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