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Rice University Research Policy No. 301-83

 

POLICIES AND PROCEDURES FOR THE MANAGEMENT AND ADMINISTRATION OF SPONSORED PROJECTS  


I. INTRODUCTION  

This memorandum is a guide to assist principal investigators, program chair and project leaders in the management of research or other scholarly projects and expresses University policies and procedures in research related matters and activities. It contains specific information for proposal preparation and submission and for the administration of on-going research projects. The guide supplements, but does not supersede, instructions issued through other Rice University policy memorandums and research policy memorandums and bulletins.

Principal investigators and others responsible for sponsored projects should read their grant and contract documents carefully and be familiar with all requirements, terms, conditions, etc. stated therein.  


II.GENERAL POLICIES ON SPONSORED RESEARCH  

Sponsored research should be proposed and carried out within a regular department of the University, or through the cooperation of several departments, and be led by a member of the faculty or authorized professional research staff. Major research projects should be clearly related to the academic programs of the department or departments involved and provide opportunities for graduate and/or undergraduate research training.

The budget should be adequate for the work proposed including student support, possible salary increases and computer services, and fringe benefits and indirect costs at standard rates. Results of all research should be routinely offered for examination and publication, as appropriate.

In accepting sponsored research, the University, the departments, and members of the faculty or staff accept obligations to furnish:

1. An appropriate share of the time and talent necessary to perform the research.

2. Reports and publications describing the research performed and the results achieved.

3. Compliance with all terms and conditions of the grant or contract, such as those covering patents, copyrights, property, travel, etc. and the timely submission of all technical and administrative reports.

Research and study on the part of the faculty are essential elements of University work. Accordingly, members of the faculty are encouraged to undertake research of special interest to them, for both governmental and private organizations. Individual researches are free to pursue interesting and important leads which may arise during the conduct of research, subject only to the terms of the research agreement and regulations of the sponsor.

The University recognizes the magnitude of current research problems in both the scientific and humanistic disciplines and interdisciplinary research is encouraged. It is, however, anticipated that those faculty members jointly interested in an interdisciplinary problem will team together under the overall guidance of a leader who will be directly responsible for the conduct of the project.

The right to publish research results in appropriate journals should not be relinquished. However, where justified in certain cases involving research projects completely supported by external funds, publication may be postponed for reasonable periods of time. The support of sponsors should usually be acknowledged in publications.

A research agreement is executed between the supporting agency and the University. While the principal investigator is responsible for the technical work and is obliged to comply with all terms of the agreement, the University is always the grantee or the contractor.

Federal research agreements normally require retention of records for a period of three to six years after final close-out of a research agreement. The Office of Advanced Studies and Research is designated as the official office of record for all matters pertaining to the technical and administrative management of the research agreement; the controller's department is similarly designated for all matters pertaining to fiscal records. Any individual originating or receiving correspondence pertaining to a research agreement will provide a copy thereof to the research administrator.


III. ADMINISTRATIVE RESPONSIBILITIES CONCERNING SPONSORED RESEARCH PROJECTS  

The Principal Investigator  

In initiating a sponsored research proposal, the faculty or authorized staff member assumes responsibilities and obligations which begin with the preparation of the proposal and continue throughout the conduct of the research program. A final report and other grant/contract closing documents are essential requirements. The research project is not concluded until these responsibilities are fulfilled.

As a principal investigator, project director/leader, etc., the faculty or research staff member is responsible for the following:

1. That the research is soundly based; its primary goal is a significant contribution to knowledge and that the personnel involved are qualified.

2. That the budget is adequate to accomplish the research.

3. That the necessary time and talent is available for commitment to the proposed research and for compliance with the terms and conditions of the grant or contract, including those covering reports and publications.

4. Identification of requirements for matching funds or cost sharing and determining or locating sources for such support.

5. Compliance with safety standards and regulations.

6. The legitimate expenditure of grant/contract funds. No funds will be used for purposes not allowable by University policy and/or regulations of the sponsor.

The Academic Department  

In supporting sponsored research activities by its faculty and research staff, departments assume certain responsibilities. The department chair's approval of a proposal certifies to the following:

1. Compliance with existing University and departmental policies.

2. Academic/scholarly considerations and the professional and scholarly quality of the project.

3. The competence of the principal investigator in the area of research.

4. The ability of the principal investigator to successfully manage the proposed research project.

5. That the research project relates to the academic objectives of the department and provides opportunities for graduate and/or undergraduate research training.

6. The capability of the department to provide necessary administrative support (personnel and supplies).

7. The availability of departmental facilities and equipment to fulfill project needs.

8. The adequacy of the budget and the determination of the department to prevent cost overruns.

9. The recognition of applicable safety standards and regulations and the existence of plans for appropriate action to comply with them.

The Vice President, Advanced Studies and Research  

The Vice President, AS&R, assisted by the research administrator, shall review sponsored research proposals for compliance with policies of the University and the potential sponsor with particular attention given to the following:

1. Contributions to the principal objectives of the University

  • The education of undergraduate and graduate students and post-doctoral researchers
  • The advancement of knowledge through research and scholarship
  • The advancement and protection of the public interest and public welfare.

2. Research shall be proposed and carried out within a regular department of the University, or through the cooperation of several departments, and be led by a member of the faculty or authorized professional research staff.

3. The relationship of research activities to the educational mission of the University.

4. The free publication of results.

5. University administrative control and responsibility for the work.

6. No sponsor or other external party shall be allowed a continuing role in the scientific direction of the research.

7. Reimbursement of the indirect expenses as well as the direct costs of the research.

The Research Administrator  

The research administrator at Rice University is responsible for the following:

1. The review of all research proposals to insure compliance with policies of the University and instructions of sponsoring agencies.

2. The administration of research grants and contracts between Rice and sponsoring agencies.

3. The administration of University programs for the support of research.

4. Assisting University personnel in locating potential sources of funding for research, fellowships, and other scholarly activities.

5. The collection and dissemination of appropriate data regarding sponsored and unsponsored research.


IV. THE UNIVERSITY RESEARCH COUNCIL  

Purpose  

The Rice University Research Council is responsible for the adequacy and appropriateness of general University policies concerning sponsored research and for the enhancement of research.

Duties  

The council shall meet at the call of the chair to consider such new policy or changes and such research promotional activities as may be deemed to be appropriate.

The minutes of all meetings of the council and such recommendations as the council may wish to make shall be recorded in writing and submitted to the Vice President, Advanced Studies and Research.


V. PROPOSAL PREPARATION  

Introduction  

This section prescribes the standard procedures and forms for submitting proposals for sponsored programs, including those for research, educational activities, facilities, equipment, and service activities.

General Procedures  

The process of obtaining research support starts with a proposal written by a member of the faculty or authorized research staff. It is reviewed by appropriate department and University officials, and submitted to potential sponsors. After grant or contract terms and conditions are negotiated and an award is made, a University account for the funds is established. The research activity is directed by the principal investigator who is also responsible for the timely submission of reports to the sponsor . Since the grant or contract is a binding legal agreement between the sponsor and the University, the University must play a significant role in the project administrative process.

Types of Proposals  

1. Proposals for "Research" are those for the support of any form of original work, including the writing of articles or books or other forms of scholarly investigation.

2. Proposals for "Education Activities" are those for the improvement of instruction, teacher training programs, institutes, conferences, symposia, seminars, continuing studies programs, etc.

3. Proposals for "Facilities" are those for support of all or part of a new building, an annex to a building, renovations, etc.

4. Proposals for "Equipment" include those for all types of permanent equipment including research equipment, instructional equipment, apparatus, etc.

5. Proposals for "Service Activities" include those involving service to some segment of the local community, service to the city, state, or country, service to another school or consortium of schools, etc.

Preparing Proposals

1. In preparing a proposal for any sponsored program, the principal investigator will be expected to avail himself, or herself, as appropriate and needed, of the advice and counsel of fellow members of the faculty, the chair of the department, the division dean, and the University Office of Advanced Studies and Research. The proposal will be typed in the proper form with an appropriate cover page and an action brief. The original and four copies will be submitted by the principal investigator to the chair of the department. Of this number, one copy is for retention by the chair of the department, one is for the divisional dean and two copies are required by the Office of Advanced Studies and Research. (One of the latter two goes to the research accountant at the time the project is funded. The other copy will be the AS&R file copy.) Additional copies are usually required by sponsoring agencies. The number prescribed should be submitted directly to the potential funding source, after approval by AS&R and the PRESIDENT.

2. To simplify the submission of proposals for sponsored programs, and to provide a record of approval by each person or office involved, the "ACTION BRIEF" form will be used for the on-campus routing of all proposals.

On-Campus Routing of Proposals

1. Proposals for research will go from the initiating faculty member to the following, in turn:

Department Chair
Vice President, Advanced Studies and Research
Assistant to the President
President

2. Proposals for educational programs , including continuing studies, facilities , equipment , and service programs , will go from the initiating faculty member to the following, in turn:

1. Department Chair

2. Dean of the School or Academic Division concerned

3. Vice President, Advanced Studies and Research

4. Assistant to the President

5. President

3. All proposals that include matters of significance regarding the procurement, use, modification or construction of facilities and plant equipment will be routed to the vice president for administration (and his signature on the action brief) before going to AS&R.

4. All proposals to private foundations, individuals, corporations, consortiums, etc., other than those to such organizations that regularly support sponsored programs at Rice, will be routed to the Vice President for Administration for coordination, (and his signature on the action brief form).

Proposal Review and Approval  

1. Only the president personally, or, under certain special circumstances a person specifically designated by the president, may sign a proposal for the institution and thus commit the University. Principal Investigators will submit their proposals without having the name and title of the approving institutional official typed in. This will be completed in the office of AS&R following signature.

2. Before initiating a proposal and starting it on its way, the faculty Principal Investigator must insure that it is complete in all respects. He or she should anticipate potential problem areas and questions that may arise out of the on-campus reviews and attach such explanatory memoranda as may be deemed appropriate. Doing this will almost always save time in the long-run. In particular, the sources of necessary matching funds must be determined in advance and clearly indicated on the accompanying action brief. If appropriate, the concurrence of University officials who may have an interest shall be obtained in writing.

3. The Chair of the Department reviews proposals for compatibility with the intellectual aims and fiscal responsibility of the department.

4. The Dean of the School or Division (as required) reviews proposals for compatibility with the intellectual aims and fiscal responsibilities of the unit.

5. Proposals for interdisciplinary programs involving faculty from more than one division or school should be approved by all of the department chairmen and deans involved, as appropriate.

6. The University Office of Advanced Studies and Research reviews proposals from the standpoint of the academic, fiscal, administrative and other requirements of the University and arranges for such changes as may be considered to be necessary. Proposals are then submitted to the President for his review and approval in the name of the University.

7. The Office of the Research Administrator will notify the department or the principal investigator after the president has affixed his approving signature. It shall be the responsibility of the investigator, or the department, to pick up the signed original and to mail or deliver the original, plus the number of copies required by the agency concerned, to the potential sponsor before their deadline.

Essential Funding to be Sought  

1. Fringe benefits and indirect costs must, of course, always be fully included at the established rates in all proposal budgets, except where specifically precluded by written instructions of the potential sponsor.

2. In addition to fringe benefits and indirect costs, proposal budgets should include funding requests for the items listed below where it is expected that expenditures will be required for such items during the conduct of the proposed project, except where specifically precluded by written instructions of the potential sponsor.

  • Computing
  • Staff (shop, secretarial, etc.)
  • Academic year/summer salary for faculty
  • Postdoctoral
  • Graduate student, stipends, to include that necessary for the student to pay tuition, as required
  • Consumable supplies/special materials
  • Miscellaneous services (maintenance, analytical, consulting, etc.)
  • Long distance telephone calls
  • Travel
  • Equipment
 

Time Required to Clear the University  

Faculty members should keep in mind the date set by sponsors for the receipt of proposals in relation to the time it takes for university review and approval, and for mail delivery. Under normal circumstances, processing requires three or more working days, but unless proposals are received by the Office of Advanced Studies and Research at least five working days before the date that it must be mailed , timely mailing cannot be assured.

Important Reminders  

1. Occasionally, because of departures from our standard procedures, some difficulties, embarrassments, and misunderstandings occur. Principal investigators should note, that whenever any of the fiscal aspects of a proposal, or of an award already made, are to be altered in any way, the communication of such changes should proceed through the same channels as a proposal. In particular, changes in the budget of a contract or grant and requests for no-cost extensions, should be communicated to the sponsor via the Office of Advanced Studies and Research to assure official sanction. This is important because the financial terms of any grant or contract or other agreement are legally binding upon the University. Faculty members cannot make legal commitmen ts or negotiate sub-contracts except through AS&R and with the approval of the president.

2. When a member of the faculty communicates informally with any sponsoring agency or office regarding a possible sponsored program of any kind, a broad approximation of the total cost of the program may be given but no detailed budget should be submitted. Only the president or persons specifically designated by him or her can commit the University in the matter of indirect costs, university-sharing of costs, or other matters which are properly the responsibility of the University administration.

3. The principal investigator may have supporting personnel consisting of one or more postdoctoral researchers, professional specialists, graduate students, undergraduate students, laboratory technicians, secretaries, etc., as properly required for the successful completion of sponsored work, provided funds are available under a given grant or contract to cover the full cost of such supporting personnel, including stipends, graduate tuition, fringe benefits, computing, publishing, equipment, supplies, travel, indirect costs, etc. It should be understood by everyone that no commitments of long range or permanent employment can be made for any category of such personnel under any sponsored program.

4. The Office of Advanced Studies and Research is very anxious to be of service to all members of the faculty and staff of the University in connection with all phases of sponsored programs.

Helpful Suggestion for the Smooth Processing of Proposals  

It is the duty of the Office of Advanced Studies and Research to see that your proposal is submitted in the best possible form and each proposal is given a close and careful review. Several common mistakes occur in the preparation of a research proposal and the following suggestions should help to avoid these mistakes and insure the smooth processing of your proposal.

1. Be sure to check the budget carefully. Make sure that the current rates for fringe benefits and indirect costs have been used in the preparation of the budget.

2. Make sure that all necessary forms are included with the proposal (i.e. the Action Brief, the proper cover page, etc.). If the proposal is in response to an R.F.P. or some other solicitation or request, please be sure to include all the information regarding such solicitations.

3. If any questions or problems arise during the preparation of the proposal, please contact the Office of Advanced Studies and Research (ext. 4820) rather than waiting until the proposal is completed and sent through for processing. This precaution may save you and AS&R valuable time and unnecessary revisions later.

VI. RESEARCH GRANT AND CONTRACT ADMINISTRATION  

Research Projects Involving Human Subjects  

The Department of Health and Human Services (DHHS), regulation 45 CFR 46, provides a systematic means, based on established ethical principles, for protecting the rights and welfare of individuals who may be exposed to the possibility of physical, psychological, or social injury while they are participating as subjects in research, development, or related activities. The regulation extends to the human fetus (either in utero or ex utero), the dead, organs, tissues, and body fluids, and graphic written, or recorded information derived from human sources. It covers activities which present no physical risk to the subjects, but which may create legal risks or expose subjects to public embarrassment or humiliation through breach of confidentiality or invasion of privacy. The major focus of a project (for example, on a medical procedure) may not be the sole determinant of the types of risks involved or the need for additional protection. The safeguarding and confidentiality of medical records and other forms of data collected on individuals and groups, the use of such data by the principal investigator conducting the original research, concurrent uses of the data by other investigators, and the use of the data for research purposes at a later time are considered within the scope of this policy.

The regulation requires institutional assurances, including the implementation of procedures for review, and the assignment of responsibilities for adequately protecting the rights and welfare of human subjects. Safeguarding these rights and welfare is, by DHHS policy, primarily the responsibility of the applicant organization. In particular, the applicant organization is responsible for ensuring that the activity described in the application and additional information relating to human subjects, derived materials or data are reviewed and approved by an Institutional Review Board (IRB).

If a proposal involves human subjects, PHS requires that the principal investigator shall, under the heading HUMAN SUBJECTS, DERIVED MATERIALS OR DATA, at the end of research plan section of the application, provide the following information:

1. Identify the sources of the potential subjects, derived materials or data. Describe the characteristics of the subject population, such as their anticipated number, age, sex, ethnic background, and state of health. Identify the criteria for inclusion or exclusion. Explain the rationale for the use of special classes of subjects, such as fetuses, pregnant women, children, institutionalized mentally disabled, prisoners, or others, especially those whose ability to give voluntary informed consent may be in question.

2. Describe the recruitment and consent procedures to be followed, including the circumstances under which consent will be solicited and obtained, who will seek it, the nature of information to be provided to prospective subjects, and the methods of documenting consent. (A copy of the consent form is required by PHS staff for review purposes.)

3. Describe any potential risks - physical, psychological, social, legal, or other - and assess their likelihood and seriousness. Describe alternative methods, if any, that were considered and why they will not be used.

4. Describe the procedures for protecting against or minimizing any potential risks and include an assessment of their likely effectiveness. Include a discussion of confidentiality safeguards, where relevant, and arrangements for providing medical treatment if needed.

5. Describe and assess the potential benefits to be gained by the subjects, as well as the benefits that may accrue to society in general as a result of the planned work.

6. Discuss the risks in relation to the anticipated benefits to the subjects and to society.

Institutional Review Board for the Protection of Human Subjects at Risk  

The purpose of the Rice University Institutional Review Board is to provide for the adequate discharge of the University's legal responsibility for safeguarding the rights and welfare of research subjects at risk.

The board functions to:

1. Review proposed research projects and activities involving human subjects.

2. Review on-going research projects and activities involving human subjects.

The Board will determine for each activity as planned and conducted:

1. Whether subjects will be placed at risk, and if risk is involved whether:

  • a. The risks to the subject are so outweighed by the sum of the benefit to the subject and the importance of the knowledge to be gained as to warrant a decision to allow the subject to accept these risks.
  • b. The rights and welfare of any such subjects will be adequately protected.
  • c. Legally effective informed consent will be obtained by adequate and appropriate methods.
  • d. Emergency medical treatment is reasonably available.

     

2. The time intervals at which the board will meet to provide for continuing review. Continuing reviews must be conducted and reported on at least annually.

Research Projects Involving Recombinant DNA Molecules  

Research by Rice University personnel involving recombinant DNA molecules, regardless of sponsorship or sources of funding, will be conducted only with the approval and under the cognizance of the Rice University Institutional Biosafety Committee (IBC), and in accordance with the Guidelines for Research Involving Recombinant DNA Molecules, published by the National Institutes of Health. (Policy Memorandum 321-year.)

The purpose of the Institutional Biosafety Committee is to insure that recombinant DNA activities at Rice University comply with the guidelines, and are conducted safely.

All research proposals and projects known or appearing to involve recombinant DNA shall be referred to the committee. Further, the committee must be notified before any research involving recombinant DNA is initiated, whether or not it is externally funded. The committee will visit and inspect each laboratory in which recombinant DNA research is to be conducted and review with the investigator(s) and other personnel concerned the procedures for complying with the guidelines of the NIH and other sponsors of research involved. Follow-up visits and inspections will also be conducted by the committee.

The Rice University Biosafety Committee will function to:

1. Advise the University administration on policies.

2. Review applications for the support of research involving recombinant DNA molecules to insure that the facilities, procedures and practices and expertise of the personnel involved are satisfactory and, if approved by the committee, to certify such on the application.

3. Review the actions of principal investigators involved with recombinant DNA research to insure that proper safeguards are implemented and that the responsibilities of the principal investigator, and others, as specified in Part IV (Roles and Responsibilities) of the guidelines are carried out.

4. Review ongoing research at least annually and, if approved by the committee, to certify such to the President.

Animal Welfare  

The care and use of laboratory animals are governed by The Laboratory Animal Welfare Act, Public Law 89-544, as amended, and such instructions and guides as may be issued by the National Institutes of Health (OPRR).

The Rice University Animal Welfare Committee shall be composed of at least five members who are knowledgeable regarding the care and use of animals used in research, including at least one veterinarian. The committee shall maintain oversight of animal facilities and procedures reviewing them at least annually and reporting to the Vice President, AS&R.

Grant or Contract Negotiations  

Administrative negotiations for all grants and contracts and other research agreements are the responsibility of the research administrator. All negotiations will, or course, be closely coordinated with the principal investigator.

Project Accounts  

All grants or contracts should be officially received for the University by the research administrator. Awards transmitted directly to principal investigators, departments, etc. should be delivered immediately to the research administrator to facilitate activation. The research accountant in the controller's department will make the funds available to the principal investigator through a separate account.

Principal investigators are furnished a copy of each grant or contract. They should review the document carefully, with particular attention to the scope of work, budget limitations and report requirements. The research administrator will be responsible for negotiation and compliance with the general terms and conditions which, in the case of some contracts, may amount to several pages of "boiler-plate" provisions.

A grant or contract is a legal binding agreement between the sponsor and Rice University, on behalf of the principal investigator.

Any questions concerning the agreement, or any modification in terms or cost, are to be referred to the research administrator.

Project Performance  

After a contract or grant has been received and an account has been established, the principal investigator is responsible for initiating requests for personnel appointments and for the purchase of any materials or supplies needed by the project. Offices throughout the University are available to help, but unless he/she signals requirements clearly and at the proper time, things will not get done. For assistance with any administrative problems that arise during initiation or conduct of the research, the project leader should consult with the research administrator.

One of the most important responsibilities of the principal investigator is to keep track of project expenditures and commitments and to prevent them from exceeding the budget or being used for inappropriate purposes. Even if the project leader designates other persons as "authorized signers" for his or her project, he or she remains the person solely responsible for operating within the budget. The principal investigator is assisted in monitoring expenditures of project funds by the monthly fiscal status reports issued by the Controller Department. Specific questions concerning these reports should be addressed to the research accountant.

The product or deliverables of most sponsored projects is a report or a series of reports. Consequently, the principal investigator should give best effort to this aspect of the project. The principal investigator should make sure that he/she knows the sponsor's requirements for reporting and plans the work of the project so that all required reports are carefully prepared and submitted by their due dates.

Expenditure of Grant/Contract Funds  

The grant/contract period begins on the effective date of the agreement and runs for the length of time indicated on the award document. Expenditures incurred prior to the effective date of the grant/contract may not be charged against the project account unless specifically authorized in the award document. No expenditures may be made after the scheduled expiration date of the agreement unless approved by the sponsor.

Revisions/Adjustments  

Sponsors generally allow principal investigators the freedom to pursue interesting and important leads which may arise during the conduct of a sponsored project. They may also discontinue or modify unpromising lines of inquiry. However, when such modifications result in a major deviation from original research objectives, prior approval must be obtained from the sponsor.

Similarly, reasonable flexibility is provided the principal investigator in the expenditure of funds. However, there are certain specific restrictions on rebudgeting, and the expenditure of any funds in excess of the amount budgeted for any item in the budget should be cleared with the research administrator. In some cases, the Vice President, AS&R has been delegated authority to approve minor deviations; in others, such as changes in senior personnel (including sabbatical leave), foreign travel, or the acquisition or expensive equipment, prior written approval of the sponsor is required. Requests to sponsors for approval of changes in program objectives or in the authorized budget are initiated by the principal investigators and transmitted via the department chairman to the Vice President, AS&R, who will provide the necessary University endorsement on the request.

Purchasing  

Although general questions concerning purchasing procedures should be referred to the controller department, questions relating to the propriety of purchases under grants and contracts may be addressed to the research administrator. Government contracts often contain specific purchasing requirements -- or limitations. Many require prior approval by the sponsor before certain types of expenditures can be made.

Requests for sponsor's approval should normally be in the form of a letter from the principal investigator addressed to the sponsoring agency program manager and endorsed by an institutional representative. Such a letter should be forwarded to the research administrator for the endorsement and forwarding to the agency.

The following are some examples of the kinds of purchases that frequently require prior approval from government sponsors:

1. Purchase of capital EQUIPMENT costing $1,000 or more.

2. Purchase of articles or supplies not produced or manufactured in the U.S.

3. Purchase of general purpose equipment or furniture.

4. Building construction, alteration or restoration.

5. Special insurance

6. Subcontracts

7. Consultant services

8. Any other special costs.

Travel  

Rice University Travel Policies and Procedures are prescribed in Policy Memorandum No. 806-93 . Some travel reminders are listed below:

1. Foreign travel requires prior approval by the sponsor under all government grants and contracts and should be processed through the research administrator approximately two months in advance of departure to allow adequate time for arrangements. (Some sponsors require the filling out of a form.)

2. Domestic travel expenses for food and lodging will be reimbursed on the basis of actual and reasonable costs. Foreign travel expenses on federally sponsored projects may be limited to maximum per diem allowances in effect at the time. These should be ascertained prior to departure.

3. Government grant or contract funds may be used for domestic travel to scientific or technical meetings, provided funds for such travel were included in the proposal budget, and provided the travel is approved by the principal investigator.

4. Entertainment - government regulations and contracts do not permit charges for entertainment.

Property  

Property purchased under government sponsorship usually falls into one of these two categories:

1. Grants and other Agreements: The property listed in the proposal and authorized by the grant may be purchased without further approval. Title to property costing less than $1,000 will vest in the University upon receipt. However, for equipment costing $1,000 or more, the sponsor may reserve the right to transfer the title to the federal government or to a third party (an option that is rarely exercised).

2. Contracts: Generally, title to property purchased or fabricated under a contract is vested in the government. Inventories are required. We normally request title transfer to Rice University for equipment costing less than $1,000 during the course of the contract period or when submitting the final inventory. Title to equipment costing $1,000 or more may be requested upon the expiration of the contract.

Title to government-furnished equipment for use on a contract or grant is vested in the government, and usually the University can obtain title only if declared surplus by the government.

Handling Property  

1. Responsibility: The principal investigator(s) named in the contract is responsible for the care, control, and custody or property accountable under that contract.

2. Administration: The University property administrator is responsible for establishing uniform property control procedures and for maintaining central property records for all sponsored projects, that will assist principal investigators in meeting contractual obligations with respect to property.

3. Receipt: Principle investigators must insure that all permanent equipment is entered into the University property inventory control system as it is delivered or brought on to the Rice campus.

4. Sponsor Requirements: Since requirements for property control vary between government agencies, it is necessary to read the terms of the contract or grant to insure that basic requirements are satisfied. For further details and for information about acquisition, transfer of title, equipment disposal and inventory, contact the office of the research administrator.

Shared Use of Equipment  

Federal Bureau of the Budget regulations require that during the time that personal property is held for us on the government sponsored project or program for which it was acquired, the recipient shall make it available for use on other projects or programs, if such other use will not interfere with the work on the project or program for which the property was originally acquired. Preference for such other use shall be:

1. Other projects or programs of the same Federal agency.

2. Projects or programs of other Federal agencies.

3. Activities not sponsored by the Federal Government (if the property is owned by the Federal Government, authorization of the Federal agency concerned may be required.)

Industrial Security Clearances  

It is sometimes desirable that an individual acquire a security clearance on a "need-to-know" basis for access to classified information. The research administrator serves as the industrial security supervisor. All requests for personnel security clearances are processed through the Office of the Research Administrator, who is also responsible for the maintenance of up-to-date records reflecting currently cleared University personnel. Detailed information is contained in the "Standard Practice Procedures for Safeguarding Classified Information" ( Policy Memorandum 818-88 ).


VII. REPORTS  

Background  

All research grant and contract funding agencies require the submission of certain reports, both periodically during the course of the research project and upon termination. Generally, they are of the following four types:

1. Performance Reports - Usually called progress or technical reports. Used to inform the sponsor or contracting agency of the progress of research underway and of results and accomplishments upon completion or termination.

2. Invention Reports - Used to promptly inform the sponsor or contracting agency of new discoveries and inventions. A complete written disclosure of each invention conceived or first actually reduced to practice is usually required immediately, and prior to publication. Following this, determinations will be made by the sponsor and/or the University, concerning advisability of a patent application, ownership, licensing and royalty arrangements. A final report of inventions, including a negative report when there are none, is required by some sponsors upon the termination of a research project.

3. Property Reports - Used to keep inventories and accountability current on all permanent equipment purchased with grant/contract funds or furnished by the sponsor. Some agencies, including DOD and NASA require both periodic and termination property reports. Others may require a report only upon termination of the project. Title transfer to the University may be contingent upon agency approval of such reports.

4. Fiscal Reports - Prepared and submitted by the research accountant and/or principal investigator, periodically and/or on termination, in accordance with the sponsor's instructions. Expenditures are subject to the sponsor's approval, or disallowance if not in accordance with the approved budget.

As the grantee or contractor, Rice University is responsible, clearly and directly, to all grantors or contracting agencies for the timely submission of all reports in accordance with the terms of the research agreement. These instructions are issued to facilitate compliance.

Responsibilities  

The Vice President, Advanced Studies and Research, through the research administrator, will execute the University's reporting responsibilities by either transmitting the reports to the sponsor, or where agency instructions will permit, insuring that the principal investigator or other responsible administrative official submits the reports directly to the sponsor, within the time allowed, furnishing a copy to the research administrator.

Principal investigators and administrative officials will execute their reporting responsibilities in accordance with the following guidelines:

1. Performance Reports - The principal investigator will submit both periodic and terminal reports to the research administrator for transmittal, unless the sponsor's instructions permit direct reporting the principal investigator prefers to handle them in this way; in which case the research administrator should be furnished with a copy.

2. Invention Reports - Rice University Policy Memorandum 303-90 , "Patent and Copyright Policy" requires immediate reporting to the Vice President, Advanced Studies and Research, of new inventions and discoveries. AS&R will make required reports to sponsors based on information thus received.

3. Property Reports - The property administrator will cause the property reports required by funding agencies to be prepared. Reports will be prepared from data in the inventory control system file, managed by the property administrator. The property administrator should ascertain that the property reports agree with the University accounting record where applicable. Reports will be coordinated with the research administrator.

4. Fiscal Reports - Prepared and submitted by the research accountant, except where submission by the principal investigator is required. In both cases, the research accountant and the principal investigator will effect coordination with each other, prior to submission. Fiscal reports prepared for submission with renewal or continuation proposals must be verified by the research accountant. Final fiscal reports cannot contain outstanding commitments. It is the responsibility of the principal investigator to ascertain that all outstanding commitments are liquidated by the termination date of a grant or contract. This will allow the submission of the fiscal report in a timely fashion.

Discussion  

The acceptance of a research grant or contract carries with it the obligation to submit technical and administrative reports by the times prescribed by the sponsor. It is incumbent upon the principal investigator and administrative officials concerned to see that the terms of the agreement are met in every way.

Adherence to these aspects of research grants and contracts can be beneficial to both investigators and the University. The timely submission of all required reports will aid in creating and maintaining good relationships between Rice and the sponsoring agencies. In the long run, if goodwill exists, then the sponsors of our research will perhaps be more receptive to our proposals for support in the future.

We are experiencing strict enforcement of administrative regulations by both federal and private sponsors. If we are to continue to receive the external support that we need to do research, we must do the best that we can to meet our contractual obligations. The full cooperation of all principal investigators and University administrative officials is important.


Policy No. 301-83
Janurary 1, 1983

See also:

Policy No. 301A-91