executive Orders 12549 and 12689. These lists contain the names of contractors debarred, suspended, or proposed for debarment by agencies, and contractors declared ineligible under other statutory or regulatory authority other than Executive Order 12549. Grantees are required to obtain a certification regarding debarment and suspension from all sub-recipients and from all parties with whom they contract for goods or services when (1) the amount of the contract is $100,000 or more, or (2) when, regardless of the amount of the contract, the contractor will have a critical influence or substantive control over the covered transaction. Such persons would be project directors and providers of federally required audit services.
- The Drug-Free Workplace Act of 1988, 41 V.S.C. 701: Requires grantees to have an ongoing drug-free awareness program; to publish a statement notifying employees that the unlawful manufacture, distribution, dispensing, possession, or use of a controlled substance is prohibited in the grantee’s workplace; to maintain evidence that this statement was given to each employee engaged in the performance of the grant; and to identify in the funding proposal or to keep on file in its office the place(s) where grant activities will be carried out.
- Title VI of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972 (as amended), Section 504 of the Rehabilitation Act of 1973 (as amended), the Age Discrimination Act of 1975 (as amended): Therefore, no person on grounds of race, color, national origin, disability, or age shall be excluded from participation in, be denied the benefits of, or be otherwise subject to discrimination under a program funded by the federal government. In addition, if a project involves an educational activity or program, as defined in Title IX of the Education Amendments of 1972, no person on the basis of sex shall be excluded from participation in the project. Grantees shall at the time of application certify that their programs operate in compliance with the requirements of the nondiscrimination statutes and their implementing regulations. Grantees are also required to obtain an executed certification of compliance with the nondiscrimination statute from all organizations that are sub-recipients under a grant.
- Research Misconduct: In accordance with 42 CFR Part 50, Subpart A, any institution receiving federal grant support will inquire into and, if necessary, investigate and resolve promptly and fairly all instances of alleged or apparent research misconduct. Research misconduct is defined as fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results.
- Buy American Act: Consistent with the Buy American Act, 41 V.S.C. 10a-c and Public Law 105-277, grantees and sub-recipients who purchase equipment and products with grant funds should purchase only American-made equipment and products.
- Welfare-to-Work Initiative: To supplement the welfare-to-work initiative, grantees and their sub-recipients are encouraged, whenever possible, to hire welfare recipients and to provide additional needed training and/or mentoring.
- Seat-Belt Usage. Executive Order 13043 of April 16, 1997: Requires each federal agency to encourage contractors, sub-contractors, and grantees to adopt and enforce on-the-job seat belt policies and programs for their employees when operating company-owned, rented, or personally owned vehicles.
- Military Recruiting and ROTC Program Access to Institutions of Higher Education. Section 588 of the National Defense Authorization Act of 1995, as implemented in 32 CFR Parts 23 and 216: Precludes grant awards to schools that the Department of Defense (DoD) determines have an anti-ROTC (Reserve Officer Training Corps) policy or practice (regardless of when implemented) that either prohibits or, in effect, prevents the Secretary of Defense from gaining entry to campuses or access to students or information for military recruiting purposes. The DoD publishes each determination of ineligibility in the Federal Register as well as publishing, once every six months, a list of all currently ineligible schools.
- Title IX Education Amendments of 1972: Title IX bans gender discrimination at institutions that receive federal funds. Most often applied to athletics, the law also applies to participation of women in the sciences, particularly under federal grant. The onus of enforcement is on universities, but agencies are also required to develop and implement procedures for investigating complaints. The Government Accounting Office issued a report on this topic on July 22, 2004 (see www.gao.gov/new.items/d04639.pdf).
Principal Investigators should review the General Standards of Professional Ethics for Conducting Research and Sponsored Programs Policy for additional information.
This policy is distributed via the Academic Advisory Council and the University Policies webpage.