I.
REFERENCES
AND RELATED POLICIES
A.
NSF Grant Policy
Manual, Revised April, 1983
B.
NSF Grant General
Conditions (F.L. 200, October 1987)
C.
UCSD
Policy and Procedure Manual (PPM)
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150-65
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Request
for Approval Procedures under Organizational/Institutional Prior Approval
Systems (OPAS/IPAS)
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380-4
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Budget
Adjustment Journal Preparation Procedures
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380-5
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Budget
Adjustments to Extramural Funds (Federal, State, Local Government, and
Private Contracts, Grants and Donations)
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522-2
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Equipment
Screening
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523-10.1
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Independent
Consultants
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II.
INTRODUCTION
The purpose of this policy is to outline the
procedure to follow in completing the Request for Approval Under the
Organizational Prior Approval System (OPAS) to expend funds under National
Science Foundation (NSF) grants.
III.
POLICY
Effective October 1, 1987, the NSF revised its
Grant General Conditions, NSF F.L. 200, which allows grantee institutions to
expend monies and rebudget certain funds in their research grants without
referral to NSF for prior approval.
Principal Investigators or Department
Administrators should request assistance from the OCGA concerning any proposed
NSF related budget deviation not covered by the NSF Grant Policy Manual or by this
issuance.
IV.
PROCEDURES
A.
Preparation
of Forms
1. If the Principal
Investigator (PI) has the authority to rebudget funds, in accordance with
Section VII. of this issuance, a Budget Adjustment Journal is all that
is required. This should be prepared according to instructions contained in PPM
380-4.
2. If authority to expend
or rebudget funds must be obtained through the Organizational Prior Approval
System (OPAS), the Principal Investigator then prepares a Request for
Approval Under Organizational Prior Approval System (see PPM 150-65) and a Budget
Adjustment Journal (see PPM 380-4). When the Principal Investigator is
requesting approval to purchase an item of equipment, the Purchase Order Requisition
and an Equipment Screening
Certification
form
(if necessary) must also be attached. The entire package should then be
forwarded via the MSO to the Department Chair and the Contract and Grant
Officer, OCGA, for review and approval.
3. If NSF prior approval
is required, the PI must prepare a letter to either of the NSF Officers, as
shown on the “Grant Award”, specifying the nature of the request, its relation
to the purpose of the grant, the amounts involved, and the budget categories
affected. The letter should be forwarded to the UCSD Office of Contract and
Grant Administration for countersignature and submission to the agency. When
approval is received, the PI should prepare and submit a Budget Adjustment
Journal and a copy of the NSF approval letter in accordance with PPM 380-4.
The Budget Adjustment Journal should be forwarded directly to the
Manager, Extramural Funds Accounting.
V.
JUSTIFICATION
The Principal Investigator is responsible for
providing a brief but comprehensive explanation/justification describing the
scientific, technical or administrative reason(s) for all requests. As a
minimum, the justification must address the following:
A.
A
brief description of the proposed action;
B.
Scientific,
technical or administrative justification for the action. (Include a statement
as to the scientific benefit which will accrue to the project as a result of
the request);
C.
Explanation
for rebudgeting from any category, why the funds are available (specify budget
categories, if applicable) and how the lack of funds in this category impacts
the continuous operation of the project as outlined in the original proposal.
D.
For
requests for travel or the purchase of equipment, the following specific areas
must be addressed:
1. Travel
a. Itemization of cost
i.e., airfare, per diem, registration fee, etc.;
b. Purpose, date, and
place of travel;
c. Relationship to
research;
d. Relationship of the
traveler(s) to the research project;
e. A statement of
compliance with Federal regulations regarding the use of U.S. Flag Air Carriers
(foreign travel only); and
f. A copy of the travel
itinerary or meeting invitation (foreign travel only).
2. Equipment
a. Description of
equipment - if more than one item requested, itemize the description and cost
of each;
b. Justification for the
request;
c. How the proposed
purchase impacts the operation of the project as outlined in the original
proposal; and
d. Requests for purchase
of equipment over $1000 must include a completed copy of the Equipment Screening
Certificate.
It is of utmost importance that special
attention be given to the above required justification(s) as it is the most
critical element of the prior approval request.
VI.
RESPONSIBILITIES
A.
MSO
Receives request from PI, reviews for
administrative purposes, initials and forwards to Department Chair.
B.
Department
Chair
1. Reviews and
approves/disapproves the request for scientific propriety, project relevance
and effective utilization of institutional resources.
2. Forwards the approved
package to the Contract and Grant Officer, OCGA.
C.
Contract
and Grant Officer, OCGA
Upon receipt by OCGA, the Contract and Grant
Officer will review the request for consistency with University and NSF policy.
When fully approved, the original copy of the request is forwarded to the
Manager, Extramural Funds Accounting, a copy is retained by OCGA and the
additional copies forwarded to the Principal Investigator, Departmental MSO and
Purchasing Division, as applicable. If any questions arise during the review,
the OCGA will consult with the appropriate departmental personnel. Should the
request be disapproved, an explanation will be forwarded to the Principal
Investigator for informational purposes or for further action.
D.
Manager,
Accounting Office/Extramural Funds Division
The Manager reviews the
Budget Adjustment Journal for conformance with University and NSF
financial regulations and returns a copy to the departmental business office.
Should additional information be required, appropriate departmental
administrators will be contacted.
VII.
ORGANIZATIONAL
PRIOR APPROVAL SYSTEM REQUIREMENTS UNDER NSF RESEARCH
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CLASSIFICTION
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AUTHORITY
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1.
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Alterations and
Renovations
A. Expenditures less
than $10,000
B. Expenditures over
$10,000 which are considered construction, as opposed to alterations and
renovations
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UCSD Contract &
Grant Officer
NSF via OCGA for
endorsement
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2.
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Capital
Expenditures for land or Buildings
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NSF via
OCGA for endorsement
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3.
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Changes
in Objectives or Scope
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NSF via
OCGA for endorsement
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4.
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Changes of Principle
Investigator or level of Principle Investigator Effort
A change of Principle
Investigator (PI) is defined as an anticipated absence for more than 3 months
during and continuous period without the active direction of an approved PI.
The request must be submitted at least thirty (30) days before the departure
of the approved PI.
A change in the level
of effort is defined as a substantial increase or decrease in the PI's effort
which affects the project/proposal as approved or the successful
progress/completion of the project.
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NSF via
OCGA for endorsement
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5.
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Consultants
The daily consultant
rate paid to an individual not employed by the University may not exceed the
maximum rate paid to a GS-18 Federal employee.
(NOTE: University Academic personnel who desire to act as professional
consultants in connection with research projects under the auspices of the
University should contact the Academic Personnel Office to determine
allowability in accordance with University policy, conflict of interest and
other related policies.)
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UCSD
Contract & Grants Officer
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6.
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Contractual Third
Party Costs
This classification
includes subcontracts and consortium agreements.
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UCSD
Contract & Grant Officer
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7.
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Equipment
Equipment (including
sales tax)-is defined as tangible nonexpendable property with a unit cost of
$500 or more and a useful life of two years or more.
A. General Purpose -
General Purpose Equipment is not used primarily or for endorsement
exclusively for scientific purposes.
B. General Purpose
used as Special Purpose - General Purpose Equipment is used primarily or
exclusively for scientific purposes.
C. Special Purpose
1) Under $1,000 per item
2) Over $1,000 per item
(each item over $1,000 requires screening)
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NSF via OCGA for
endorsement
UCSD Contract &
Grant Officer
Principal
Investigator UCSD Contract & Grant Officer
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8.
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No-Cost Extensions
One time only for up
to six (6) months beyond flexibility period. The justification for the
request will include a brief summary of progress to date, funds remaining and
their future use and plans for completion of project for which extension is
requested. The fact that funds remain upon expiration is not in itself
sufficient justification for an extension. The request with justification
must be submitted no later than 30 days prior to the grant period expiration
date.
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UCSD
Contract & Grant Officer with written notification to the NSF Grant
Officer
|
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9.
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Personnel
Costs
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Principle
Investigator
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10.
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Pre-Award Costs
Up to 90 days prior
to the effective date of award. Form FO2141, Request for Advance Approval
to Establish Accounts & Incur Expenses, is required for this action
and must be approved prior to incurrence of the cost.
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UCSD
Contract & Grant Officer
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11.
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Related Projects
A. Provided no
significant change is made in the objectives or scope of an individual NSF
grant, allowable grant costs may be committed or otherwise expended between
two or more active NSF grants held by the same Principal Investigator during
the grant periods. Sufficient documentation shall accompany the Principal
Investigator's request to enable OPAS to determine that the projects have a
scientific or technical commonality.
B.Other Uses of
Relatedness (e.g, collaboration of two Principal Investigators with separate
projects)
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UCSD Contract &
Grant Officer
NSF via OCGA for
endorsement
|
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12.
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Retroactive Approval
NSF allows
retroactive approval only under "unusual circumstances"and requires
substantially more justification. Specifically, such approvals require a
detailed explanantion as to why prior approval was not obtained on a timely
basis.
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NSF via
OCGA for endorsement
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13.
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Travel
Must be directly
related to and show promise of enhancing the capability of carrying out the
sponsored research objectives.
A. Domestic
1) Cumulative expenditures less than $500 or 25% over the amount budgeted,
whichever is greater
2) Cumulative
expenditures which exceed $500 or 25% over the amount budgeted, whichever is
greater.
B. Foreign
Foreign travel is
defined as any travel outside the U.S. (50 states)
and Canada.
1) Each trip (exclusive of solicited travel approved by award)
2) Dependent Travel, when
a) Individual scientist is a key person who is essential to the research on a
full-time basis.
b) Individual scientist's residence is away from home and in a foreign
country for a continuous period of six months or more and is essential for
the effective performance of the project.
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Principal
Investigator
UCSD Contract &
Grant Officer
UCSD Contract &
Grant Officer
UCSD Contract &
Grant Officer
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