Purdue University

Policies and Procedures for the Administration of Sponsored Program Activities

I. Fiscal Administration 2Allowable Costs 2Proposal Costing 2Proposal Processing 2Preaward Process 3Financial Accounting and Reporting 3Cash Management 3Account Management 3Cost Sharing 4Cost Accounting Standards 4Effort Reporting 4Facilities and Administrative (F&A) Costs 4Library of Training Material 5

II. Property Accounting 6Equipment Screening 6

III. Compliance Assessments and Audits 6Signature Delegation 7Sponsored Programs Questionable Object Code Listing 7Preaudit Process Guide 7Lockout Procedures 7Closing Checklist for Departmental Business Offices 7Closing Checklist for SPS 7

IV. Compliance with Protection Regulations 7Human Subjects 7Animal Care 10Environmental Safety 12

V. Conflict of Interest 13VI. Alcohol-Free and Drug-Free Campus and Workplace Policy 13VII. Certification Regarding Lobbying 13VIII. Award Management 14

Financial Management Systems 14Prior Approvals 14Award Establishment 14Sponsored Projects Termination Dates 14Subrecipient Agreements 15Inventions 15

IX. Reports, Records and Management of Technical Data 15Reporting Requirements 15Financial Record Retention 16Freedom of Information (FOIA) Requirements 16

X. Intellectual Property 16XI. Research Integrity 16

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I. Fiscal Administration

A. Allowable Costs : The University has written policies and procedures defining allowability of costs. These policies and procedures are available as follows:

1. Allowability of costs: http://www.purdue.edu/costing/BPM/CAS_Guidelines/cost4.htm

2. Reference guide to determine if costs are allowable according to the University’s costing policy:http://www.purdue.edu/costing/doc/CostChargInstruct.doc

B. Proposal Costing : To assure costs are included in proposal budgets consistent with the University’s cost accounting practices there are general instructions on the preparation of proposal budgets in accordance with University guidelines and federal regulations. Questions regarding the costs of a specific sponsor should be addressed to the appropriate administrator in Sponsored Program Services http://www.purdue.edu/sps/staffDirectory.htm

1. http://www.purdue.edu/costing/BPM/ CAS_Guidelines.chrgindx.htm

C. Proposal Processing : The University has proposal processing information and guidelines to assure timely and accurate processing of proposals.

1. Research Handbook: A Guide to the Grants Process at Purdue University:http://www.purdue.edu/research/vpr/proposal/docs/grantsprocess.pdf

2. Proposal Roles and Responsibilities:http://www.purdue.edu/sps/proposals/roles.html

3. Proposal Preparation and Training Materials:http://www.purdue.edu/sps/proposals/puguidelines.html

4. Quick Tips for Proposal Preparation:http://www.purdue.edu/sps/proposals/quicktip.html

5. Budget Development Material for Coeus:http://www.purdue.edu/coeus/resources/appendices/propdev/index.html

6. Interdisciplinary Proposal Information:

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http://www.purdue.edu/sps/proposals/interdisinfo.html

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7. Proposal Transmittal Checksheet:http://www.purdue.edu/sps/pdf/TCS.pdf

8. Proposal Transmittal Checksheet Instructions:http://www.purdue.edu/sps/proposals/tcsinstruct.html

9. Guidelines for Submitting Industrial Proposals:http://www.purdue.edu/sps/contracting/guidelines.html

D. Preaward Process : The University strongly encourages departments to establish a Notice to Proceed (NTP) when expenses are being incurred for the benefit of a project but the Sponsor award document has not been received. Instructions and the form for this process are available as follows:

1. Notice to Proceed Form Instructions:http://www.purdue.edu/sps/accountmgmt/ntpinstructions.html

2. Notice to Proceed Form:http://www.purdue.edu/sps/pdf/ntp.pdf

E. Financial Accounting and Reporting : The University has cost allocation guidelines containing the fundamental requirements of the federal regulations and interpretations of those regulations. The Guidelines provide thought processes to apply regulatory requirements to allowable costs and identify roles and responsibilities.

1. Cost Allocation Guidelines:http://www.purdue.edu/costing/BPM/CAS_Guidelines/costindx.htm

F. Cash Management : Sponsored programs cash management is a critical part of the University’s operations. The guidelines for cash management are available at:

1. COMING SOON!

G. Account Management : The University has written policies and a process guide for managing sponsored program accounts.

1. Account Management Guidelines:http://www.purdue.edu/sps/accountmgmt/amguidelines.html

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2. Account Management Process Guide:http://www.purdue.edu/sps/accountmgmt/procguid.html

H. Cost sharing : The University has written policies and procedures for cost sharing.

1. Cost sharing policy:http://www.purdue.edu/sps/accountmgmt/costshguide.html

2. Procedures for cost sharing:http://www.purdue.edu/sps/pdf/CS05guide.pdf

I. Cost Accounting Standards : The Cost Accounting Standards Board (CASB) has published four standards applicable to educational institutions. These standards deal with the allowability of costs to sponsored projects and other activities as either direct costs or indirect costs. The University has disclosed their cost accounting standards as mandated by the federal government in OMB Circular A-21.

1. Reference guide to determine if costs are allowable according to the University’s disclosure statement: http://www.purdue.edu/costing/doc/CostChargInstruct.doc

J. Effort Reporting: OMB Circular A-21 sets federal requirements for the establishment of a Professional Effort Reporting System (PARS). The University has written policies and procedures for PARS as follows:

1. The Effort Reporting Reference Manual is available at:http://www.purdue.edu/costing/BPM/Effort_Reporting/Xwebparm0.htm

2. Effort related forms and queries are available at:http://www.purdue.edu/costing/BPM/Effort_Reporting/forms.html

K. Facilities and Administrative (F&A) Costs: The University has written policies and procedures for concerning F&A costs.

1. Instruction No. 1: http://www.purdue.edu/sps/pdf//inst1-62703.pdf

L. Library of Training Material: The University has reference material available on a number of topics. The following outlines the topics and information available:

1. First Time Award Recipients:http://www.purdue.edu/sps/ppt/firstaward1.ppt

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2. Business Services Basic Skills Training:http://www.purdue.edu/sps/edprogram/basicskills/index.html

3. Correcting Documents Guide:http://www.purdue.edu/sps/pdf/cdguide12-03.pdf

4. Cost Sharing: Training Material:

http://www.purdue.edu/sps/pdf/CS05guide.pdf

Guidelines:http://www.purdue.edu/sps/accountmgmt/costshguide.html

5. Voluntary Support: Fund Classification Decision Guide:

http://www.purdue.edu/sps/pdf/fundguide.pdf

Processing Guide:http://www.purdue.edu/sps/pdf/vsprocessguide.pdf

6. Fellowship Training:http://www.purdue.edu/sps/ppt/fellowships.ppt

7. Proposal Preparation and Training Materials:http://www.purdue.edu/sps/proposals/basicshome.html

8. Signature Delegation:http://www.purdue.edu/bs-ba/Training/SIGDELTR.htm

9. Pre-audit Process Guide:http://www.purdue.edu/sps/accountmgmt/preaudit/index.html

II. Property Accounting: The University has written policies and procedures in place to account for property that is purchased.

A. Equipment/Property Accounting:http://www.purdue.edu/account/Reference/Equipment_Screening/Welcome.html

B. Establishment of the Office of Property Accounting:http://www.purdue.edu/business/Executive_Memoranda/VPBS/bom21.htm

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C. Policies & Procedures for acquisition, tagging, and safeguarding property inventory:http://www.purdue.edu/bpm/BPM/Accounting_Services_Index/propmgt.htm

D. Equipment Screeninghttp://www.purdue.edu/account/Reference/Equipment_Screening/instr.html

III. Compliance Assessments and Audits: The University has a formal system for

compliance assessment and audit that demonstrates that the institution complies with both internal policies and federal regulations.

A. Compliance Assessments and Formal Audits: The University has written policies and procedures for performing compliance assessments and formal audits and for reporting the results of such reviews to management.

1. Business Process Manager Position: Schedule and conduct business process reviews for human resources, payroll, financial, purchasing, SPS, and other operations. Conduct compliance checks across de-central business office areas. Serve as a resource for areas undergoing an internal audit. Write or revise University policies at request of Directors.

2. Internal Audit:http://www.purdue.edu/ia/

B. Internal and External Audit Responsibilities: The University has written policies and procedures for both its external independent audit and its internal audit responsibilities.

1. Policies and procedures in place to assure the independence of auditors and the institution’s auditor reports directly to a board of regents or equivalent structure.Executive Memorandum A-34 http://www.purdue.edu/Business/Executive_Memoranda/A/a-34.htm

2. The State Board of Accounts conducts the University’s A-133 Audit.

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C. Finance Review: The University has procedures for recurring review of its finances, compliance with its administrative directives, and conformance with governmental laws and regulations.

1. Signature Delegation http://www.purdue.edu/bs-ba/Training/SIGDELTR.htm

2. Sponsored Programs Questionable Object Code Listinghttp://www.purdue.edu/sps/accountmgmt/codefaq.html

3. Pre-audit Process Guidehttp://www.purdue.edu/sps/accountmgmt/preaudit/index.html

4. Lockout Procedureshttp://www.purdue.edu/sps/accountmgmt/overlock.html

5. Closing Checklist for Departmental Business Officeshttp://www.purdue.edu/sps/pdf/closacct.pdf

6. Closing Checklist for SPShttp://www.purdue.edu/sps/pdf/spsclose.pdf

IV. Compliance with Protection Regulations: The University has systems that comply with federal and, where necessary, state and local government regulations and with requirements of non-federal sponsors in the areas of protection of human subjects and of animals, the environment, and in the operation of its facilities.

A. Compliance Systems: The University’s compliance systems accommodate multiple and integrated compliance obligations and are coordinated so that oversight and approval responsibilities are linked in an effective and timely manner.

1. Office of Research Administration:http://www.purdue.edu/research/vpr/compliance/index.html

B. Human Subjects: The University has a system that complies with federal and, where necessary, with state and local government regulations and with the requirements of non-federal sponsors to protect the rights, well being, and personal privacy of human subjects in research.

1. Department of Health and Human Resources: The University has filed a written assurance with the Department of Health and Human Services and received approval in accordance with federal regulations.

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Executive Memorandum B-13http://www.purdue.edu/Business/Executive_Memoranda/B/b-13.htm

Executive Memorandum B-45http://www.purdue.edu/oop/policies/pages/teach_res_outreach/b_45.html

Review procedures when human subjects are used in research:http://www.irb.purdue.edu/revproc.shtml

The University has educational programs to ensure that personnel engaged in human subject research are adequately trained.http://www.purdue.edu/Research/vpr/compliance/humans/researchandme/index_p6.htm

2. Institutional Review Board: The University has established at least one Institutional Review Board (IRB) in accordance with federal regulations to review, approve, require modifications in, or disapprove research activities involving humans as subjects.

There is adequate recognition of responsibility for protection of the rights and welfare of human subjects.http://www.irb.purdue.edu/mission.shtml

Statement of Principles:http://www.irb.purdue.edu/statepri.shtml

The University has protocol review procedures and mechanisms for certain kinds of research that meet the definitions for exempt protocols and expedited reviews as defined by the government.http://www.irb.purdue.edu/rerguide.shtml

Each IRB includes at least one member from outside the Institution.http://www.irb.purdue.edu/whoweare.shtml

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The Institution has a system to meet requirements for continuing review and monitoring of approved protocols.http://www.irb.purdue.edu/contrev.shtml

Assent Guidelines:http://www.irb.purdue.edu/assentgu.shtml

The review committee has representation on a continuing or “ad hoc” basis when vulnerable populations are being considered as research subjects (e.g., prisoners, handicapped, elderly, children).http://www.irb.purdue.edu/irbcomm.shtml

The IRB has the authority to suspend or terminate approval of research that is not being conducted in accordance with the IRB’s requirements or that has been associated with unexpected serious harm to subjects.http://www.irb.purdue.edu/contrev.shtml

II. New Drugs or Devices: If the University undertakes research projects involving investigational new drugs (IND) or devices, it has policies and mechanisms for handling such activities.

1. You must indicate if your project includes the use of a pharmaceutical that is classified as an Investigational Medical Device (IMD) by the Food and Drug Administration (FDA) or if the project includes the use of a device for which it has not been approved by the Food and Drug Administration (FDA). If this is the case please state the name of the device, the IMD number and company manufacturing the device. Any application using an IMD must be reviewed by the Full Committee. More information can be found at the following link:

http://www.irb.purdue.edu/appguide.shtml

III. Policy and Procedure Changes: Changes in policies and procedures are made in a timely fashion and, where appropriate, communicated to the University community.

Institutional policy and procedures:http://www.irb.purdue.edu/regpolic.shtml

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IV. Responsible Party for Emergency Treatment: Policies exist to notify appropriate personnel when emergency treatment of patients is required to provide for such treatment when necessary.

http://www.irb.purdue.edu/pirespons.shtml

V. Patient Privacy: There are policies and procedures in compliance with federal, state and local laws, to protect the privacy of both patient health information and human biological specimens used in research.

Compliance with HIPPA Privacy Regulationshttp://www.purdue.edu/oop/policies/pages/records/vi_2_1.html

C. Animal Care: The University has a system to assure the existence of policies and procedures which comply with federal, and where necessary, with state and local government regulations and with the requirements of non-federal sponsors to humanely, efficiently, effectively, and legally use live vertebrate animals in research covered by such regulations.

1. Department of Health and Human Services: The University has filed a written assurance with the Department of Health and Human Services and received approval thereof, and has also secured Department of Agriculture registration.

Executive Memorandum B-1http://www.purdue.edu/oop/policies/pages/teach_res_outreach/b_1.html

PACUC Executive Memorandum C-21http://www.purdue.edu/oop/policies/pages/human_resources/c_21.html

Purdue Animal Care and Use Committee:http://www.purdue.edu/Research/vpr/compliance/animals/staff.shtml

Policies and procedures when animals are used in research:http://www.purdue.edu/Research/vpr/compliance/animals/policies.shtml

PACUC Handbook:

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http://www.purdue.edu/Research/vpr/compliance/animals/handbook.shtml

2. Institutional Animal Care and Use Committee (IACUC): The University has established at least one Institutional Animal Care and Use Committee (IACUC), in accordance with federal regulations to review, approve, require modifications to, or disapprove, suspend or terminate activities involving animals used in research.

Adequate scientific justification is required prior to approval, including consideration of alternative or in vitro methods.

Veterinary medical care program:http://www.purdue.edu/research/vpr/compliance/animals/vetcare.shtml

Laboratory Animal Program:http://www.purdue.edu/Research/vpr/compliance/animals/index.shtml

3. Training: The University has programs and procedures for training and medical examination of scientists, animal technicians, and other personnel involved in animal care or use.

Orientation Program:http://www.purdue.edu/Research/vpr/compliance/animals/training.shtml

4. Compliance: Adequate systems are in place to track report and maintain compliance with the Animal Welfare Act and the PHS Good Laboratory Practices Guide as well as any applicable occupational health and safety regulations.

Compliance with Federal Good Laboratory Practices or GLP regulations involves complex record keeping/archiving and is generally only required for projects producing data for regulatory activities (registration of pesticides or drugs or devices by EPA or FDA). Whenever anyone thinks that GLP compliance is required, The Assistant Vice President for Research Compliance needs to speak with him or her to determine why and how he or she plans to comply.

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D. Environmental Safety: The University has a system to assure the existence of policies and procedures which comply with federal and, where necessary, with state and local government regulations pertaining to environmental safety.

1. Biohazards and Hazardous Waste: With respect to biohazards and hazardous waste, the university has in place a process which complies with requirements for the identification, classification and control of biological hazards (biohazards) and other hazardous waste associated with research (including recombinant DNA).

http://www.purdue.edu/Research/vpr/compliance/rdna/index.html

2. Environmental Health and Safety Office: With respect to the environment, the University has established an environmental health and safety office that is charged with general institutional responsibility in the area of environmental compliance.

Office of Research Administration:http://www.purdue.edu/research/vpr/compliance/index.html

Institutional Bio-safety Committeehttp://www.purdue.edu/Research/vpr/compliance/rdna/members.html

Biological Safety Manual:http://www.purdue.edu/rem/home/booklets/bioman.pdf

E. Facilities: The University has a system to assure the existence of regulations concerning security for campus buildings, other college or university facilities, equipment, information systems and, if appropriate, other materials.

1. Security: The University has policies and procedures for the security of the buildings, grounds, information systems, facilities, and animals of the institution to provide protection from loss or disruption of institutional and/or sponsor investments in its research programs.

Emergency Handbook:http://news.uns.purdue.edu/Emhandbook/Emergency.index.html

Physical Facilities Emergency Contacts:http://www.purdue.edu/physicalfacilities/emerg.htm

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Building Security:http://www.purdue.edu/police/programs/types/buildingsecurity.htm

Information Systems Security:http://www.itap.purdue.edu/security/

2. Health and Safety Standards: Regulations pertaining to compliance requirements for health and safety standards in the workplace, including compliance with OSHA regulations, where appropriate, are published and disseminated to employees.

Safety and Ergonomicshttp://www.purdue.edu/rem/safety/safety.htm

V. Conflict of Interest: Under University policy and Indiana law, staff members who were appointed by the Board of Trustees or who are employed in any position involving any authority to purchase or contract on behalf of the University, must file disclosure statements with the Board of Trustees, stating any financial interest they may have in any University contract or purchase. Additional information can be found as follows:

A. Executive Memorandum C-39 http://www.purdue.edu/oop/policies/pages/human_resources/c_39.html

B. Human Resources Executive Memorandum C-1http://www.purdue.edu/oop/policies/pages/human_resources/c_1.html

VI. Alcohol- and Drug-Free Campus and Workplace Policy:

Executive Memorandum C-44http://www.purdue.edu/oop/policies/pages/human_resources/c_44.html

VII. Certification Regarding Lobbying: When submitting a proposal to a sponsoring agency, the principal investigator must sign the transmittal check sheet certifying to the best of their knowledge that no federally appropriated funds have been or will be paid on their behalf to any person for influencing an officer or employee of any agency, a Member of Congress, or an employee of a Member of Congress in connection with the awarding of the contract, grant, or cooperative agreement. If any funds other than the federally appropriated funds have been or will be used for such purpose, the undersigned agree to complete and submit Standard Form-LLL, Disclosure Form to Report Lobbying, in accordance with its instructions. The form can be found at the following address:

http://www.purdue.edu/sps/pdf/SF-LLL.pdf

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VIII. Award Management: The University has a system to manage externally funded programs in accordance with the requirements of each sponsoring agency

A. Financial Management Systems: The University has written procedures and standards for financial management systems.

B. Prior Approvals: The University has a system for seeking required sponsor prior approvals, where required, and has developed procedures to implement the federal expanded authorities as provided in OMB Circular A-110.

1. Obtaining sponsor Prior Approvals:http://www.purdue.edu/sps/accountmgmt/priorapproval/index.html

C. Subcontracting Plan Expectations: Federal regulations require in certain circumstances that the University develop a “Subcontracting Plan”. The Subcontracting Plan is required when the Government anticipates awarding a contract that is expected to exceed $500,000, and establishes an estimated amount of goods and services to be purchased for a project from small, small disadvantaged, and women-owned vendors. To develop the Subcontracting Plan the Business Office and the Principal Investigator must develop a budget in sufficient detail that the Purchasing Department may identify minority vendors that can provide goods and services for the project. Once a contract is awarded, Purdue is required to report to the sponsor actual expenditures in relation to the approved Subcontracting Plan.

1. Subcontracting Plan Expectations:http://www.purdue.edu/sps/general/subplanexpect.htm

D. Award Establishment: The University has developed procedures to establish awards in its accounting system in a timely manner, including receipt of electronic awards.

1. Terms and conditions of awards are distributed to principal investigators and made available to other institutional personnel, as required.

2. Electronic Notice of AwardCOMING SOON!

3. Regulatory Process – The transmittal check sheet is used for faculty to identify any regulatory approvals that must be obtained prior to conducting any research on a given project. When SPS receives an award, the Account Manager will review the third page transmittal check sheet under the heading “Regulatory Assurance and Compliance Data” to

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see if any of the questions are marked indicating that approvals are needed. If any approvals are needed, the award file will be routed to the Administrative Assistant for the Vice Provost for Research who will determine if all approvals are in place. Once the approvals are in place, the file will be returned to the Account Manager for account establishment.

E. Sponsored Projects Termination Dates: The University has procedures regarding notification of upcoming termination dates for sponsored projects to appropriate internal offices.

1. Account Management Guidelines – Account Closeouthttp://www.purdue.edu/sps/accountmgmt/procguid.html

2. The Expired with any Balance query can be used to identify projects with any balance that either have expired or will be expiring in the next 120 days. This query is located in the repository.

F. Sub-recipient Agreements: The University has policies and procedures for issuing sub-recipient agreements and for monitoring the performance of sub-recipients.

1. A-133 Audit Processhttp://www.adpc.purdue.edu/SPS/html/usermanu.htm#SubCert

2. Award Management:

Issuing Subcontracts:http://www.purdue.edu/sps/contracting/subcontracthome.html

G. Inventions: The University has written policies and procedures for the routine reporting of inventions developed with Federal Support.

Executive Memorandum B-10http://www.purdue.edu/oop/policies/pages/teach_res_outreach/b_10.html

IX. Reports, Records and Management of Technical Data

A. Reporting Requirements: The University has policies and procedures regarding responsibility for preparation of and procedures for submission of required reports.

1. Jim Almond/Gary Isom internal memorandum on the importance of meeting sponsor reporting requirements:

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http://www.purdue.edu/sps/pdf/report1.pdf

2. Guidelines for tracking reporting requirements and assignment of responsibility for various reports:http://www.purdue.edu/sps/pdf/guidelines.pdf

B. Financial Record Retention: The University has policies and procedures regarding record retention and access to financial and administrative records generated under sponsored programs.

http://www.purdue.edu/business/Quick_Links/records.xls

C. Freedom of Information (FOIA) Requirements: Anyone receiving a request for sponsored program data under the Freedom of Information Act should refer the request immediately to the Associate Director of Sponsored Programs Administration.

X. Intellectual Property

A. Policy: The University policy on intellectual property is covered in Executive Memorandum B-10.

http://www.purdue.edu/oop/policies/pages/teach_res_outreach/b_10.html

The policy covers topics such as disclosure requirements, ownership, revenue distribution, and management of Intellectual Property

B. Disclosure : The University has procedures for timely reporting of intellectual property within the institution and to external sponsors.http://www.prf.org/otc/forms/discl/Disclosure%20Form%20Patent%202005_07_13.pdf

XI. Research Integrity

A. Policy: The University policy on Integrity in Research is covered in Executive Memorandum C-22. The policy includes statements that demonstrate an understanding of ethical scholarship and provide procedures for raising and resolving questions of what professional or ethical standards in conducting research entail.

http://www.purdue.edu/oop/policies/pages/human_resources/c_22.html

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