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Procedural Alerts

Radford University's Plan
Training Undergraduates in the Responsible Conduct of Research Policy

Background: Pursuant to the 2007 America COMPETES Act, the National Science Foundation has adopted a new certification requirement that becomes effective January 4, 2010. The new NSF Grant Proposal Guide states: "When submitting a proposal to NSF, the Authorized Organizational Representative is required to complete a certification that the institution has a plan to provide appropriate training and oversight in the responsible and ethical conduct of research to undergraduates, graduate students, and postdoctoral researchers who will be supported by NSF to conduct research." The plan must also include a system to verify that the training has occurred. The plan does not have to be submitted with proposals, but NSF could request it at any time- and NSF could audit compliance. Currently, institutions are free to develop their own plans, and at present there are no NSF- recommended models.

1. Faculty Principal Investigators (PIs) have the primary responsibility for training the students involved in their NSF- funded research. The Proposal Summary Form requires a signature (in the Research Training section) from any PI who submits an NSF proposal that requests funding for graduate or undergraduate students. This signature indicates that the PI agrees to participate in appropriate RCR Training.

2. RCR (Responsible Conduct of Research) training will be required for all graduate or undergraduates receiving wages (or working as volunteers) or receiving academic credit for participating in NSF-funded research. Training must be completed within the semester or summer that the graduate or undergraduate begins work on the NSF-funded research. RCR training will be documented on a form developed for that purpose, signed by both the PI and the undergraduate. This RCR form will be maintained by the IRB Administrator's Office. RCR training will include the following components:

  • Each student must successfully complete the appropriate CITI* module of RCR training. This requirement can be waived for students who have successfully completed an RCR workshop at another institution designed to satisfy NSF's training requirement or other comparable training; the Provost will specify what consitutes appropriate documentation in these cases. Successful completion will be documented by attaching to the RCR form a certificate generated by the onlien training program or by other documentation acceptable to the Provost.
  • PIs will certify on the RCR form that the student has received RCR training appropriate to the research and discipline.

3. PIs give the IRB Administrator periodic updates listing the students participating in the research. The IRB administrator will facilitate this process by sending reminder emails to all faculty who are PIs on NSF grants at the beginning of each semester and before summer research begins.

4. Radford University academic deans may amend this plan at any time after consultation with the Office of Sponsored Programs and Grants Management and IRB Administrator. Details of any amended plan will be sent to all faculty with NSF grants, the SPGM, and the IRB Administrator and will be posted on the SPGM and IRB Administrator websites. At a minimum, the plan will be reviewed and updated annually, no later than July 1 of each year (beginning  July 1, 2010).

5. The Provost will make decisions on a case-by-case basis about students whose only participation in NSF funded research falls into one of the following situations:

  • the active NSF grant funds equipment used in courses to provide research training
  • the active NSF grant funds research that is incorporated into the research training provided to students in a course.

To acces the training module, please go to CITI Responsible Conduct in Research Training to complete the registration and follow the instructions for your RCR training. Please contact Sponsored Programs and Grants Management if you encounter any problems. Thank you.

*CITI- Collaborative Institutional Training Initiative*

 

Personnel Effort Changes on Grants Policy

In an effort to ensure compliance with sponsor regulations, the following procedure is adopted. Effort is the amount of time a person spends working on a grant or contract. Effort cannot exceed 100% overall and should reflect as closely as possible the portion of an individual's time working on a particular grant or contract. Personnel effort is budgeted based on the scope of work included in the grant or contract proposal. Changes to personnel effort must be requested in writing to the Office of Sponsored Programs and Grants Management (SPGM), and copied to the Chair, and Dean. The request should include a justification for the change ensuring that the scope of work will be completed and address and budgetary implications. SPGM will review the request and determine if it is reasonable and if sponsor approval is necessary. SPGM will notify the Principal Investigator once a determination has been made along with any further instructions. Personnel should not change their effort without SPGM approval. It should be noted that while changes can be made retroactively, they will not be done immediately until a full review is complete of the requested change.

 

Altered Routing Requirements on Supplements, Extensions, and Modifications Policy

The following conditions have been determined to be those that require routing of changes to contracts and awards. Some examples of changes to awards are supplements, cost extensions, and modifications. If conditions are met under column A then the change does not need to be routed but an email notification of the change will be sent to all of the parties who would normally have had to sign off on a document. If the conditions under column B are met then the change will need to be routed.

Column A (no routing needed)                    Column B (must route)
Change is under $10,000                                 Cost sharing requested
No cost sharing requested                                Reassigned time requested
No reassigned time requested                          Substantial change in the scope of work
No substantial change in scope of work

 

In an effort to ensure compliance with sponsor regulations, the following procedure is adopted. Effort is the amount of time a person spends working on a grant or contract. Effort cannot exceed 100% overall and should reflect as closely as possible the portion of an individual’s time working on a particular grant or contract. Personnel effort is budgeted based on the scope of work included in the grant or contract proposal. Changes to personnel effort must be requested in writing to the Office of Sponsored Programs and Grants Management (SPGM), and copied to the Chair, and Dean. The request should include a justification for the change ensuring that the scope of work will be completed and address any budgetary implications. SPGM will review the request and determine if it is reasonable and if sponsor approval is necessary. SPGM will notify the Principal Investigator once a determination has been made along with any further instructions. Personnel should not change their effort without SPGM approval. It should be noted that while changes can be made retroactively, they will not be done immediately until a full review is complete of the requested change.

Addressing Budget Deficits Policy

In the course of monitoring and reconcilling awards, should a Post-Award Grant Specialist identify a budget deficit, defined as the committed amount, (expended + encumbered amounts), that exceeds the contracted or awarded budget, the Specialist will attempt to identify any data entry errors that may have caused the deficit and correct them. If all information on the Account Expenditure summary for the grant is correct, the Principal Investigator will be immediately notified and only personnel expenditures (salaries, wages, and benefits) will be processed against the award until such a time as the Principal Investigator has identified and corrected the items which were not budgeted and therefore created the deficit.

 

Notification of Fringe Benefit Change of Sponsored Employees Policy

For effective monitoring of grant and contract expenditures and budget balances, the following procedure is adopted:

Principle Investigators must notify the Office of Sponsored Programs and Grants Managent (SPGM) when an employee hired on a grant or contract makes a change to their benefits (increase/decrease health coverage or cash match). Employees hired on grants or contracts are entitled to the same benefit choices as non-grant emplotees. Benefit changes will affect the cost of benefits charged to your grant or contract. Some changes can significantly alter the budget and may require sponsor approved re-budgeting. The SPGM staff will assist you in obtaining any necessary budget changes and/or sponsor approvals. This process will assist Principal Investigator's in fully expending your grant or contract.

 

Preliminary Proposal Policy

In the past, letters of intent or concept papers including any kind of detailed budget have required signatory approvals. However, since preliminary proposals are not binding for the institution, Principal Investigators are only required to work with the Office of Sponsored Programs and Grants Managemenr (SPGM) to prepare these going forward. Routing for signatures will be reserved for proposals resulting in funding, rather than an invitation to submit a full proposal. It is still advised to notify chairs and deans about grant activity and to give SPGM as much notice as possible in regards to preliminary deadlines.

 

NIH PubMed Central Policy

All Radford University NIH PI's are required to ensure that publications derived from research funded by the National Institutes for Health will be submitted to PubMed Central. According to the NIH, "Authors should work with the publisher before any rights are transferred to ensure that all conditions of the NIH Public Access Policy can be met. Authors should avoid signing any agreements with publishers that do not allow the author to comply with the NIH Public Access Policy." The PI should disclose to the publisher upon submission of an article that it is subject to this NIH policy. The journal's author instructions and copyright transfer or publication agreement should be reviewed for any language that may prohibit the PI from complying with submission to PubMed Central. Specific language should appear in the copyright transfer or publication agreement specifically allowing for deposit PMC. If it does not, an addendum should be attached to the agreement by the PI. NIH recommended language is as follows: "Journal acknowledges that Author retains the right to provide a copy of the final manuscript to the NIH upon acceptance for Journal publication, for public archiving in PubMed Central as soon as possible but no later than 12 months after publication by the Journal." Decisions about the approved submission will need to be negotiated with the Publisher. Should the PI require assistance with these negotiations, the Office of Sponsored Programs and Grants Management will be happy to assist.

Pi's have four methods appropriate and consistent with the NIH publishing agreement:

  1. Publish in a journal that deposits all NIH-funded final published articles in PMC without author involvement.
  2. Make arrangements to have a publisher deposit a specific final published article in PMC.
  3. Deposit the final peer-reviewed manuscript in PMC yourself via the NIH Manuscript Submission System (NIHMS)
  4. Complete the submission process for a final peer reviewed manuscrip that the publisher has deposited via the NIHMS. http://publicaccess.nih.gov/submit_process.htm.

 

Proposal Preparation

For the purposes of clarification, the Office of Sponsored Programs is issuing the following procedural alert. In preparation of grant proposals, faculty are encouraged, but are not required to, work with the Pre-Award Office of SPGM in developing their proposals. We recommend that faculty interested in seeking external funding contact and work with the Pre-Award Office at the earliest possible opportunity to fully utilize the expertise that this office brings. It is the responsibility of the Pre-Award Office to review all proposals along with a final budget being submitted under the University's name. In order to obtain required institutional approval in time for a timely submission, a two week lead time has been instituted to being the routing process. This two weeks should allow for the PI to sign,  and obtain their Chair and Deans approvals. When discussing approval, the Chair and Dean should have a clear idea of what is being proposed and any relevant costs associated with that proposal. With less than two week to the route, the Office of Sponsored Programs cannot guarantee the required approvals will be obtained allowing timely proposal submission. Please bear in mind, that in order for the Office of Sponsored Programs to forward the proposal for approval beyond our office, the full proposal must have been provided to and reviewed by the Pre-Award Staff. this means that the proposal should be delivered to the Office of Sponsored Programs and Grants Management with ample time to review prior to routing.

Thank you for your patience and cooperation during our transition.

 

Proposal Summary Form Procedure

To more efficiently serve faculty and staff, the Office of Sponsored Programs and Grants Management (SPGM) has implemented a new procedure. Currently, proposals are routed for signature via a form known as the "pink sheet." The SPGM Director has been the first to sign, and our office has been responsible for circulating a red folder to everyone whose approval is required. Our new procedure will allow the Principal Investigator(s) to fill out and print the Proposal Summary Form, and collect the signatures of his or her chair and dean before bringing it to SPGM. It will then be reviewed by the SPGM Director and go on to the Provost and/or appropriate Vice President if necessary. The Proposal Summary Form, found here, will continue to be due to SPGM two weeks before the submission deadline. Until formal instructions are developed, SPGM staff will be happy to assist with the completion of the form over the phone or in person.

Thank you for your patience and cooperation during our transition.

 

Close-Out Procedure

In an effort to provide more service to Principal Investigators and to ensure that the University has captured all expenses applicable to a grant or contract, the following close-out procedure is adopted. The Office of Sponsored Programs and Grants Management (SPGM) will email notifications to the PI and their administrative staff (90) ninety days prior to the termination date of their grant or contract advising that the term date is approaching and if a no cost extension is going to be requested, the cut-off date for such a request is eminent. The notice will also advise the PI to review the grant or contract for appropriate charges and to start to consider final chargeds to the grant. (60) Sixty days prior to the termination date, SPGM will again send a notice to the PI that a financial and programmatic review of the status of the grant or contract should be conducted. At this point, the PI should be ensuring that the program indicated in the scope of work is nearing completion and all costs associated with that effort have been or will be captured by the grant or contract. (30) Thirty days prior to the termination of the grant or contract, SPGM will once again email the PI and their administrative staff, informing them that, with few exceptions, non-personnel charges will no longer be allowed to be charged to the accounr. Again, a request for review of the program and budget is requested.

Following the close-out of an award, when invoices are prepared by the SPGM, the PI will receive a draft copy of the final invoice for their award or contract. A review and response to the invoice should be provided to the agency delivering the invoice within two weeks. If the invoice is acceptable, no response will be considered tacit approval of the invoice. If the office of Grant Accounting prepared invoices, Sarah Underwood at (540) 831-5594.

Thank you for your patience and cooperation during our transition.

 

Signature Policy

Due to increased volume, the Office of Sponsored Programs and Grants Management (SPGM) has implemented a new procedure. When SPGM staff signature is required, documents received by SPGM by noon on Wednesday will be ready and available by noon on Friday. Walk-in's can no longer be accommodated when the requesting person or their agent wait for the signature. While we understand that emergencies arise and we will accommodate those emergencies when possilbe, all items requiring SPGM signatures received by noon on Wednesday will be ready by noon on Friday. Full review of documentation is the responsibility of the staff signing and that is not possible when one or more are waiting for documents to be approved. Instructions should be provided as to whether signed documents will be picked up or the signed document mailed to its next destination.

Thank you for your patience and cooperation during our transition.