Sponsored Programs

//SPONSORED PROGRAMS

Office of Sponsored Programs

The Office of Sponsored Programs includes resources to assist program staff when seeking external funding in support of our Tribal Colleges and Universities.  

FEDERAL FUNDING SOURCES:

National Science Foundation:
The U.S. National Science Foundation is an independent federal agency that supports science and engineering in all 50 states and U.S. territories.

National Institutes of Health:
NIH is part of the U.S. Department of Health and Human Services and the largest biomedical research agency in the world.

NIH’s mission is to seek fundamental knowledge about the nature and behavior of living systems and the application of that knowledge to enhance health, lengthen life, and reduce illness and disability.

OTHER FUNDING SOURCES:

Grants.gov is a common website for federal agencies to post discretionary funding opportunities and for grantees to find and apply to them. 

FedConnect: The Government Acquisition and Grants Portal

GrantWatch publishes grants by foundations, corporations, states, locales and the federal government.

Pre- and Post-Award Resources

Identify a Need or Idea

This usually starts with discussion among colleagues and/or students.

Identify a Funding Source

The most common source of sponsored program support is the federal government. State governments and private foundations are also good sources of support. The links listed under ‘Federal Funding Sources’ above are good starting points to begin your search.

If you have a good idea, but cannot identify an appropriate source, do not hesitate to call or e-mail agencies and foundations with your concept and ask for their assistance in seeking potential sponsors (funders). This is a service that sponsors readily provide.

Obtain Institutional Approval for Your Idea

It is important to involve all relevant parties at your institution to ensure your idea is a commitment your institution is willing and able to make. The availability of suitable space, potential cost sharing requirements, personnel time commitments, and the ability to sustain a project after sponsored funding ends, may preclude an otherwise good idea from being supported at a given time.

Start by completing a Sponsored Program Approval Form, if applicable to your institution, before writing the proposal. This form is designed to help ensure that individuals do not spend time writing proposals that cannot be supported by the institution, and additionally, to prevent the duplication of proposals being drafted for any given opportunity.

Understand What Must be Included in the Proposal and Know How It Will be Evaluated

Most of the time you will be writing in response to a specific RFP (Request for Proposals), or NOFA (Notice of Funding Availability), and/or a notice in the Federal Register. A sponsor generally describes in detail the types of projects a program is designed to support, which type organizations are eligible to apply, what must be included in an application, and how the proposal will be evaluated, or scored. These are requirements, not suggestions. Many times an RFP will provide the exact wording you are to use for various headings and sub-headings, page limitations, font size, margin size and line spacing. A proposal can be declared ineligible if it deviates from the required formatting.

Know the deadline for submission. A date will usually be provided identifying the date and time the proposal must be received by the sponsor. Make sure you are meeting the correct deadline according to your submission choice. Private foundations may not have deadlines.

Make sure you allow time for your institution’s president and/or your supervisor to read the final proposal before submission. Build in a few days to a week to allow enough time for their review; not a few hours.

Get Help for Writing

A proposal will generally be made stronger by involving more people in the writing and review process.

Try to create a writing team. Allocate specific portions of the grant to different individuals, according to their writing strengths. It is best that a lead writer be identified so that the entire proposal is coherent and written in a single style. If you chose to go it alone, please make sure you have a reliable proofreader, at minimum.

Though things are changing slowly, you should generally assume that the people reading your proposal do not know what a tribal college is, or how they differ from mainstream institutions. You will want to devote some space in the first part of your proposal to describe your college, the communities and students it serves, its mission, strengths and challenges. It is often expeditious to adapt some of this information from a successful grant in the college’s archives. This template can be obtained through the office of AIHEC Sponsored Programs (ASP); please do not copy text verbatim, make sure the information is current and that it is emphasizing aspects of particular relevance to your proposal.

Budgets can be difficult. Please get guidance and review from your supervisor on your proposed budget, the college business office and AIHEC.

A Budget Narrative’s purpose is to support the budget proposal.  Make sure it aligns closely with your budget. The budget narrative contains the specifics of how you arrived at the expenditures in the budget. The budget narrative should utilize sub-headings identical to the line items used in the budget.

Neatness counts. Generally, people reviewing proposals are under severe time constraints to read and critique a large number of proposals in a short amount of time. Use headings and tables that clearly identify the content and make it easier for readers to understand exactly what you are proposing. Brevity is usually preferred over lengthy elaboration. Generally, avoid the use of color; it can often be distracting, and the effect will be lost if the sponsor needs to make copies of your proposal.

Forms

If you are writing to a federal agency, there will be a large number of forms required. It’s best to assign one member the task of insuring that all necessary forms are included.  

Submission

Have a checklist of what must be included in the proposal submission. Double check your formatting requirements, page limits, font size and spacing requirements.  Some sponsors will decline the proposal if these requirements aren’t followed.  AIHEC uses the DARCI Project Management tool.  It’s helpful in tracking proposal requirements from creation to submission. 

Wait

There can often be a long period of time between proposal submission and notification from the sponsor regarding whether your idea is to be awarded funding. Notification dates are generally printed in the RFP or NOFA. Do not hesitate to call a sponsor if this date has passed and you have not heard from them.

Often times, the sponsor will notify you if they have questions or require additional information.  Be prompt and thorough in your response.  

The grant reviewers (sponsor) evaluating your proposal prepare written comments, describing what they identify as your proposal’s strengths and weaknesses. Be sure to obtain these after the award notification date has passed. These comments are valuable tools in the grant-writing process and will help you improve your grant-writing skills.

If your proposal was not funded, obtain and utilize the readers’ comments to identify ways of strengthening the proposal, and submit it to the next round of funding or look for a new sponsor. Sponsors generally have limited funds and worthy proposals can be denied simply because the available monies were not sufficient to cover the number of proposals submitted.

Following is a list of resources to consult prior to writing a proposal. A strong proposal incorporates data and references to other sources documenting need and supporting the methodology/solution described in an application. Grant reviewers like to see that a writer has done research to accurately identify and quantify (where possible) the nature of a problem. A search of the literature and best practices employed by other institutions in similar situations substantially strengthens a proposal.

STEM Resource Statistics:  The National Science Foundation site contains statistical information on the demographics of STEM students, graduates and workforce.

EduCause is a nonprofit association advancing higher education through the use of information technology.

Directory of Open Access Journals: For academic communication, this site offers free, full text, quality controlled scientific and scholarly journals that aims to cover all subjects and languages.

National Council of University Research Administration: NCURA has an excellent resource page entitled the Fundamentals of Sponsored Project Administration.

Because grants are non-repayable funds (firm fixed-price contract), provided by a corporation, trust, foundation, or government agency, grant approval is a competitive process. The grant application is substantiated with a comprehensive program budget detailing an accurate depiction of anticipated costs.  

UNDERSTAND THE FUNDER‘S REQUIREMENTS:

Before preparing the project’s budget, check the required format. Some funders require applicants to use their budget template, and some do not.  

Budget Period:

The budget period must align with the grant’s period of performance.

Budget Line Items and Level of Detail:

COSTING

It is important to use “real numbers”; line-item expenses should reflect current market values

 ALIGN BUDGET WITH BUDGET JUSTIFICATION

In addition to the budget, include a program budget justification outlining personnel, program execution, travel, equipment, participant costs, etc., and desired outcomes. Ensure the program budget is consistent with the budget justification by confirming all narrative items with an attached cost are reflected in the program’s budget.

Definition of Participant Support

Participant support costs (PSC) are “direct costs for items such as stipends, honoraria, or subsistence allowances, travel allowances and registration fees paid to, or on behalf of, participants, trainees, and/or speakers, (not your organization’s employees) in connection with meetings, conferences, symposia, or training projects. These costs are allowable with the prior approval of the awarding agency.” As a clarifying note, in order for non-employee travel to qualify as PSC, the sole purpose of the trip must be to participate in a meeting, conference, symposia, or training project/workshop.

Background Information

Participant support is provided by a number of federal agencies and other sponsors; however, the National Science Foundation has the most restrictive policies governing the budgeting, expending, and reporting of these funds. Therefore, the following policy is based upon NSF requirements, and should be followed for all federal awards. In general, participants are the recipients of service or training provided at a workshop, conference, seminar, symposia, or other short-term instructional or information sharing activity. The participants are not required to provide any deliverable to the organization or third party, nor would they be disciplined or terminated for their failure to perform.

Participants may include students, national scholars and scientists, private sector representatives, agency personnel, teachers, and others who attend and participate in the conference, workshop, or training activity. 

Participant support costs are defined by the National Science Foundation (NSF) as “direct costs for items such as stipends or subsistence allowances, travel allowances and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with meetings, conferences, symposia or training projects.”

Pertinent Regulations
“Funds provided for participant support may not be used by grantees for other categories of expense without the specific prior written approval of the cognizant NSF Program Officer. Therefore, awardee organizations must account for participant support costs separately.”

“Participant support allowances may not be paid to trainees who are receiving compensation, either directly or indirectly, from other Federal government sources while participating in the project. A non-NSF Federal employee may receive participant support allowances from grant funds provided there is no duplication of funding of items and provided no single item of participant cost is divided between his/her parent agency and NSF grant funds.”

NSF further specifies that local attendees may participate in conference meals and coffee breaks, however, grant funds may not be used to pay per diem or similar expenses for these Participants.

Purpose The purpose of this policy is to comply with federal regulations, ensuring that funds provided for participant costs are separately accounted for, and expended for appropriate and intended objectives.

Procedures

Budgeting for Participant Costs
Whenever Participant Support Costs are proposed in a budget, a detailed justification will be required that describes the purpose for the costs and the way in which they will directly benefit the proposed project’s scope of work. Upon receipt of an award that includes Participant Support Costs, the Principal Investigator will be notified of the specific restrictions governing the expenditure of these funds.

Identifying and Accounting for Participant Costs
When an award provides funding for participant support, a separately budgeted cost code should be established in the Accounting Application. The cost code description should be entered in the Accounting Application and assigned as “Participant Costs” for the grant in order to more easily identify and isolate these expenses.

Post Award Project Management

Award Acceptance

Once the funding has been awarded, project implementation begins. 

Project Implementation and Management

Throughout implementation and project management, the program manager monitors program activity and budget expenditures, to ensure the program is on target and performing within the designated timeline, adjusting where necessary.

Any proposed changes may require an agency approved ‘change request’, as outlined in the award’s terms and conditions. If needed adjustments to the budget or statement of work are identified, a thorough review of the funder’s contract terms and conditions must be done to determine any required permission(s) and/or steps to follow, prior to implementing any changes.

Reporting Requirements

Narrative and financial reporting is a formal way to update funders on what has been accomplished with their funding. While many funders have grant reporting guidelines, some funders do not.

Federal Funders require the completion of an SF425 (Federal Financial Report). Additionally, most funders require a Narrative (or Project) report.  While report requirements differ by funder, a narrative is normally a summary of the previous quarter’s or year’s activities and outcomes.

In most cases, awarding agencies assign each grant a designated grant management official (GMO) and program officer (PO), both of which work with the principal investigator (PI) throughout the life of the grant. The principal investigator will have open lines of communication with the GMO and/or PO as they are the designee for reviewing program reports and conducting site visits. 

FSRS Reporting Requirements

As of October 1, 2010, prime grant recipients awarded a new Federal grant totaling $20,000 or more, are subject to FFATA subrecipient reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010.  This requirement mandates AIHEC file an FFATA subrecipient report by the end of each month following the month in which AIHEC made a subrecipient award greater than or equal to $30,000.  These reports are filed monthly in the Federal Funding Accountability and Transparency Act Subrecipient Reporting System (FSRS).

No Cost Extension (NCE)

When the project’s end date is approaching and the PI determines that program and/or research will not be completed within the specified grant project period, the program manager may request a No Cost Extension.  The amount of carryover funding will be determined and used to create a budget for the extension period.  

Preparation for closeout should begin three months prior to the grant’s end date.  The grant agreement contains specific information for close out requirements, e.g., required documents, financial reporting, etc.  

All supporting documents and financial, statistical, and performance records are typically retained for a period of seven years.

Compliance Reminder

Failure to submit timely and accurate final reports adversely affects future funding decisions and/or awards with the same principal investigator. Accordingly, the funder may impose sanctions on the organization if/when recurring reporting problems are not corrected. Such sanctions may include restricting facilities and administrative (F&A) costs, delaying or withholding further awards to the project or program, and/or the organization receiving a high-risk grantee designation.

AIHEC Grant Application and Award Management

GENERAL INFORMATION STATEMENT

American Indian Higher Education Consortium (AIHEC) encourages staff to seek external funding to support projects and activities that align and enrich our institutional mission.  AIHEC central office provides this grant information to assist staff in the preparation of grant applications and proposals for research, service, curricular development, training, and other program operations supported by external funding.  The content found here outlines procedures for seeking research and grant funding. 

Things to consider when seeking external funding

Determine the type of grant most appropriate to the need:

Grant Criteria 

Confirm the grant meets one or many needs of the Tribal College and University’s (TCUs) needs; generally determined through research data collection/analysis, stated priorities, etc. and also supports AIHEC’s mission and strategic priorities as laid out in AIHEC’s current Strategic Plan

Types of Proposals

 Determine which type of proposal(s) to develop to apply for the grant (at times, both an LOI + proposal is needed):

RFP Criteria – Deciding to Move Forward 

Deciding factors for responding to a Solicited Proposal (RFP):

Funding Sources

AIHEC staff looks to foundations and organizations (funders) who share AIHEC’s values, interests, and goals. The Federal government also offers considerable funding opportunities; most AIHEC grants are federally funded.

Proposal Summary Approval Form

Prior to pursuing any funding opportunity, approval must be gained from AIHEC’s President & CEO.  This is done by completing AIHEC’s Proposal Summary Approval Form (PSAF). The form must be completed in its entirety and forwarded to AIHEC’s Grants Administrator who will, in turn, forward for approval.   Once approved, the program manager may proceed with writing the proposal.

DARCI

Once the opportunity has received approval to pursue, the Grants Administrator develops a DARCI specific to the funding announcement or solicitation.

DARCI is AIHEC’s project management tool and is used to track and assign tasks, develop timelines, and promote coordination and collaboration.  

Because grants are non-repayable funds (firm fixed-price contract), provided by a corporation, trust, foundation, or government agency, grant approval is a competitive process. The grant application is substantiated with a comprehensive program budget detailing an accurate depiction of anticipated costs.  The Program Manager works with the Manager of Finance & Accounting to construct a budget that aligns with both AIHEC and Funder requirements. 

UNDERSTAND THE FUNDER‘S REQUIREMENTS

Some funders require applicants to use their budget template, and some do not.  If the funder provides a budget template, AIHEC staff will complete both  AIHEC’s budget template and the funder’s budget template.  AIHEC requires the grant applicant to complete AIHEC’s budget template for each proposal submission, as it aligns with the organization’s budget categories and financial reporting.

Budget Period

The budget period must align with the grant’s period of performance

Budget Line Items and Level of Detail

AIHEC requires program staff to work in concert with the Finance Department to develop budgets and budget justifications.

COSTING

It is important to use “real numbers”; line-item expenses should reflect current market values

ALIGN BUDGET WITH BUDGET JUSTIFICATION

In addition to the budget, include a program budget justification outlining personnel, program execution, travel, equipment, participant costs, etc., and desired outcomes. Ensure the program budget is consistent with the budget justification by confirming all narrative items with an attached cost are reflected in the program’s budget.

Budget and Budget Justification Review and Approval Process

Post Award Project Management

Award Acceptance

Once the funding has been awarded, project implementation begins. 

Project Implementation and Management

Throughout implementation and project management, the Program Manager monitors program activity and budget expenditures, to ensure program is on target and performing within the designated timeline, adjusting where and as necessary.

Any proposed changes may require an agency approved ‘change request’, as outlined in the award’s terms and conditions. If needed adjustments to the budget or statement of work are identified, a thorough review of the funder’s contract terms and conditions is performed to determine any required permission(s) and/or steps to follow, prior to implementing any changes.

Reporting Requirements

Narrative and financial reporting is a formal way to update funders on what has been accomplished with their funding. While many funders have grant reporting guidelines, some funders do not.

Federal Funders require the completion of an SF425 (Federal Financial Report). Additionally, most funders require a Narrative (or Project) report.  While report requirements differ by funder, a narrative is normally a summary of the previous quarter’s activities.

In most cases, awarding agencies assign each grant a designated Grant Program Officer and Program Officer (GPO), both of which work with the Principal Investigator (PI) throughout the life of the grant. Program Staff will have open lines of communication with the GPO and/or PO as they are the designee for reviewing program reports and conducting site visits. 

FSRS Reporting Requirements

As of October 1, 2010, prime grant recipients awarded a new Federal grant totaling $20,000 or more, are subject to FFATA subrecipient reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010.  This requirement mandates AIHEC file an FFATA subrecipient report by the end of each month following the month in which AIHEC made a subrecipient award greater than or equal to $30,000.  These reports are filed monthly in the Federal Funding Accountability and Transparency Act Subrecipient Reporting System (FSRS).

No Cost Extension (NCE)

When the project’s end date is approaching and the PI determines that program and/or research will not be completed within the specified grant project period, the Program Manager may request a No Cost Extension.  The amount of carryover funding will be determined and used to create a budget for the extension period.  

AIHEC’s Subrecipient Selection Procedures determines which TCUs will be receive a subrecipient award from AIHEC.  The procedure requires the prospective subrecipient to complete an AIHEC Subrecipient Application in response to an AIHEC Request for Application, in order to be considered for AIHEC subrecipient funding. Only regular member institutions in good standing with AIHEC are eligible to apply for subrecipient funding. 

Applications are evaluated by using AIHEC’s Subrecipient Application Scoresheet and awards are made based on the results. While AIHEC chooses the subrecipient(s) for most AIHEC grants, some are pre-selected by the awarding agency or organization. In these cases, an AIHEC evaluation is waived.

The awarded Subrecipient enters into the contract process with AIHEC.  The contract process includes:

AIHEC considers accreditation (and pre-candidacy status) conferred by a regional accrediting body to be a fair indication of a sub-grantee’s organizational and fiscal capacity.  

AIHEC program staff monitors subrecipient activities and ensures all contractual requirements are fulfilled including the timely submission of properly completed narrative and financial reports.

AIHEC requires quarterly reports from all subrecipients, regardless of funder requirements. These reports must include, at minimum, completion of a Project Narrative and SF425 financial report. The financial reports will be reviewed and program staff will be alerted to any abnormalities, e.g., subrecipient report does not demonstrates funding is being spent down to accommodate work performed under the subrecipient statement of work.  For cases like these, AIHEC reserves the right to withhold future installments and/or require the remaining funds be returned to AIHEC. 

Report reminders are sent to Subrecipient program staff 15 days in advance of the report due date and notes required elements of reporting, e.g., narrative, SF425, and other elements noted in the contract.  

If the reports are not received by the contractual due date, a warning communication is sent to the Subrecipient program staff describing the consequences of non-compliance and offers reasonable assistance. If no response is received, a second communication is sent to the Principal Investigator and the TCU’s President reiterating the consequences of non-compliance; noted as follows:

(2) Consequences of non-compliance are:

If the required report is not received within 45 days after the due date, at AIHEC’s discretion, a certified letter is sent to the institution’s president citing non-compliance and, consequently, the measures described in (2) ‘Consequences of non-compliance’ remain in effect until the institution has returned to a status of compliance by meeting all contractual requirements.

AIHEC does not distribute funding to any institution or provide support for such institution’s faculty to participate in AIHEC sponsored activities if the institution is not in compliance with relevant grant proposal submission and accountability requirements.

SUBRECIPIENT AWARD MONITORING

SUBRECIPIENT POST–AWARD MONITORING

AIHEC program staff work closely with subrecipients throughout the grant period via electronic and telephone communications, workshops, and site visits (as necessary).

Participant Support Cost Guidelines

Definition of Participant Support Costs

Participant support costs (PSC) are “direct costs for items such as stipends, honoraria, or subsistence allowances, travel allowances and registration fees paid to, or on behalf of, participants, trainees, or speakers, (but not employees) in connection with meetings, conferences, symposia, or training projects. These costs are allowable with the prior approval of the awarding agency.” As a clarifying note, in order for non-employee travel to qualify as PSC, the sole purpose of the trip must be to participate in a meeting, conference, symposia, or training project/workshop.

Background Information

Participant support is provided by a number of federal agencies and other sponsors; however, the National Science Foundation has the most restrictive policies governing the budgeting, expending, and reporting of these funds. Therefore, AIHEC’s participant support policy is based on NSF requirements. In general, participants are the recipients of service or training provided at a workshop, conference, seminar, symposia, or other short-term instructional or information sharing activity. The participants are not required to provide any deliverable to the organization or third party, nor would they be disciplined or terminated for their failure to perform.

Participants may include students, national scholars and scientists, private sector representatives, agency personnel, teachers, and others who attend and participate in the conference, workshop, or training activity. Unless specifically provided for in the award document, AIHEC staff are not eligible for participant support cost.

Pertinent Regulations
“Funds provided for participant support may not be used by grantees for other categories of expense without the specific prior written approval of the cognizant NSF Program Officer. Therefore, awardee organizations must account for participant support costs separately.”

“Participant support allowances may not be paid to trainees who are receiving compensation, either directly or indirectly, from other Federal government sources while participating in the project. A non-NSF Federal employee may receive participant support allowances from grant funds provided there is no duplication of funding of items and provided no single item of participant cost is divided between his/her parent agency and NSF grant funds.”

NSF further specifies that local attendees may participate in conference meals and coffee breaks, however, grant funds may not be used to pay per diem or similar expenses for these participants.

Purpose: The purpose of this policy is to comply with federal regulations, ensuring that funds provided for participant costs are separately accounted for, and expended for appropriate and intended objectives.

Procedures

Budgeting for Participant Costs
Whenever participant support costs are proposed in a budget, a detailed justification will be required that describes the purpose for the costs and the way in which they will directly benefit the proposed project’s scope of work. Upon receipt of an award that includes participant support costs, the principal investigator will be notified of the specific restrictions governing the expenditure of these funds.

Identifying and Accounting for Participant Costs
When an award provides funding for participant support, AIHEC manager of finance and accounting will establish a separately budgeted expense account number in the Greatplains Accounting application. The expense account number’s description will be entered in the accounting application and assigned as “participant costs” for the grant in order to more easily identify and isolate these expenses.

Greatplains Accounting Application expense account numbers and Greatplains FRX expense descriptions can further differentiate expenses:
xxx-xx-587 – Stipends
xxx-xx-508 – Honoraria & Speaker Gifts
xxx-xx-547 – Reimburse Expenses – Advisory Committee
xxx-xx-548 – Reimburse Expenses – Speakers
xxx-xx-549 – Reimburse Expenses – Non Staff
xxx-xx-522 – Participant Meeting room rental

Monitoring the Project
The staff accountant identifies all PSC to include all pertinent information regarding the type and amount. Budget descriptions for PSC will then be entered into the participant cost section of FRX database. The database is used to create monthly and quarterly review of all budgeted expenses. Each month, the accountant and Vice President of Finance & Administration reviews the grant financial statements, transactions, and source documents, if necessary, to ensure the funds are being expended according to federal regulations and the terms of the agreement. If questions or concerns arise, the staff accountant will notify the appropriate grant program manager for further evaluation and/or corrective action. When the project is complete, or all funds have been expended appropriately, the accountant notifies the Vice President of Finance & Administration who notifies the grant program manager. The expense account is then disabled on the accounting application. Once all of the funds are expended, a final financial report is prepared by the staff accountant and reviewed by the Vice President of Finance & Administration. A copy of the report is placed in the grant accounting file, and a copy of the report is sent to the grant program manager. The program manager files the final report when required. A copy of the final report and a financial summary is placed in the official project file.

AIHEC begins preparing for award closeout three months prior to the grant’s end date.  The grant agreement is reviewed to determine close out requirements, e.g., required documents, financial reporting, etc.  AIHEC’s finance department closeout activities include a review and evaluation of final reports, determination of allowable costs, and calculation of funds due to the funder or recipient.

All supporting documents and financial, statistical, and performance records are to be retained for a period of seven years.

Compliance Reminder

Failure to submit timely and accurate final reports adversely affects future funding to AIHEC and/or awards with the same principal investigator. Accordingly, the funder may impose sanctions on the organization if/when recurring reporting problems are not corrected. Such sanctions may include restricting facilities and administrative (F&A) costs, delaying or withholding further awards to the project or program, and/or AIHEC receiving a high-risk grantee designation.

Timesheet Reporting Policy

This policy provides requirements and guidelines for timesheet reporting of AIHEC staff.

Responsibilities

AIHEC employees prepare their Timesheet semi-monthly, which coincides with AIHEC’s pay period.

Employee:
• Records time worked and absent on electronic timesheet
• Records timesheet based on hours worked on cost center. Timesheet must reflect accurately how employee spent his/her time in various grant cost centers.
• Submit leave request approved by supervisor for any leave time claimed on timesheet for each pay period.
• Submit timesheet on semi-monthly basis.

Project Coordinator/ Supervisor
• Ensures cost-shared labor commitments are identified in the grant budget.
• Reviews and approves direct report timesheets.

Principal Investigator
• Ensures timesheet is accurately documented.
• Ensures accuracy of the timesheet for all direct reports.
• Monitors and reviews their projects’ timesheet on a regular basis to ensure the accuracy of all effort expended on the sponsored project.
• Ensures the proposed level of effort is reasonable and necessary to carry out the proposed project.
• Ensures the individual listed in a proposal is aware and has approved his/her participation in the activity and the committed effort in the proposal has been reviewed and approved by his/her supervisor.
• Ensures that an individual’s total effort does not exceed 100%.
• Ensures that their own activities will not conflict with the proposed effort commitment.
• Obtains sponsor’s prior approval when the reduction for the effort of PI and/or key personnel is greater than 25% (OMB A-122).
• Establishes effective processes and controls to ensure compliance with effort reporting requirements, and provide oversight for those processes and controls.

Senior Accountant
• Ensures the distribution of salaries and wages are supported by timesheet.
• Contacts project coordinator/supervisor to follow-up with timesheet not returned in a timely manner.
• Tracks the receipt of timesheet forms to ensure 100% submission.

Payroll Allocation to the General Ledger
Each award is assigned an individual internal cost center. The unique cost center identifies the federal award on each timesheet. Timesheets are completed based on hours worked. If an employee works on a federal award, the hours worked on the award is recorded to the award cost center listed on the employee’s timesheet. Once the timesheets are compiled, federal award hours are totaled and the number of hours for each award is calculated based on the employee hourly rate and the number of hours charged to various award cost centers. The salary wages are then processed and charged to the federal award.

AIHEC requires each ‘Principal Investigator’ (as defined below), for each of AIHEC’s awards, review AIHEC’s Financial Conflict of Interest Policy (FCOI), complete the FCOI Disclosure Form, and NIH FCOI Interactive training .  The Policy states that, by law, all Investigators applying for and working on award funded research, where required, must disclose significant financial interests that are related to the Investigator’s institutional responsibilities.  In the Policy, Investigators are defined as “the project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of award funded research or proposed for such funding, which may include, for example, collaborators and/or consultants”.   This policy also applies to subrecipient program staff. 

AIHEC program staff and Subrecipient program staff are considered ‘in compliance’ with AIHEC’s FCOI policy when the following are completed:

  1. The FCOI Policy is reviewed in its entirety
  2. FCOI Disclosure Form is completed/signed
  3. The NIH interactive Financial Conflict of Interest training is complete and the Certificate is sent to the AIHEC Business Office via email.. This training is required every four (4) years.

Examples of Conflict of Interest:

  1. An institution’s researcher holds an executive position with a company that stands to benefit from the research being conducted at the institution.
  2. An institution’s researcher holds equity over a certain dollar amount or percentage of a company that stands to benefit from the research study at the institution.
  3. A researcher receives significant financial compensation in the form of consulting payments or payment for services on a company’s advisory board from a company that will be affected by the research study

Example:  A member of program staff hires an Evaluator to conduct focus groups and administer surveys in order to collect data for a report that identifies possible solutions to increase the graduation rate of AIAN students. The research results show graduation rates increased for those that receive career counseling and support services.  That same Evaluator owns a company that provides these services.

Because the Evaluator’s company could potentially benefit from the results of the survey, this is considered a Financial Conflict of Interest or potential Financial Conflict of Interest.

Grants Management Policy

GIFTS and GRATUITIES
In order to avoid a conflict of interest or the appearance of a conflict of interest, at no time should an employee solicit or accept gifts from a vendor or contractor or from a potential vendor or contractor except as described below.

Unsolicited personal gifts valued at $25.00 or more cannot be accepted by employees and should be returned immediately to the donor. If the value of the gift is undetermined it should be returned. Ordinary business courtesies, such as payment for a modest lunch or dinner, are acceptable provided it does not exceed the value listed above. Gifts which are promotional items without significant value, and which are distributed routinely by the vendor to clients, are also acceptable.

Gratuities or gifts of money to the employee cannot be accepted at any time and should be returned immediately to the donor. Employees who have questions regarding this policy should confer, in writing, with their supervisor (or AIHEC’s Finance & Administration Director) to determine an appropriate course of action.

All employees are subject to this policy and are expected to comply fully. Instances of deliberate breach of policy, or failure to comply with the policy, will be reported to AIHEC’s President and CEO for appropriate action.

HUMAN RESEARCH PARTICIPANTS
Sponsored research involving human subjects, which may include people who are being interviewed and/or electronically recorded, has strict guidelines intended to protect these individuals. Personnel involved in such research need to be informed on how to ensure proper protection of their rights. Per AIHEC board motion, AIHEC’s Institutional Review Board (IRB) is Northwest Indian College (NWIC).  Proposals that include human research participants must be approved by an Institutional Review Board (IRB) prior to being submitted. A copy of the IRB Guidebook developed by the Department of Health and Human Services (DHHS) is available on-line. Access the full Code of Federal Regulations text defining Protection of Human Subjects regulations as specified by DHHS.

Many federal agencies involved in sponsoring research involving human subjects, have adopted the same set of regulations, referred to as the “Common Rule.” The National Science Foundation (NSF) Web site has a page on Human Subjects that is both easy to use and understand and a FAQ’s page to help people interpret these regulations.

Grant that include research and any grant applications involving human subject research, and all applications made to the National Institute of Health must provide assurance (‘assurance’ defined as ‘completing HHS Human Subjects Certification), that all key personnel have been educated in how to ensure proper protection of human subjects. 

OMB CIRCULARS
The Office of Management and Budget (OMB) has declared that all tribal colleges, “…regardless of whether they are part of an Indian Tribal government…” must follow circular A-21, in addition to A-110 and A-133. There is a similar circular, A-87, entitled “Cost Principles for State, Local and Indian Tribal Governments” that does not apply to tribal colleges and universities.

  1. A-21 Cost Principles for Educational Institutions
  2. A-110 Uniform Administrative Requirements
  3. A-133 Audit Requirements

FEDERAL AGENCY GRANT REGULATIONS
Always read the award documentation that is received from the sponsoring agency. The award letter contains vital information and also generally specifies the Terms and Conditions that govern how an award should be managed. As of July 2008, many federal agencies have standardized terms and conditions in an effort to simplify award management. The information provided below is a general guideline; specific award letters should be referred to at all times for possible exceptions.

Department of Defense

  1. Department of Defense Grant and Agreement Regulations
  2. U.S. Army Research Office: The Army Research Office adopted the Standard Terms and Conditions of many other federal agencies effective July 1, 2008; also refer to the Agency Specific Terms.
  3. Office of Naval Research: The ONR adopted the Standard Terms and Conditions of many other federal agencies effective July 1, 2008; also refer to the Agency Specific Terms.

Department of Education

  1. EDGAR—Education Department General Administrative Regulations

Department of Health and Human Services

  1. Grants Policies & Regulations

NASA

  1. NASA Grant and Cooperative Agreement Handbook
  2. As of July 1, 2008, NASA will apply the Standard Terms and Conditions to all research, education and training grants. The new Standard Terms “will not apply to cooperative agreements, contracts or other transactions.” 

National Institutes of Health

  1. NIH Grants Policy Statement
  2. As of July 1, 2008, NIH will apply the Standard Terms and Conditions to all NIH grants and cooperative agreements with the exceptions noted on the NIH Agency Specific Requirements.

National Science Foundation

  1. As of July 1, 2008, NSF will apply the Standard Terms and Conditions to all new NSF grants and funding increments, and include the NSF Research Terms & Conditions, Agency Specific Requirements. NSF TCUP projects are cooperative agreements, so the Research Terms and Conditions do not apply to them.
  2. Grants Policy Manual
  3. Grants General Conditions
  4. Grant Proposal Guide—This manual is used when developing an NSF application/proposal.

National Endowment for the Humanities

  1. General Grant Provisions for Organizations

USDA

  1. CSREES General Terms and Conditions-B—These terms and conditions apply to the same awards as the General Terms and Conditions-A with the same exceptions; however, General Terms and Conditions-B applies to those recipients who have not had at least three years of managing NIFA funds. Research Terms and Conditions: Effective for awards made on July 1, 2008 or later, these Terms and Conditions have been standardized across multiple federal agencies that support research and research-related activities. This includes education and extension awards made through CSREES. Refer to: Research Terms and Conditions and Agency Specific Research Terms and Conditions.

OSP Resources

  1. NCURA: The National Council of University Research Administrators has an excellent Web site which includes a resource page entitled the Fundamentals of Sponsored Project Administration.


PROGRAM SUPPORT

Program Support offers resources for AIHEC Consultants, Students, and Subrecipients.