I. Policy Summary
New Jersey Institute of Technology (NJIT) receives external support in the form of money, property, or services to further University purposes. To ensure proper accounting, legal compliance, and administrative oversight, these awards must be classified as either a Gift (non-exchange) or a Grant/Contract (exchange).
II. Policy Purpose
This policy provides a framework for classifying external funds in compliance with GASB/FASB accounting standards and the University’s Chart of Accounts. Proper classification ensures that:
- Revenue is recognized in the correct fiscal period.
- Facilities and Administrative (F&A) costs are appropriately applied.
- Compliance, reporting, and stewardship obligations are met.
III. Policy Scope and Applicability
This policy applies to all NJIT units, specifically the Office of Development and Alumni Relations (Development) and the Office of Research.
IV. Definitions
- Gift: A voluntary, non-reciprocal transfer of resources. There is no expectation of direct economic benefit or "quid pro quo" services.
- Grant or Contract: An award in exchange for specific deliverables (e.g., technical reports, data, or products) provided within a defined period of performance.
- Exchange Transaction: A reciprocal transfer where the sponsor receives a benefit of roughly equal value to the resources provided.
- Non-Exchange Transaction: A transfer where the sponsor does not receive direct compensation or goods in return.
- F&A (Indirect) Costs: Costs incurred for common institutional objectives (e.g., utilities, administration) that cannot be uniquely assigned to a specific project.
- Sponsor: Any federal, state, local, or private entity providing financial or material support.
V. Policy Statement
1. General Principles
Classification requires professional judgment. The terminology used by a sponsor (e.g., calling a contract a "grant") is not solely determinative.
Research Determination: All awards from federal or state government sources (including pass-through) related to research are classified as Grants/Contracts and administered by the Office of Research.
- Regardless of the source, an award is a Grant/Contract if it meets all the following:
- Supports activities within the research enterprise.
- Requires regulatory monitoring (IRB, IACUC, etc.).
- Includes terms for Intellectual Property (IP), confidentiality, or licensing.
- Has a specified period of performance and deliverables.
- Requires fiduciary reporting (expenditure certification, effort reporting).
2. Accounting and Revenue Recognition
- Gifts: Recognized as revenue in the period received. Pledges are recorded at their present value.
- Grants/Contracts: Recognized as revenue only as qualified expenditures are incurred.
3. Conflict Resolution
If the Office of Research and Development cannot agree on a classification:
- The offices will review documentation against the Decision Tree (Appendix A).
- Unresolved cases escalate to the VP for Development and the SVP for Research.
- Final determination rests with the SVP for Finance and Chief Financial Officer (CFO).
VI. Review Criteria
The following table serves as a guide for classification. The presence of a single factor does not mandate a designation; the award must be viewed in its entirety.
Factor | Gift | Research Gift | Grant/Contract (Exchange) |
|---|---|---|---|
Administered By | Development | Development | Office of Research |
Source | Individuals, Family Foundations, Corps | Individuals, Family Foundations, Corps | Gov. Agencies, Corps, Other Universities |
Proposal | Initiated by Development/Sponsor | Joint effort: Faculty & Development | Faculty working with Office of Research |
Intent | General area of interest/General support | Supports a specific PI or research program | Defined Scope of Work (SOW) |
Period of Perf. | N/A | N/A | Specified start/end dates |
Reporting | Stewardship/Impact reports only | Stewardship/Impact reports only | Technical, financial, and milestone reports |
Compliance | N/A | Restricted use for research | Regulatory approvals (IRB/IACUC) required |
Intellectual Prop. | N/A | N/A | Terms for IP, Licensing, or Non-compete |
F&A Costs | N/A | N/A | F&A rates typically apply |
VII. Authority and Responsibility
The Office of Research, Development and Alumni Relations, and Finance share institutional authority for the administration of this policy.
Contact Information
For questions regarding fund classification, compliance with University guidelines, or adherence to 2 CFR 200 (Uniform Guidance), please contact:
- Office of Research: Executive Director, Sponsored Research Programs Administration
- Office of Development: Associate Vice President of Development Operations
Appendix A: Decision Tree for Funding Classification
To determine if external support should be processed as a Gift (through Development) or a Grant/Contract (through the Office of Research), follow the diagnostic flow below.
Frequently Asked Questions (FAQ)
1. The sponsor calls the award a "Grant," but there are no deliverables or IP requirements. Is it still a grant?
Not necessarily. As per Section V(i), the sponsor’s terminology is not determinative. If the funds are a voluntary, non-reciprocal transfer for general support without a specific "quid pro quo" (deliverables, audits, or IP terms), it may be classified as a Gift.
2. What is a "Research Gift" and how is it different from a "Research Grant"?
- Research Gift: Funds restricted to a specific researcher or lab to support their general work. There are no technical milestones, no return of unspent funds, and no IP claims. (Administered by Development).
- Research Grant: Funds provided for a specific project with a defined scope of work, budget, start/end dates, and required technical reports. (Administered by Office of Research).
3. If a corporation provides funding but requires a copy of the final research data, is it a gift?
No. Requiring specific data, technical reports, or a right to review findings constitutes a deliverable (Exchange Transaction). This should be processed as a Grant/Contract.
4. Why does it matter which office handles the funds?
Correct classification ensures NJIT complies with Uniform Guidance (2 CFR 200) for federal funds and GASB/FASB accounting standards. It also ensures that Facility & Administrative (F&A) costs are recovered where applicable and that the Office of Research can provide necessary oversight for compliance (e.g., human subjects or lab safety).
5. What happens if an award includes a "Right to First Refusal" for Intellectual Property?
Any language regarding the ownership, licensing, or control of Intellectual Property (IP) automatically classifies the award as a Grant or Contract to be managed by the Office of Research.
I. Policy Summary
The Senior Vice Provost for Research (SVPR) is the sole authorized signing official for NJIT and holds the formal authority to submit sponsored project proposals or to delegate this authority to others. In practice, the SVPR delegates this responsibility to Central Office Research Administrators within the Office of Research, who are authorized to submit proposals on behalf of the university.
To ensure a successful submission, complete proposals are expected to arrive in the Office of Research, with all required academic unit approvals, no later than three business days before the sponsor’s deadline. While the Office of Research will make the “best effort" to submit proposals that arrive after this deadline, such proposals may not receive an administrative review and risk rejection by the agency due to technical or compliance issues that cannot be addressed in time.
II. Policy Purpose
This policy provides clear guidance on the expected timeline and institutional authority for all sponsored project proposals submitted by the Office of Research on behalf of NJIT.
III. Policy Scope and Applicability
This policy is in effect for all units of NJIT and applies to all proposals related to sponsored research programs, including grants, contracts, and cooperative agreements.
IV. Policy Statement
The Senior Vice Provost for Research holds sole institutional authority as the signing official for sponsored projects. Proposals submitted to a sponsor without the approval of the SVPR or their authorized delegates may not be honored by the university and will be subject to an executive-level review to determine appropriate corrective actions.
Submission Requirements:
- Approvals: Complete proposals, including all administrative, financial, and technical components, must receive academic approval from appropriate Chairs, Center Directors, and Deans before submission. It is the responsibility of the Principal Investigator (PI), assisted by their College Director of Research or Project Manager, to ensure all approvals are secured.
- Delegation: Deans, Chairs, and Center Directors may delegate approval authority (e.g., to an Associate Dean for Research). Such delegations must be communicated to the Director of Pre-Award Services to update roles within Streamlyne, NJIT’s grant management system.
- The Three-Day Rule: A "complete final proposal “meaning one that contains all necessary components and requires no further revisions—must reach the Office of Research at least three business days prior to the deadline.
- Late Submissions: For proposals arriving within the final three-day window, the Office of Research does not guarantee a final administrative review. NJIT reserves the right to recall proposals from a sponsor if errors are discovered post-submission. The Office of Research is not responsible for submission failures or rejections for proposals that do not meet the three-day lead time.
V. Procedures
Faculty members must not make formal commitments to external entities on behalf of NJIT. Any contractual research agreement must follow this sequence:
- Initiation: PI identifies needs and terms using NJIT or company templates.
- Departmental Review: Draft is submitted to the Chair to review departmental resource commitments.
- Dean Review: Chair forwards the draft and comments to the College/School Dean.
- Research Office Review: Dean forwards the package to the SVPR for consideration.
- Legal Review: The Office of Research routes the agreement to the Legal Department for full review and editing.
- Negotiation: The edited version is shared with the PI and external agency to reach a consensus.
- Execution: Once finalized, the agreement is executed (signed) by the SVPR or their authorized delegate.
- Distribution: Copies of the executed document are sent to the PI, Chair, and Dean.
VI. Roles & Responsibilities
- Principal Investigator (PI): Bears primary responsibility for leading the proposal effort and routing it for approvals.
- Academic Leadership: Approvals from Chairs and Deans certify that the PI has the necessary time and lab space, that any cost-sharing is funded, and that the budget meets college expectations.
- Office of Research: Responsible for the timely submission of proposals that meet the three-day deadline and for providing "best effort" support for late arrivals.
VII. Authority and Responsibility
The Office of Research maintains institutional authority over this policy. For inquiries or guidance regarding these procedures, please contact the appropriate representative via the Office of Research Contact Page.
I. Policy Summary
Principal Investigators (PIs) are responsible for the preparation and justification of the fiscal budgets of their sponsored project proposals. Academic leadership at the departmental, college, and institute levels has the responsibility of approving budgets. The Office of Research provides financial and administrative support for the management of these activities.
II. Policy Purpose
The purpose of this policy is to outline institutional expectations for the budgeting of sponsored projects and ensure alignment with federal cost principles.
III. Policy Scope and Applicability
This policy is in effect for all units of NJIT and applies to all sponsored project budgets.
IV. Definitions
- Allowable Costs: Expenses that meet the specific criteria for federal reimbursement (200.403).
- F&A Costs: Facilities and Administrative costs, often referred to as overhead (200.414).
- Streamlyne: The institutional system of records for grant management and budget approvals.
V. Policy Statement
PIs must develop budgets that respond to the specific scope of work proposed. In preparing these budgets, the institute requires adherence to the following federal and institutional standards:
- Cost Principles: All budget expenses must be allowable (200.403), reasonable (200.404), and allocable (200.405).
- Consistency: Costs must be treated consistently across the institution as either direct or indirect (200.403(d)).
- Overhead & Fringe: F&A and fringe costs will be charged in accordance with the institute’s current rate agreement with the Department of Health and Human Services (200.414).
- Exceptions: F&A may only be reduced if the sponsor has a non-negotiable, publicly published limit (200.414(c)).
- Graduate Support: Budgets should prioritize full-year stipend and tuition support for PhD students.
VI. Budgeting Guidelines (Priority Framework)
Budgets must be developed in consideration of the proposed deliverables and funding caps. PIs should prioritize personnel funding within the following hierarchy:
- Priority 1: Full support for a PhD student (tuition and stipend) (200.466).
- Priority 2: One month of faculty summer salary (200.430).
- Priority 3: Academic year salary release (1/8 of AY salary) where allowed by the agency.
- Priority 4: Second full summer month of faculty salary.
- Priority 5: Full support for a second graduate student. If not requested, prioritize post-docs or technicians.
- Priority 6: Additional academic year salary release (second course release).
- Priority 7: Third summer month of faculty salary (not to exceed 3 months total).
Note: Salary release funds may be redirected to research support (e.g., student funding) with Chair/Dean approval but cannot be converted to faculty summer salary.
VII. Procedures
- Direct Charges: Administrative and clerical salaries should typically be treated as indirect costs unless they meet the specific criteria for direct charging (200.413(c)).
- Equipment: Items over $5,000 must be justified as essential to the project (200.313 / 200.439).
- Computing Devices: Devices under $5,000 are treated as supplies and are allowable if essential and allocable (200.453).
- Institutional Match: Any mandatory institutional matching must be approved by the Senior Vice-Provost for Research before submission (200.306).
- Approval Workflow: All budgets must be approved by the Chair and Dean within Streamlyne. Delegation of this authority must be filed with the Director of Pre-Award Services.
VIII. Roles & Responsibilities
- Principal Investigators: Developing and justifying budgets.
- College Directors of Research: Assisting with budget development and guaranteeing compliance with sponsor and institutional expectations.
- Chairs/Deans: Approving budgets for consistency with the scope of work and local expectations.
- Office of Research: Maintaining institutional authority over cost interpretation and final submission. If you have any questions, please contact the Director of Sponsored Research Administration.
Related Policies and Regulations
Principal Investigator Eligibility
Policy on Cost Sharing
I. Policy Summary
All policies under the purview of the Office of Research (OR) are reviewed and updated systematically to ensure continuous alignment with federal regulations (e.g., Uniform Guidance), sponsoring agency requirements (NSF, NIH, NASA, DOD, etc.), and university governance.
II. Policy Purpose
This policy establishes a formal framework for the creation, review, and maintenance of Research Administration policies. It ensures that institutional guidelines reflect the evolving landscape of sponsored programs and federal oversight.
III. Policy Scope and Applicability
This policy applies to all administrative, financial, and compliance policies maintained or originated within the Office of Research and its subsidiary units.
IV. Definitions
- Uniform Guidance (2 CFR 200): The federal government's framework for grants management.
- Sponsor-Specific Requirements: Supplemental regulations issued by agencies (e.g., NIH Grants Policy Statement, NSF Proposal & Award Policies & Procedures Guide (PAPPG).
- Policy Committee: The governing body responsible for institutional research policy oversight.
V. Policy Statement
The Office of Research Policy Committee reviews all departmental policies biannually or in response to regulatory changes.
To maintain compliance with external sponsors:
- Federal Alignment: Policies must be updated immediately upon significant changes to the Uniform Guidance or agency-specific terms (e.g., new NSF/NIH disclosure requirements or DOD cybersecurity standards).
- Industry & Non-Profit Relations: Policies shall account for the unique IP and overhead requirements of industry-sponsored research.
- Oversight: The Associate Vice Provost for Sponsored Research Administration for Research, Senior Executive Director of Sponsored Research Programs Administration, and the Director of Sponsored Research Administration hold ultimate authority over policy veracity.
VI. Procedures
- Scheduled Review: The Committee meets as needed. Directors must review and monitor regulations that have a direct effect on the Sponsored Research portfolios 30 days prior to the meeting to assess applicability.
- Ad Hoc/Emergency Updates: In the event of a change in federal law (e.g., updates to 2 CFR 200.306 regarding cost sharing) or University mandate, the Executive Director may bypass the semesterly schedule to implement immediate policy revisions.
- Submission Process: Proposed drafts must be submitted to the Committee at least one week before a scheduled meeting.
- Dissemination: Once approved, revised policies are updated in the institutional repository and communicated to the faculty and research staff.
VII. Roles & Responsibilities
Role | Responsibility |
|---|---|
Senior Vice Provost for Research | Final approval authority; strategic alignment with the University mission. |
Executive Director, SRPA | Chairs the Policy Committee; monitors Federal Register for Uniform Guidance updates. |
Director, Pre-Award Services | Maintains policies on proposal submission, NSF/NIH bio sketches, and disclosure requirements. |
Director, Post-Award Management | Maintains policies on financial compliance, effort reporting, and allowability of costs. |
Director, Faculty Awards | Manages internal seed funding and limited submission policy updates. |
VIII. Authority and Responsibility
The Office of Research maintains institutional authority over these matters. Questions regarding the interpretation of federal or sponsor-specific regulations should be directed to the Director, Sponsored Research Administration.
Related Regulations:
- OMB Uniform Guidance (2 CFR 200)
- NSF PAPPG / NIH Grants Policy Statement
- Federal Acquisition Regulation (FAR) for DOD/NASA contracts