Handbook of Operating Procedures 7-1040
Sponsored Projects
Effective July 17, 2024
Executive Sponsor: Vice President for Research
Policy Owner: Assistant Vice President, Office of Sponsored Projects
- Policy Statement
UT Austin is one of the world’s leading research universities. UT Austin researchers are encouraged to explore and seek support for their research interests provided the funding complies with University policies, as well as state and federal law. This policy provides guidance for principal investigators/project directors in the submission and management of externally-funded sponsored projects.
All proposals and requests for funding (assistance, cooperative agreement, letter, etc.) for Sponsored Projects must be reviewed and approved by the Office of Sponsored Projects (OSP) before submission to an external sponsor. OSP serves as the coordinating office for externally- funded research and sponsored projects at UT Austin, including those with industrial partners. When sponsored projects are negotiated to facilitate intellectual property development with industrial partners, Discovery to Impact will facilitate on behalf of UT Austin.
The mission of OSP is to assist faculty and professional research staff in their efforts to secure and ensure proper stewardship of external funding. OSP assists faculty, researchers, and staff with the following:
- Proposal review, authorization, and submission;
- Award negotiation and acceptance;
- Account management and close-out;
- Receivables management and collection;
- Financial reporting;
- Audit liaison;
- Professional development and education;
- Research, regulatory, and financial compliance.
- Reason for Policy
This policy is intended to provide the framework for ensuring that any sponsored project activity is conducted under proper oversight from the University administration; complies with local, state, federal, and other pertinent regulations governing sponsored projects; and contributes to the University’s missions.
Supplemental instructions or guidance may be issued by the Office of the Vice President for Research, Scholarship and Creative Endeavors (OVPR) or OSP.
- Scope & Audience
This policy applies to all University employees, students, and affiliated researchers who are engaged in a sponsored project activity occurring in University facilities or at other locations when those projects involve external funding and use of University resources (including University faculty, staff, or student effort), or who have been approved by OSP to engage directly with a sponsor.
- Definitions (specific to this policy)
Applicant:
The entity or person submitting a sponsored project application.
Award:
Financial assistance that provides support or stimulation to accomplish a public purpose. Awards include grants and other agreements by a sponsor to an eligible recipient. The term does not include technical assistance, which provides services instead of money; other assistance in the form of loans, loan guarantees, interest subsidies, or insurance; and direct payments of any kind to individuals.
Award Recipient:
An entity that receives an award directly from a sponsoring agency to carry out an activity under a sponsor-defined program. The term recipient does not include subrecipients.
Direct Costs:
Direct Costs are costs that can be identified specifically with a particular final cost objective or can be directly assigned to such activities relatively easily with a high degree of accuracy (e.g., salary, fringe benefits, and materials and supplies). Costs incurred for the same purpose in like circumstances must be treated consistently as either direct or indirect (F&A) costs (see 2 CFR 200.413).
Gift:
A gift is a voluntary and irrevocable charitable contribution from an individual or an organization. Gifts may either be unrestricted or restricted. An unrestricted gift may be used for any purpose, while a restricted gift must be used for a particular purpose or project as specified by the donor and agreed to by the University. For additional details, please refer to HOP 3-2031 - Gifts: Solicitation, Acceptable, and Management.
Indirect Costs:
Indirect Costs, or Facilities and Administration (F&A) costs, are costs that are incurred for a common or joint purpose benefiting more than one cost objective, and are not readily assignable to the cost objectives specifically benefitted. These costs include building depreciation, equipment and capital improvement, utilities, custodial services, general administration, research administration, libraries, accounting, and purchasing (see 2 CFR 200.414).
Principal Investigator (PI)/Project Director (PD):
The Principal Investigator (PI)/Project Director (PD) is the individual with ultimate responsibility for the conduct of the activities of a well-defined science, academic, or public service project, including all regulatory compliance requirements, review, and reporting of the findings and outcomes of the externally-funded sponsored activity. See additional discussion at https://research.utexas.edu/resources/research-integrity-and-compliance/serving-as-pi.
Sponsored Project:
A sponsored project is an activity financially sponsored by an external entity, such as a federal, state, local or private organization that includes a specific scope of work or set of specific aims for research, instruction, training, and other scholarly or creative activities.
Subawardee:
A subawardee is an entity that receives and expends award funding from a pass-through entity to carry out a portion of a sponsored project for which the pass-through entity is the prime or lead award recipient.
- Website (for policy)
https://secure4.compliancebridge.com/utexas/public/getdoc.php?file=7-1040
- Contacts
- Responsibilities & Procedures
- General Policies
Integration of Teaching and Research
The University of Texas at Austin encourages faculty members and researchers to seek support for sponsored projects related to teaching, research, and public service. The University recognizes that research under sponsored projects contributes significantly to the academic stature, achievement, and capability of the faculty in fulfilling its responsibilities as teachers and public servants. To that end, the University seeks to ensure the close integration of research and teaching, including the employment of students in sponsored projects and the use of research facilities for instructional purposes.
Faculty Initiative
The basic responsibility for originating a proposal and managing the project lies with the individual faculty member. The PI/PD has many University resources at their disposal to assist them in the preparation of a proposal, the management of the project, and the termination of the project.
Depending on the need, assistance can be obtained from various University offices that support the sponsored project community. The following offices are commonly utilized during the life cycle of a project:
Restrictions on Publication
The University encourages the general dissemination of knowledge acquired through sponsored projects. Protection of publication and research rights is paramount to the University’s mission, and the University will generally accept only those agreements under which the University researcher(s) have the ability to freely publish results. Where necessary, and with specific justification, restrictions on publication may be permitted in the interest of national security or protecting sponsor proprietary information/intellectual property. Classified research projects must be reviewed periodically by the Committee on Classified Research (see HOP 7-1050, Classified Research Policy.)
Public Benefits for Research
While the University encourages projects sponsored by commercial and industrial organizations, as a public institution, it cannot engage in projects that involve continuing large-scale production or manufacturing. Likewise, the University ordinarily will not undertake projects that limit benefits to one corporation or agency but will accept projects that benefit an entire industry or the public.
Social Action and Advocacy
The University encourages sponsored projects that seek to discover and disseminate knowledge in the areas of human rights and welfare. However, in order to remain free to continue the quest for knowledge, the University cannot assume the role of an advocate or social action agency.
Persons Authorized to be Principal Investigators (PI) or Project Directors (PD) for Sponsored Projects
When the University accepts a grant or contract from an outside sponsoring agency, certain legal and ethical obligations are stated or implied in the document of agreement. The University becomes responsible for the proper performance of the stated work and for fiscal management of the funds received from the sponsor. Sponsors usually require that an individual be named to oversee the project with the reasonable assurance that the agreed responsibilities will be discharged faithfully and prudently in the mutual interest of the sponsor and the University and over the full period of the award.
To implement these obligations, only individuals in certain categories are automatically authorized to be PI/PDs for sponsored projects: - Members of the faculty in the professorial ranks (Assistant Professor, Associate Professor, and Professor)
- Adjoint faculty (Adjoint Assistant Professor, Adjoint Associate Professor, and Adjoint Professor
- Professors of Practice
- Professors of Instruction
- Faculty Associates
- Directors, Chairs, Deans, VPs, AVPs
- Affiliate or Clinical Faculty when all the research will be conducted at the University, Dell Medical School, or affiliated facility
- Research scientists/engineers and senior research scientists/engineers
- Research Associates
OSP may authorize the following to hold PI/PD status following a request from appropriate leadership within their college or unit, like a Director, Chair, Associate Dean for Research, or Dean:
- Assistant and Associate Professors of Practice
- Assistant and Associate Professors of Instruction
- Emeritus Faculty
- Faculty Instructors
- Instructors
- Lecturers
- Librarians
To learn more about the exception process, visit https://research.utexas.edu/resources/research-integrity-and-compliance/serving-as-pi.
Award Recipient
The execution of sponsored research by University faculty and staff relies on the unique facilities and resources made available through public funding. All external grant and contract funding utilized to execute sponsored projects by University faculty and staff using University facilities or resources must be approved and managed through and by the University. University faculty and staff may pursue funding from organizations which only issue awards directly to individual researchers (e.g., John Simon Guggenheim Memorial Foundation Fellowships), provided the faculty or staff provide notification of the award to OSP. University faculty or staff may not serve as a PI or Co-PI on sponsored research funding awarded to an outside institution without advance approval from the Assistant Vice President for Research, Office of Sponsored Projects.
- Proposal Administration
All funding proposals to sponsoring agencies must be reviewed and approved at certain University administrative levels before being transmitted to the sponsoring agency.
Departmental and College/School policies must be adhered to and, if required, proposals must be approved by designated departmental reviewers and approvers, such as:
- Department Chair (or Unit Head)
- Associate Dean for Research
- Dean (or Director)
The official applicant for external funds to support sponsored projects at the University is The University of Texas at Austin. As such, only duly named and authorized individuals in OSP can endorse and submit proposals on behalf of The University of Texas at Austin. All proposals, after preparation and initiation by the individual PI/PD, must be reviewed and approved by OSP prior to transmittal to the sponsoring agency.
In some cases, depending on the nature of the proposed activity, the cost of the project, or institutional commitments involved, the U.T. System administration may require prior review and approval. PIs/PDs should contact the OSP during proposal preparation to ascertain the required approvals.
By submitting a proposal to OSP, the PI/PD certifies that the statements and documents sent to OSP are true, complete, and accurate to the best of their knowledge and accept the obligation to comply with terms and conditions set forth by a sponsor if a grant application is awarded. The PI/PD is aware that any false, fictitious, or fraudulent statements or claims may subject them to criminal, civil, or administrative penalties.
All proposals must be facilitated by a Funding Proposal (FP) and Budget (BU) in UTRMS, OSP’s electronic research management system, and include proposal packet contents prior to final review and submission:
- Funding Opportunity or Solicitation
- UT Statement of Work
- Budget for University portion of work
- Budget justification for University portion of work
- Sponsor IDC policy if it deviates from the University’s standard F&A rate
- If the University’s prime sponsor requires a subaward commitment form, the form must be provided at the start of proposal review process
- Subaward packet (if the proposal has a subaward):
- Letter of Commitment from OSP counterpart
- Statement of Work
- Budget
- Budget Justification
- Consultant letters that confirm named consultants are aware of their commitment and contributions to the sponsored activity
The FP and proposal packet will facilitate administrative review and approval, thus helping to expedite processing. A copy of all final proposal documents must be filed with OSP, regardless of submission format or channel.
- Award Acceptance and Management
Authorized Signatory
Externally sponsored project awards are issued to the institution, and only those individuals with signature authority delegated by the University President are authorized to accept the award agreement. PI/PDs, Department Chairs, and Deans do not have signature authority for sponsored projects and should work with OSP to secure the appropriate signature. Likewise, OSP and Discovery to Impact have delegated authority for the negotiation of all terms and conditions in sponsored project award agreements.
Account Management of Expenditures
Sponsored projects are set up within the OSP 26 financial account series with budget periods consistent with the award document or award agreement. Expenditures incurred prior to the effective start date of the sponsored project may not be charged against the award unless specifically authorized in the award, when approval has been granted by the sponsor, or through expanded authorities granted by federal agencies. Expenditures over the life of the award must be incurred within the approved project period. Transactions after the expiration date must have service dates within the authorized funding period and goods/services must be received during the grant’s life. The PI/PD has primary oversight to ensure that all charges and budgetary decisions for an externally sponsored project are made in accordance with the terms and conditions of the award, including the approved budget, and in accordance with the relevant policies of the University and state, federal, and other pertinent regulations governing the sponsored project.
All costs charged to a sponsored project must be allowable, reasonable, and allocable (see 2 CFR 200 Subpart E—Cost Principles). A cost is not necessarily allowable just because it is proposed and not excluded from the award or because it is invoiced and not excluded by the sponsor when reimbursed. Costs must meet the following criteria, and may be found unallowable even after award closeout:Allowable: A direct cost is allowable when it is necessary for the project and meets the criteria for reasonable and allocable costs outlined here as well in 2 CFR 200.403. An allowable direct cost must: - Conform to the terms and conditions of the award itself;
- Be consistent with University policies and practices;
- Be treated consistently as a direct cost (as opposed to an indirect cost) when incurred for the same purpose in like circumstances;
- Not be included as a cost or cost share on another award;
- Be adequately documented.
Reasonable: A direct cost is reasonable when it does not exceed that which would be incurred by a prudent person (2 CFR 200.404). A reasonable direct cost must: - Be ordinary and necessary for the proper and efficient performance of the award;
- Conform to the terms of the award, all applicable regulations, and sound business practices;
- Conform to market prices for comparable goods and services in the area;
- Be incurred with all responsibilities to the University, the public, and the sponsor having been prudently considered;
- Be consistent with University policies and practices.
Allocable: A cost is allocable to a particular award if the relative benefit of the goods or services can be assigned to that award. The cost must be incurred specifically for the award and be charged to the award proportionally to the benefit the award received (2 CFR 200.405). See OSP’s Cost Allocation page for more details on how to apply cost allocation methodologies.
Reporting and Closeout
It is the responsibility of the PI/PD to ensure that all periodic and final scientific/technical reports associated with sponsored projects are transmitted timely to the sponsor through OSP in accordance with the terms and conditions and deadlines of the award. OSP requires a copy of any report submitted by the PI/PD directly to the sponsor. Failure to submit reports on a timely basis may result in action by the University against the PI/PD, including ineligibility to submit any future proposals for sponsored research until all delinquent reports have been submitted and accepted by a sponsor.
The University, through Discovery to Impact, Inventory Services, and OSP, is responsible for submitting all invention, equipment/property, and fiscal reports. The PI/PD shall work with these offices and provide the necessary information to ensure the timely and accurate submission of all reports. 