APPENDIX 1
APPENDIX 2
APPENDIX 3
APPENDIX 4
APPENDIX 5

WVU RESEARCH CORPORATION OVERVIEW

About the Research Corporation

The West Virginia University Research Corporation is an independent, not for profit corporation which began operation in 1989. The Research Corporation was created in response to legislative action to help promote the development, implementation and coordination of sponsored research and scholarly projects in the furtherance of the University's mission. In addition to serving as the fiscal agent for the University's sponsored projects, the Research Corporation also acts for the University in managing intellectual property from the evaluation of disclosures, to patents and licensing.

Purpose of This Guide

The Project Management Guide is designed for project managers and includes basic information necessary for managing sponsored projects. The guide is intended to be used as a quick reference to help answer questions that often arise during the course of a project.

The WVU Research Corporation would like to hear any questions or suggestions you may have pertaining to changes or improvements in the contents of this guide. Please contact the WVU Office of Sponsored Research Accounting (SRA) at 293-4002, or the WVU Office of Sponsored Programs (OSP) at 293-3998.

Responsibilities of the Principal Investigator (PI), Department, and Dean

The Research Corporation provides support services and has established procedures to help meet both sponsor and university administrative requirements. The Research Corporation is, in turn, legally and financially responsible as well as accountable to the sponsor for performance of the funded activity.

Although the Research Corporation signs sponsored agreements and is, with the University, legally responsible to the sponsor, the principal investigator (PI) is responsible for the proper fiscal management and conduct of the project and for preparation of required technical and other non-financial reports. The PI is also responsible for compliance with all terms and conditions of a sponsored agreement, for efficiently and effectively managing project funds within approved budgets, and for completing the project in a diligent and professional manner.

Projects are conducted as a department or college function. If a project is overexpended or if an expenditure is disallowed, the Research Corporation expects the department or college to cover this cost. The PI is therefore responsible to the sponsor, University, college, department, and the Research Corporation for ensuring that the requirements of the agreement are met.

THE SPONSORED AGREEMENT PROCESS

Proposal Preparation

Faculty members with ideas for projects they wish to pursue should first contact a representative from the OSP who works with their college. The OSP will assist in identifying funding sources as well as the necessary application materials. Additional assistance on proposal development is also available regarding budget preparation, compliance to format, and the appropriate completion of necessary forms.

As provided by WVU policy, proposals are not to be submitted to external funding agencies until review and approval by the college, department, appropriate central academic office, and the WVU Research Corporation have been attained. The review and approval process is important and should not be overlooked. Failure to obtain the necessary approvals in a timely manner can result in delaying proposal submission and may jeopardize funding for the project. The Sponsored Programs Application Approval Sheet (Blue Sheet) must be used to obtain such approvals. This form is available from the OSP or from your college or department office. Assistance in completing the Blue Sheet is also available from the OSP.

Proposal Negotiation

As the approving office for the Research Corporation, the OSP is the only entity empowered to conduct and agree to negotiations with project sponsors. While it is recognized that some sponsors will make unilateral budget changes, which are generally reductions, any discussions with sponsor representatives which may result in changes in budget or scope of work must involve the OSP. Under no circumstances will the OSP agree to any changes without appropriate faculty involvement and approval.

Awards received by the Research Corporation that reflect some manner of negotiation between you, the PI, and the sponsor and did not involve the OSP will, at best, be delayed pending review and approval through the department, dean, and OSP. Confirmation that the changes do not affect the University's ability to perform in accordance with the sponsor's expectations is also necessary.

Proposal Acceptance and Initiation

All agreements or other documentation from the sponsor must be sent to the OSP for action by the Research Corporation. In some instances, signing a contract or other agreement may be required. The OSP initiates the formal award process within the Research Corporation's financial and administrative systems.

Based on the OSP Award Notification, SRA will assign a Fund Area Organization (FAO) number (account) and establish your project's budget. The assigned FAO for the award enables you to properly place, allocate, and record charges. You may not spend any award funds until a FAO is assigned.

Project Performance

Administrative steps for the conduct of a project may include:

• Hiring people to work on the project, including preparation of personnel posting as required by WVU Human Resources policy
• Initiating personnel appointments for those to be paid from a Research Corporation project
• Initiating release time appointments for all whose salaries will be charged to the project, either as a charge to the sponsor or as cost sharing to the project
• Certifying time reports
• Initiating fee authorizations for graduate students
• Requisitioning equipment
• Requisitioning supplies
• Arranging for travel
• Arranging for consultants
• Arranging for conferences or meetings
• Producing technical reports (monthly, quarterly or as required)
• Monitoring cost schedules
• Requesting through the OSP, with appropriate lead time, such things as

  - - modifications to agreement if program, budget, or schedule changes are needed

  - - no-cost time extensions

  - - other modifications which may require sponsor approval

• Final closeout of the project, with issuance of a final technical report.

Detailed procedural requirements for these and other actions appear in the following chapters.

PROJECT START-UP

Briefing the Principal Investigator and Project Staff Personnel

Prior to undertaking any Research Corporation project, you and your project staff should obtain as much information as possible concerning the administration of the sponsored agreement. This guide was prepared with that in mind. However, in view of the individuality of each project, we at the Research Corporation would like to meet with you and your staff to review the operating procedures outlined in this guide and discuss other various details associated with your project. If you are performing a Research Corporation project for the first time, a briefing between you and members of the Office of Sponsored Programs and the Controller's Office of Sponsored Research Accounting is especially important.

Even though you may have conducted other sponsored programs in the past, but feel, after reviewing this guide, that a personal briefing would be helpful, please contact a representative of the OSP and SRA to arrange a meeting. Also, if new personnel join your staff or if you or your staff wish to refresh or update your understanding of these procedures, feel free to contact us.

Initiating the Project

After a sponsored agreement has been received by the OSP and the SRA has assigned an account number, fund/area/organization (FAO), you are responsible for hiring personnel (including posting positions as appropriate under WVU policies), initiating personnel appointments, and submitting requisitions for any equipment, supplies, and services needed by the project.

There may be cases when an award's receipt is delayed, but the official effective date and amount of the award is known and work must proceed to meet sponsor expectations. In these instances, pre-award approval may be granted. Contact OSP for the specific proceedure.

As the PI, you are the initiator of all activities related to your project. Various offices through the WVU Research Corporation and the University itself are available for assistance. However, unless you initiate actions at the proper time, tasks associated with your project will not get accomplished.

For assistance with any administrative or business problems that may arise during the initial stages of the project, contact the OSP or SRA as early as possible.

Sponsored Award Budget Submission Worksheet

The SRA has prepared a sponsored award budget submission worksheet to assist you in preparation of your proposal budgets. Use of this worksheet during the proposal stage can help avoid missing potential hidden costs of your award. Later, after the agency has agreed to sponsor the award, the worksheet facilitates the initiation of your award into the accounting system. The worksheet appears in Appendix 5 for you reference.

Definitions for the various institutional object codes are available in the Controller's Office Procedures Manual. The SRA is available to assist you with the use of the worksheet.

Project Participation

Every individual who participates in a project administered by the WVU Research Corporation is required to fulfill certain institutional responsibilities. This applies to every sponsored project for which there is any institutional accountability, functional or financial, to an external sponsor. These responsibilities include:

1. Fulfilling detailed requirements established by federal regulations for all projects receiving federal funds (including formula funds),
2. Satisfying various expressed and implied obligations that are commonly undertaken by the University in its arrangements with nonfederal sponsors, and
3. Ensuring that participants recognize certain project-related responsibilities that derive from institutional policies and applicable law.

NOTE: It is also your responsibility to ensure that you and other personnel are properly appointed to a WVU Research Corporation project prior to performing any work on a project.

Sponsor Requirements

WVU Research Corporation systems are designed to meet normal sponsor rules and regulations. Any exceptions will be noted in the OSP Notice of Award. The full texts of sponsors' rules and regulations are available upon request from the OSP.

Hiring Process

Hiring of personnel must follow the procedures established by the Office of Human Resources. To establish a new position call 293-5494; to hire someone for an existing position, call 293-3405; for Health Sciences hiring procedures, call 293-4103.

COST SHARING

Cost Sharing

Cost sharing represents WVU's commitment to a project. Federal and other sponsors often require the University to contribute to the cost of projects. This portion, called cost sharing (or matching), is a percentage of the total cost of a project (direct costs, indirect costs and the cost sharing amount); it is subject to agency guidelines and is usually based on salaries, associated fringe benefits, and/or indirect costs contributed by the University. Any contribution to a project, even if not required by the sponsor, must be accounted for. The University's proposed contribution to a project, required or voluntary, becomes a required part of the resulting award.

When cost sharing is included in a proposal, it is essential that all commitments be established at the proposal stage and approved by the appropriate signature on the Application Approval Sheet (Blue Sheet). For cost sharing provided from an industrial participant or other sources not related to WVU, the proposal must contain a formal financial commitment from the cost sharing provider. A letter from an individual authorized to obligate the participating entity will generally suffice. Proposals will not be submitted until all proposed cost sharing is confirmed. Keep in mind that unless an agency requires cost sharing, you do not have to provide cost sharing figures in your proposal budget. If you do include cost sharing in your proposal and subsequently receive an award, the cost sharing is a requirement of that award. It is important for you to realize that cost sharing expenditures must be made during the period of performance of the sponsored award. In general, any expenditures which would be allowable expenditures on the sponsored award may be used for cost sharing.

When an award is received, the University cost sharing must be established in a dedicated Fund/Area/Org (account). This ensures that the contribution is made in a timely fashion relative to the expenditure of the awarded funds, which in turn enables timely filing of requests for reimbursement and financial reports. Reimbursements for expenditures made from the grant or contract funds, are often conditioned upon the documentation of the required contribution.

The SRA will coordinate with PIs on the documentation needed from participants not associated with WVU. The manner and timing of the reports of cost sharing contributions will depend on the nature of the project and contribution. However, in all cases, the contributor will have to provide confirmation of provided funds or services in a form that meets sponsor requirements.

If you have any questions or concerns pertaining to form or process, please contact the OSP as early in the proposal preparation process as possible.

In-Kind Cost Sharing

In-kind contributions represent the value of noncash contributions provided by the University sponsor and all other nonfederal third parties. The sponsored award documentation will specify if in-kind cost sharing may be used and what types of contributions are required. The college or school is responsible for obtaining, maintaining, and reporting in writing to the Controller's Office all accounting information and other documentation substantiating in-kind contributions. Valuation documentation must be in writing and verify the fair market value, at the time of donation, of all noncash contributions.

In-kind cost sharing can take many forms. Regardless of the form, it is important that in-kind cost sharing is separately identifiable and meets all applicable federal, agency, and institutional policies. The sponsoring agency must have approved as part of the award, the use of unrecovered indirect cost for in-kind cost sharing as also approved by the WVURC Executive Committee.

PROJECT PERSONNEL

Personnel Action Requirements

All individuals working on projects administered through the WVU Research Corporation are employed in accordance with the policies and guidelines established by the WVU Office of Human Resources and Academic Affairs. Guidelines provided by Human Resources and the Controller's Office assist in the preparation of appointment forms and related personnel and payroll documents. You must be aware that a change in funding to a sponsored research award has no effect on the basic contract salary of the employee concerned.

Each person devoting any time to a WVU Research Corporation project must be appointed to either the sponsored award FAO or the cost sharing FAO by completing the Personnel Action (PA) forms, prior to the first day of work. PAs are a group of forms that must be filled out appropriately to enact any personnel action, be it an assignment or appointment, as it applies to any project, Research Corporation or otherwise. Instructions for completing the PA form may be found in the WVU Controller's Office Procedures Manual.

You must submit PAs according to the prearranged schedule in order for the employee to receive a paycheck for that pay cycle; otherwise there is a two week delay. For more detailed information on completing Personnel Actions, contact the Controller's Office of Payroll and Travel Accounting.

Cost Sharing of Personnel

In order for cost sharing of personnel to take place during your project, a separately identifiable FAO will need to be established. The PA for this action needs to be submitted for any individual from the cost sharing FAO account.

Reporting of Effort

The Effort Reporting Certification System provides the required support for charging salaries and wages directly to grants, contracts, and other agreements as required in the Office of Management and Budgets Circular A-21 (OMB A-21). Effort reports are supplied to deans, directors, and effort support representatives for distribution. All employees who meet the following criteria should receive a copy of their project's effort report.

• Employees whose salaries are charged in whole or in part to grants, contracts, or other agreements or are used in meeting cost sharing requirements on such agreements
• Employees who expend effort toward departmental administration
• Employees who expend effort toward organized research
• Employees who perform two or more activities.

The effort reports must be signed by an individual who can attest to effort distribution by signing the certification statement on the form. The certification states, "I certify that I have suitable knowledge of all effort expended and the distribution of effort reasonably reflects the actual effort expended." Once a policy for certification has been established by each department, distribution to the proper level can be implemented.

Vacation and Sick Leave Accrual

Vacation and sick leave accruals for persons working on projects administered through the WVU Research Corporation are made in accordance with the policies and guidelines of Human Resources and the WVU Board of Trustees. Normal use of vacation and sick leave is charged proportionately to sponsored research projects and other funding at the time of use. Charges for unused vacation and sick leave may not be made after the expiration date of the sponsored award.

FUNDING MATTERS

Fiscal Procedures

As the PI, you can authorize expenditure of project funds within the limitations imposed by terms of the sponsored agreement and WVU Research Corporation procedures. (Note: You can delegate authority, but the delegation must be submitted in writing to the Research Corporation through the Controller's Office). Actual disbursement of project funds is made only by the Research Corporation.

Ordinarily, project funds can be expended only within the category specified in the approved budget (salaries and wages, supplies, equipment, travel, etc.). If you feel it is necessary to shift funds among categories, first contact SRA to determine if the Research Corporation can authorize the change or if it must be referred to the sponsoring agency for approval. Unauthorized transfer of funds between budget categories may result in costs being disallowed.

Restricted Funds

All WVU Research Corporation accounts are restricted funds. This means that all charges to WVU Research Corporation sponsored project accounts must be:

• Reasonable and allocable to the project
• In accordance with program plans and objectives
• Clearly required for project use
• In accordance with the budget established for the account in total, by category, and in some cases by line items
• Incurred and/or performed service within the authorized time frame of the project
• In accordance with sponsor and University regulations as well as the WVU Research Corporation procedures that implement those regulations

Any questions concerning project funds should be referred to SRA or OSP.

Overexpenditures

One of your most important responsibilities as the PI is to monitor project expenditures and commitments and to prevent them from exceeding the project budget or being used for unauthorized purposes. Even if you designate other persons as "authorized signers" for your project, you retain responsibility for ensuring that the project is conducted within the authorized budget. The Research Corporation expects the department or college to provide funds to cover overexpenditures.

Audit Requirements and Records Retention

Sponsored agreements funded with public money (federal, state and local governments and subcontracts from other entities receiving public money) are subject to full review of all project activity, both program and financial. All activities must be conducted in full accordance with sponsored agreement terms and conditions and all applicable regulations. Major requirements are in the sponsored agreement, should you have questions, contact the OSP.

The accounting, purchasing, and administrative personnel for the Research Corporation are generally familiar with sponsor restrictions and screen transactions accordingly. However, such screening, by necessity, is limited. The primary responsibility for adherence to sponsored agreement requirements belongs to the PI. The PI must certify the time spent by project personnel on the project and also ensure that purchases and travel are in accordance with the budget and are properly required for project performance. Be alert to errors that may occur, such as the wrong project being specified or leave taken and not reported. Errors can occur at initiation of charges or by processing errors later. Try to detect errors by the following month and report them to the SRA so the appropriate corrective action can be initiated immediately.

Government auditors may question the PI long after a project is completed about details of program performance and project changes. You must maintain complete and full records on your project and retain these at least three years after all project activities (final technical report, final fiscal report, and final payment) have been completed.

Fiscal Reports to Sponsors

Sponsors usually require fiscal reports on each project on a monthly, quarterly, annual and/or completion of project basis. Such reports are normally prepared and submitted to the sponsor by the SRA as part of the invoicing function. Some projects require coordination of these reports with the PI prior to submission. If you have any questions regarding fiscal reports, contact the SRA at 293-4002.

PROJECT FINANCIAL MANAGEMENT

Factors Affecting Allowability of Costs

Several factors described in OMB Circular A-21 affect whether or not costs are allowable.

Reasonable Costs. A cost is reasonable if the nature and cost of the goods or services are what a prudent person would have contracted for under the circumstances prevailing at the time. Major considerations in determining reasonable cost include:

- whether or not the cost is necessary for the operation of the sponsored agreement

- the restraints or requirements imposed by the terms and conditions of the sponsored agreement

- whether or not the individuals concerned acted with due prudence in the circumstances, considering their responsibility to the institution and the sponsored agreement

- the extent to which the actions taken in incurring the cost are consistent with established institutional policies and practices and with the sponsored agreement.

Allocation of Costs. A cost is allocable to a sponsored project if it is incurred solely to advance the work under the sponsored project.

Transfer of Costs. Any costs allocable to a particular sponsored project may not be shifted to other sponsored projects to meet deficiencies caused by overruns or other fund considerations, to avoid restrictions imposed by law or by terms of the sponsored project, or for other reasons of convenience.

Use of cost transfers is limited to correction of clerical errors. Errors involving payroll are to be corrected within 30 days of occurrence. All other errors are to be corrected within 90 days of occurrence or within 30 days of the end date of the sponsored award, whichever comes first. Corrections not made within these time frames may become the financial responsibility of the department or college.

Allowable Costs

Communications Costs. Communications costs incurred for local and long distance telephone calls, telegrams, radiograms, postage, etc., are allowable. (Local telephone service charges, equipment rental, voice mail, etc. are not allowable unless specifically provided for in the award.)

Compensation for Personal Services. Compensation for personal services will cover all amounts paid currently by the institution for services rendered during the period of performance under sponsored projects. Such amounts include salaries, wages, and fringe benefits. These costs are allowable to the extent that the total compensation to individual employees conforms to the established policies of the institution, consistently applied, and provided that the charges for work performed directly on sponsored projects as well as other allocable work as indirect costs are determined and supported as provided by government cost principles.

Salary Rates for Academic Year. Charges for work performed on sponsored projects by faculty members during the academic year will be based on the individual faculty member's regular compensation. Charges for work performed on sponsored projects during all or any portion of such a period are allowable at the base salary rate. Charges to sponsored projects, irrespective of the basis of computation, should not exceed the proportionate share of the base salary for that period.

Since intra-University consulting is assumed to be undertaken as a University obligation requiring no compensation in addition to full-time base salary, the principle also applies to faculty members who function as consultants or otherwise contribute to a sponsored project conducted by another faculty member of the same institution (see Policy on Intra-University Consulting).

However, in unusual cases where consultation is across departmental lines or involves a separate or remote operation, and the work performed by the consultant is in addition to the faculty member's regular departmental load, charges for such work representing extra compensation above the base salary are allowable, provided that such consulting arrangements are specifically provided for in the agreement or pre-approved in writing by the sponsoring agency.

Salary Rates for Periods Outside the Academic Year. Except as otherwise specified for teaching activity, charges for work performed by nine-month faculty members on sponsored projects during the summer months or other periods not included in the base salary period will be determined for each faculty member at a rate proportionate to the base salary divided by the period to which the base salary relates. The base salary period used in computing charges for work performed during the summer months will be the number of months covered by the faculty member's official academic year appointment. Charges for teaching activities performed by faculty members on sponsored projects during the summer months or other periods not included in the base salary period will be based on the normal policy of the institution governing compensation to faculty members for teaching assignments during such periods.

Equipment and Other Facilities. The costs of permanent equipment or other facilities are allowable when such purchases are approved by the sponsoring agency or provided for by the terms of the sponsored agreement.

General Purpose Equipment. General purpose equipment is generally defined as equipment that is not limited in use only to research, medical, scientific, or other technical activities. Examples of such equipment are office equipment, furnishings, heating and cooling units (including air-conditioning equipment), passenger and cargo vehicles, computing and automatic data processing devices, cameras, refrigerators, and freezers. Unless specifically provided for in the approved budget, prior approval from the sponsor is required for spending federal funds to acquire general purpose equipment.

Special Purpose Equipment. Special purpose equipment is allowable and is generally defined as equipment that may only be used for research, medical, scientific, or other technical activities. This includes such items as microscopes, X-ray machines, and surgical instruments.

Insurance and Indemnification. Costs of insurance required or approved pursuant to the research agreement, are allowable.

Maintenance and Repair Costs. Maintenance and repair costs incurred for necessary maintenance or repair of property (including government property, unless otherwise provided for) which do not add to the permanent value of the property or appreciably prolong its intended life, but keep it in efficient operating condition, are allowable.

Material Costs. Costs incurred for purchases of materials, supplies, and fabricated parts directly related to the research agreement, are allowable. Direct material costs may include only the materials and supplies actually used for the performance of the research.

Meetings and Conference Costs. Costs of meetings and conferences, when the primary purpose is the dissemination of technical information, are allowable as long as travel has been approved in the award budget. This includes costs of meals, transportation, rental of facilities, and other items incidental to such meetings or conferences based on the Research Corporation travel policies.

Transportation Costs. Transportation costs incurred for freight, express, cartage, postage and other transportation services relating to goods either purchased in process, or delivered, are allowable.

Travel Costs. Travel costs are allowable when they are directly attributable to specific work under an agreement, as long as travel has been approved in the award budget. The difference between first-class air accommodations and less-than-first-class air accommodations is unallowable except for when less-than-first-class air accommodations are not reasonably available to meet necessary mission requirements.

Foreign travel is generally defined as any travel outside of Canada and the United States and its territories and possessions. Foreign travel costs are allowable. However, if the proposed foreign travel is not specifically included in the approved budget from the sponsor, internal institutional prior approval or direct approval from the sponsor is required. Domestic travel costs are allowable. However, some federal agencies provide that expenditures may not exceed the amount budgeted for travel by more than $500.00 or 25%, whichever is greater. In instances where there is not a travel budget in the sponsored agreement, pre-approval from the sponsor may be required. Some sponsored agreements often include more stringent restrictions. Additional information on travel costs is located in the travel section of this guide.

Unallowable Costs

The examples presented here are only representative of unallowable expenditures and are not all-inclusive.

Alcoholic Beverages. Costs for such beverages generally are not allowable.

Capital Expenditures. The costs of equipment, buildings, and repairs that materially increase the value or usefulness of buildings or equipment are unallowable except when provided for in the sponsored agreement. Government funds will not be used for the acquisition of land, or any interest therein, except with the specific prior approval of the sponsoring agency.

Entertainment Costs. Costs incurred for amusement, social activities, entertainment, and any items relating thereto (such as meals, lodging, rentals, alcoholic beverages, transportation, and gratuities) are unallowable.

Pre-Agreement Costs. Costs incurred prior to the effective date of the sponsored project, whether or not they would have been allowable, are unallowable unless specifically set forth and identified in the sponsored agreement, or approved through prior approval procedures.

Memberships and Subscriptions. Costs of an individual's membership in civic business, technical, and professional organizations are normally not allowable as a direct cost unless specifically identified in the agreement or unless prior agency approval is obtained based on project need. Costs of individual subscriptions to civic, business, professional, and technical periodicals are normally not allowable as a direct cost unless specifically identified in the agreement or unless approval is obtained based on project need.

Indirect Costs

Indirect costs are those costs that can be neither accurately nor specifically identified with a particular activity within the University. Examples of indirect costs include the following:

• The Physical Plant provides utility and custodial services to all areas at WVU. The cost of such services cannot be identified accurately and specifically with a particular research project.
• The Controller's Office and Purchasing process payment vouchers, invoices, and purchase orders for all areas at WVU. The cost of providing this service cannot be identified accurately and specifically with a particular research project.
• The OSP processes award proposals for all areas at WVU. The cost of providing this service cannot be identified accurately and specifically with a particular research project.
• The library provides books, tapes, periodicals, journals, etc. to all areas at WVU. The cost of providing this service cannot be identified accurately and specifically with a particular research project.

Transferring Costs and Expenditures

Generally, cost transfers are only to be used to correct errors or to assess charges approved through the policy on Interdepartmental Services Rate Development. The following examples detail procedures for initiating and enacting specific cost transfers.

• Cost transfers for personal services must be broken down by pay cycle, effort, and title as listed in the award budget.
• Cost transfers required to adjust payroll-related expenditures must be initiated within 30 days of the end of the month in which the error occurred. The document should include a description of the error and why it occurred and should include or be preceded by a modified effort report. If an effort report is not available, a memorandum detailing the adjustment and the necessity for a change in effort is required.
• Cost transfers required to correct clerical or miscellaneous errors in the preparation of the sponsored award must be initiated within 90 days of the original transaction or within 30 days of the end date of the sponsored award. The document should include a description of the error and why it occurred.
• Cost transfers used to distribute costs must be directly allocable to the award as defined by the Policy on Direct Costs on Grants and Contracts or supported by a detailed rate schedule consistent with the policy on Interdepartmental Services Rate Development.
• Cost transfers charging sponsored agreements cannot be made after 30 days past the expiration date of the award or contract regardless of the allowability of the charges. The department or college is financially responsible for these charges.
• Cost transfers occurring within the last 30 days of a award contract require a detailed justification of the necessity for the transfer.

In circumstances of over or noncompliant expenditures, if the appropriate correction is not effected within the 30-day period after the expiration date of the award, the SRA will make the transfers using department or college funds.

• When an overexpenditure occurs, sufficient funds to correct the condition will be transferred to the cost sharing account, a departmental operating account, dean's overhead account, or an account established specifically for that purpose.
• If expenditures are noncompliant, the charges will be moved to dean's overhead account, a departmental operating account, or an account established specifically for that purpose.

Standard Monthly Financial Reports

The Controller's Office provides a set of monthly departmental reports to each school/college/center once every month. Such reports provide information on grants that have previously been or are currently active. Reports of particular interest to PIs are:

WCM1010: Displays detailed expense budget (objects and organizations), appropriation (budgetary control), encumbrance, and expenditure transactions for the month. This report lists each expenditure transaction that occurred on your account during the preceding month.

WCM1020: Displays detailed revenue and revenue budget transactions. This report lists each revenue transaction (bills and payments) that occurred on your account during the preceding month.

WCM1040: Displays a summary of expenditure and budget activity by unit of appropriation (budgetary control). This report summarizes expenditure activity at the object level for your account.

More detailed information about these reports is available in the Controller's Office Procedures Manual. Contact your dean or business office for copies of this manual.

CUFS QUERY (Department Access)

Authorized individuals have access to an on-line QUERY System, which provides current information on all University accounts. A set of screens provides information on account structures, available codes, detailed transactions and summary information by organization and fund. Of particular interest to PIs are the following screens:

Option 10: Award Information, displays demographic information about each award.

Option 15: Ledger Transaction Detail, displays detailed expense, encumbrance or revenue by FAO, object code, and revenue source.

Option 16: Budget Summary/expense Review, displays summary expense and budget information by FAO at either summary or object code level.

More detailed information about these screens is available in the Controller's Office Procedures Manual. If you do not have access to CUFS QUERY, contact Computing Services for a WVU Administrative QUERY System Access Request form. In general, you as the PI will require view access to the sponsored award fund plus all cost sharing fund area organizations (FAO).

Program Income

Program income is defined as the gross income earned by a recipient from activities of which part or all of the cost is borne either as a direct cost by an award or counted as a direct cost toward meeting a cost sharing requirement of an award. Examples of program income include fees for services, usage and rental fees; proceeds from sale of tangible personal property; patent or copyright royalties; and license fees. Some sponsoring agencies allow grantees to exempt royalty income from treatment as program income.

According to WVU and the WVU Research Corporation policy, sponsored projects funded by awards and receiving program income during the project period must account for such income in a manner that will permit its identification and treatment consistent with the requirements of the federal sponsor. Program income from projects supported by federal awards will be accounted for in accordance with federal awarding agency regulations or the terms and conditions of the award. Proposals for projects must indicate whether or not program income is anticipated during the project period. Additionally, when you anticipate receiving program related income for funded projects must so indicate when the FAO (account) is established. If you will be collecting program income, contact SRA for direction on establishing accounts and collecting fees.

There are three alternatives for handling program income: deductive, matching, or additive. The method applicable for a given award will be the method prescribed by the sponsor's policy or the terms of the award. In any circumstance, the terms of the award will govern in case of conflict. However, if specific guidance is not provided by the award terms, the following will apply:

- For a research agreement, the additive alternative will apply.

- For a non-research agreement, the deductive alternative will apply.

If the use of program income is specified as either being added or used as matching, the agency may specify limits on such use. Any program income over that limit is deducted from the total award allowable cost. The recipients have no obligation to the federal government regarding any program income earned after the end of the award period, unless as otherwise provided in federal awarding agency regulations or the terms and conditions of the award.

Unrelated Business Income Tax (UBIT)

Unrelated Business Income Tax (UBIT) represents the federal tax WVU and WVURC is required to pay on any income generated from activity unrelated to their core missions. This tax is intended to eliminate unfair competition with businesses outside the University. There are two primary conditions under which UBIT exists. The conditions are:

Trade or Business. An activity conducted for the production of income from either the sale of goods or the performance of services not related to the primary missions of the University (i.e., instruction, research, and public service).

Unrelated. Two conditions exist for an activity to be considered unrelated. First, the activity must be "regularly carried on" and the activity should be conducted with sufficient consistency, even if the activity is infrequent or seasonal. Second, the activity must not be "substantially related" to the exempt purpose of the University.

• The activity is tax exempt if the following conditions exist:
• the work is performed without compensation (volunteers)
• the merchandise for sale is a by-product of educational, research, or public service activities
• the merchandise for sale has been donated to the University
• the activity is operated for the convenience of students, faculty, and staff

Research activities normally carried on incidental to commercial or industrial operations are taxable (examples include testing or inspecting materials or products, designing or construction equipment or buildings, etc.). Research activities are considered taxable if the results do not provide a public benefit (i.e., aids in the scientific education of a student; aids a community by encouraging industrial development in the area; aids in discovering disease cures; or the results are made public information). Public benefit is often measured by the timely, unrestricted publication of research results.

In general, UBIT is levied only on project income from private sponsors in which revenues of the project are not related or are only loosely related to the expenditures.

PROJECT SUPPORT

WVNET

WVNET, the West Virginia Network for Educational Telecomputing, exists to provide and facilitate state of the art information technology and networking in support of higher education in West Virginia. WVNET provides central computing facilities that link the campus computing systems at most of the colleges and universities throughout the state. Additionally, WVNET acts as purchasing agent for the State College and University Systems to obtain bulk pricing discounts and provides expert purchasing services regarding computer maintenance and equipment purchases.

WVNET accounts are established through Computing Services. Accounts to be charged to an award must be coded sponsored research. Accounts used as cost sharing must be established as departmental research. WVNET accounts classified as sponsored research must expire on the end date of the sponsored award.

Environmental Health and Safety

The Office of Environmental Health and Safety existsto protect WVU resources and also to provide the University community with a safe and healthful place in which to work, learn, or visit. The department provides health and safety services in the areas of air quality, medical monitoring, facility code compliance, injury or illness prevention, environmental health, hazardous materials, safety training, and asbestos management. To assure compliance with federal, state, and local health and safety agencies, researchers should contact the Environmental Health and Safety Office prior to award application.

Facilities Management

Facilities Planning and Management is responsible for keeping track and overseeing all space-related issues that may arise during the extent of a sponsored award. For instance, if you need additional space in order to house new staff or equipment as related to the requirements of your award, you (with dean's approval) will need to contact Facilities Planning and Management. With the assistance of the Physical Plant, Facilities Planning and Management will ensure your needs are met.

Additionally, all leasing agreements related to an award are established and activated through Facilities Planning and Management. It is your responsibility to notify Facilities Planning and Management of any changes relating to the use of space. Examples include the location of the staff members appointed to the sponsored award requiring the space as well as the end of the award signifying the use of the space is no longer necessary. Notification of changes is necessary so that Facilities Planning and Management can accurately record the utilization of such space and can be accomplished by calling 293-7309.

Campus Mail Facilities

The WVU Postal Service provides mail service to all faculty and staff of WVU. WVU postal employees pick up and deliver all incoming, inter-campus, and outgoing U.S. and international mail at one central location in each of 60 buildings on the Downtown and Evansdale campuses and the Health Sciences Center.

When managing a sponsored award, it is your responsibility to establish a postage number for exclusive use of your sponsored award through Mail and Transportation Services. All postage numbers should expire on the end date of the sponsored award. Any questions or concerns about campus mail facilities can be directed to the mail service staff by calling 293-4050 or 293-2359.

Long Distance Telephone Calls

In most instances when a Research Corporation account number is assigned to a project, the telecommunications staff will assign a six-digit T.I.D. number specifically for that project. TID numbers are necessary for placing long distance phone calls and FAX. Project-related long distance calls should be charged to an award's TID. All project-related TID numbers must be canceled on the end date of the sponsored award.

The PI is responsible for maintaining proper security of the assigned telephone code to prevent its unauthorized use. Do not divulge the code to anyone not authorized to place long-distance telephone calls pertaining to your project. Use of the code implies certification that the call is required for and properly chargeable to the project. The telephone code should only be used for project business.

In instances where long-distance calls are charged to department accounts in error or for occasional convenience purposes, you will need to transfer the charges to the Research Corporation. To do this, use the WVU intra-University cost transfer form. It is your responsibility to be sure all TID numbers are canceled at the project closeout phase.

INTRA-UNIVERSITY CONSULTING

Intra-University Consulting

WVU and the Research Corporation encourage consulting among faculty. Intra-University consultants do not routinely qualify for additional compensation for these efforts. Payment for consulting from sponsored awards is guided by OMB Circular A-21:

"Since intra-university consulting is assumed to be undertaken as a university obligation requiring no compensation in addition to full-time base salary, the principal also applies to faculty members who function as consultants or otherwise contribute to a sponsored agreement conducted by another faculty member of the same institution."

Exceptions guided by OMB Circular A-21, are outlined below:

"However, in unusual cases where consultation is across departmental lines or involves a separate or remote operation, and the work performed by the consultant is in addition to his regular departmental load, any charges for such consulting arrangements are specifically provided for in the agreement or approved in writing by the sponsoring agency."

Intra-University consulting is defined as that which occurs between two separate and distinct departments within WVU. A department is defined as a distinct group involved in a recognized discipline and headed by a chair or director. For the purposes of this policy, research centers which are functioning units within a college or school are not separate and distinct departments.

Paid intra-University consulting is allowable in those instances where the faculty member's participation in a project is nominal, i.e., less than five (5) percent effort. Additionally, a compensated intra-University consulting activity must be in addition to the faculty member's regular departmental duties and must take place across departmental or similar unit as defined by CUFS Area code.

For involvement in a sponsored project which anticipates more than a nominal commitment of time, faculty effort should be included as a named position in the project budget with compensation requested commensurate with the proposed level of effort.

No compensation in addition to full-time base salary is allowed. However, a portion of the employee's full-time base salary may be charged to the department receiving the consulting services. In such cases, the employee's home department and the department receiving consulting should execute a memorandum of agreement detailing the service expected, amount of base salary to be charged, and the expected length of service.

Exceptions - In unusual cases, exceptions may be granted, allowing the consultant to receive additional compensation for his or her efforts. In order to be considered for an exception, the following factors must be met:

• The consulting must be across colleges or schools or in a remote location.
• The consulting must be in addition to the faculty member's usual workload as certified by the consultant's dean or director.
• The consultant must be receiving no portion of his or her base salary from the college, school, or center for which he or she is consulting.
• The consultant must be a tenure track or nontenure-track faculty member at the instructor level or above.
• Intra-University consulting charged to sponsored agreements must be specifically identified as such and provided for in the agreement or approved in writing by the sponsoring agency prior to any actual activity.

Exceptions must be preapproved in writing by the Vice President for Administration and Finance, the Vice President for Academic Affairs, and, if appropriate, the Vice President for Health Sciences.

Agreements with Sponsoring Agencies

Agreements must specify that work will be performed by an employee of the institution and all associated fringes and overhead will apply. Additional expenditures related to the consulting work such as general office supplies and travel need not be specified in the agreement, however, these expenditures must be charged (at cost) to the sponsored agreement or other funds within the department receiving the consulting and cannot be included in the consulting rate. Funds allocated by the sponsor for Intra-University consulting will be budgeted in a distinct accounting code. Applicable fringes and overhead will apply.

Procurement for Consulting Services

When additional compensation for Intra-University consulting will occur, all institutional policies concerning procurement are applicable.

Payment Options

Compensation may be in the form of a specifically identifiable payment to the faculty member's department. Funds earned in this manner are institutional resources and are dedicated to the support of the faculty member's department.

OR

Compensation is processed through the University's hourly payroll system (using the object for Intra-University Consulting) semi-monthly during the consulting period or in a lump sum within 30 days of the end of the consulting service or prior to the ending date of the sponsored award, whichever comes first.

The option shall be determined and reflected on the intra-University consulting form as provided in the Controller's Office Policies and Procedures Manual.

Rates for Interdepartmental Consulting

Intra-University consulting payments, as provided by the sponsor in the approved project budget, shall be at a rate, including the current fringe benefit rate, which shall not exceed the then current rate for Executive Level IV Federal employee compensation. The daily equivalent rate for an Executive Level IV employee is established and published by the Federal Government at least annually and is available from the Office of Sponsored Programs.

Processing and Approvals

Payment for Intra-University consulting to the faculty member is processed through the institution's hourly payroll system. Payment to the faculty member's department is processed through Accounts Payable. No advance payment will be permitted. Interdepartmental consulting payments must be made semi-monthly during the service period or in a lump sum within 30 days of the end of the service period using a payroll form specifically for that purpose. The form requires certification that the consulting is in addition to the individual's departmental workload.

Intra-University consulting for additional compensation is excluded from the effort reporting system. Under OMB Circular A-21, Section jf-8-a;

"Incidental work (that in excess of normal for the individual), for which supplemental compensation is paid by an institution under institutional policy, need not be included in the payroll distribution systems described below, provided such work and compensation are separately identified and documented in the financial management system of the institution."

The following approvals are necessary for an Intra-University consulting agreement when additional compensation is to be provided:

• The individual performing the consulting
• The PI of a sponsored award
• The dean or director of the department providing the consultant, confirming that consulting efforts are in addition to a normal departmental workload
• The Controller's Office, if a sponsored agreement funding is being used
• Office of Sponsored Programs

  Forms and procedures are available from the Controller's Payroll Accounting Office.

SUBCONTRACTING

Subcontracting

Subcontracting a portion of the effort under a sponsored agreement, whether it be an award, contract or cooperative agreement, is subject to explicit and inalterable procedures by federal regulation and Research Corporation policy. It is incumbent on you to anticipate as early as possible the need to enter into a subcontract.

For subcontracts that are described in the proposal (detailed in the technical and budget sections of the proposal), and approved by the sponsor in the award document, the OSP will prepare the appropriate document. To begin this process, you must contact the OSP to ensure that adequate budgetary and scope of work information is available to create an appropriate agreement.

Davis-Bacon

The Davis-Bacon Act applies to federally funded awards and implies that all construction contracts awarded in an amount of more than $2,000 will include a provision for compliance with the Department of Labor regulations. Under the Davis-Bacon Act, contractors are required to pay wages to laborers and mechanics at a rate not less than the minimum wages specified in a wage determination made by the Secretary of Labor. Contractors are also required to pay wages not less than once a week. The contract award will be conditioned upon the acceptance of the wage determination. It is your responsibility to report all suspected or reported violations to the federal awarding agency.

Non-University Consultants

The use of consultants on a sponsored agreement must be explicitily approved by the sponsor. Additionally, the procurement of consultants is subject to the processes described in the Purchasing Section of this handbook.

UHA Funded Projects

For projects which utilize employees of University Health Associates (UHA), an agreement is required between the Research Corporation and UHA. This is a one-page form available from the office of the Associate Vice President for Finance, Health Sciences. Standard purchasing procedures govern processing this agreement.

PURCHASING

Competitive Bidding

There are four types of competitive bidding processes that must be followed to purchase goods and services through the Research Corporation:

• Competitive Purchases greater than $25,000 - Formal Requests for Bids
• Competitive Purchases Between $1,000 and $25,000 - Formal or Informal Requests for Quotations
• Purchases Less than $1,000 - Small Purchases
• Competitive Sealed Proposals

Competitive purchases greater than $25,000: Bids are solicited through the issuance of "formal" Requests for Bid. Competitive purchases designated as formal must be publicized at least ten days prior to the bid opening. Suppliers can only bid through the sealed bid process and bids must be submitted to the WVU Purchasing Office prior to the specified bid opening date and time.

Competitive purchases between $1,000 and $25,000: For competitive purchases estimated to cost between $1,000 and $25,000 purchasing solicits request for quotations from no less than three suppliers, whenever possible. Depending on the complexity of the commodity or service, time constraints, and other applicable factors, solicitations may be formal Requests for Quotations (using the process cited above) or "informal". "Informal" Requests for Quotations may be submitted by phone, fax, or in writing. It should be recognized that an important element in determining the method of procurement, be it formal or informal, is the purchasing agent's discretion.

Purchases less than $1,000: Purchases, products, or services estimated to cost less than $1,000 are generally not bid transactions. Decentralized purchasing authority is available to departments for the procurement of commodities not to exceed $1,000.

While competition is encouraged, purchases in this category do not require competitive bids or quotations. The WVU Research Corporation Departmental Purchase Order (DPO) is the proper document for making such purchases. Specifically excluded are professional and consultant services, controlled substances, radio nuclides, and live animals. DPO authority may be suspended by Purchasing should the DPO be used in a manner to circumvent or abuse the competitive process required for larger dollar purchases. Your budget officer's signature is required on the DPO. It is your responsibility to confirm that appropriate funding is available prior to using the Research Corporation DPO.

It is necessary for you to realize that the use of any DPO is to be avoided in the last 30 days of a sponsored award. In all cases, receipt of goods or services must occur on or prior to the end date of an award. Invoice processing must occur within 30 days of the award end date. Otherwise, the department or college may retain financial responsibility for the purchase.

Competitive Sealed Proposals: The request for proposal (RFP) method of purchasing is used to obtain goods and services when sufficient knowledge or expertise does not exist or adequately specify the details of the desired result. The desired result is written in the RFP. The supplier should respond with a proposal identifying his or her intended approach to meet the desired result along with a proposed price or fee. RFPs go beyond price, however. They also look at the supplier's ability and resources available to provide the services necessary to obtain the desired result. Quality of service and performance are important considerations. An important difference between RFPs and competitive sealed bidding is the finality of initial offers. Under RFPs, alterations in the nature of the proposal and prices may be made after proposals are opened. RFPs are primarily used for large dollar projects requiring a high level of expertise on the part of the supplier.

Reimbursements for Out-of-Pocket Expenses

Should out-of-pocket expenses be necessary, reimbursement will be made under the essential services policy. The following must be obtained and provided to the appropriate budget officer for reimbursement under this policy:

• Budget officer approval that the expense can be reimbursed
• An original vendor's invoice (proof that the employee is now the vendor)
• A photocopy of the itemized invoice that was paid on behalf of the WVU Research Corporation
• Proof of payment

NOTE: An out-of-pocket purchase exceeding $400 must have the approval of WVU Purchasing prior to reimbursement. Once all of the above is completed, forward to the appropriate budget officer for final processing.

Small and Disadvantaged Businesses

There may be stipulations in federally funded awards that reference goals as to dollars to be expended to small, small disadvantaged, or small woman-owned businesses in the acquisition of commodities or services. You should be cognizant of any small business plan accompanying a federal award and the percentage of dollars from the award to be expended toward meeting those goals.

In addition, WVU provides, to the maximum practical extent, opportunities for state resident suppliers to conduct business with WVU. A database of small disadvantaged businesses that are registered to do business with WVU is maintained by WVU Purchasing. The database is available upon request by contacting the Purchasing Office at 293-5711.

Single or Sole-Source Procurement

In some situations, the good or service needed may be obtained only through a single- or sole-source procurement. A request for single- or sole-source procurement must be submitted to Purchasing for approval prior to purchase of the goods or services. The request must be signed by you as the PI and include the following information:

• A department name and contact person.
• Some form of cost and price analysis. This can be accomplished in a number of ways, for example, comparison of market prices or similar indicia.
• Specific justification why competition is not possible or appropriate.
• Basis for contractor selection.
• Basis for award cost or price.

Special Provisions for Acquisition

A file of those suppliers eligible to do business with the Research Corporation is maintained through Purchasing. Specific supplier information must be provided for the file before payment can be made to the supplier. Additionally, supplier information is needed for the purposes of tracking expenditures to small, small disadvantaged, and woman-owned businesses.

External Purchases/Subcontracting

It is important that you be knowledgeable as to the permissibility of subcontracting. If allowed, then it should be noted as to whether subcontracting must be competitively bid or if the funding agency has approved a pre-selected subcontractor. You are responsible for providing Purchasing with documentation of the approval for the pre-selection. If competitive bidding is required, be sure to allow the lead time necessary for competitive bidding.

Professional Services

Professional services applies to the procurement of the services of accountants, architects, engineers, land surveyors, clergy, physicians, lawyers, or others as applicable. Except as authorized under Sole- or Single-Source Procurement or Emergency Procurement, competitive selections procedures shall be used for all procurement of professional services listed above or in excess of $25,000. Notice of the need for such services shall be made by the Chief Procurement Officer in the form of a RFP at least ten days prior to the proposal due date. Adequate public notice shall be given as provided herein. Procurement of services costing greater than $1,000 but not exceeding $25,000 may be procured by securing three competitive, written, faxed, or verbal proposals as per the purchasing agent's discretion.

Split Funding

Split funding is defined as the mixing of state and federal dollars for purchases. Should acquisitions involve both federal and state funds for a single purchase, state regulations must apply.

Equipment Purchases

Equipment having a useful life of two years or more and an individual unit acquisition cost (including invoice amount, transportation, installation, and insurance charges) of $1,000 or greater will be tagged for the Research Corporation by Inventory Management. Required information regarding the equipment will be maintained by Inventory Management for the purposes of tracking the equipment from acquisition to disposition. The title (ownership) of fixed assets is determined by various regulations, sponsored agreement provisions, federal law, etc. You must be aware of these restrictions and may not assume ownership solely on the basis of equipment purchases from your sponsored agreement funds.

The Office of Naval Research is WVU's cognizant auditing agency regarding equipment. In order for WVU to remain in compliance with federal regulations and eligible to continue to receive federal funding, specific reporting requirements must be met. You must also be aware of these reporting requirements and assist where necessary.

Requisitions for equipment purchases above certain thresholds with federal dollars require Inventory Management to perform a pre-acquisition process to determine if similar or like equipment is already purchased, on campus, and can be shared. Additional time must be allowed for the pre-acquisition process to occur when requesting equipment purchases subject to such review.

TRAVEL

The WVU Research Corporation's travel policy is intended to facilitate travel and travel arrangements, to provide full reimbursement for all necessary expenses, and to protect travelers against the risk of loss while maintaining the necessary controls for accountability.

This policy applies to all faculty, staff, and students who intend to request reimbursement. The travel policy is designed to establish signature authority and responsibilities, provide cost containment initiatives, and effect timely payment and reimbursement of expenses.

This policy applies to all travel under a sponsored agreement unless superseded by federal regulations or specific guidelines of a particular award. Travel expenses on state-funded sponsored agreements administered through the WVU Research Corporation must adhere to state travel guidelines unless specifically stated otherwise in the award document.

This policy also applies to the reimbursement of travel expenses for non-employees (i.e., consultants, lecturers, etc.). When travel is the only expense being reimbursed, a consulting agreement is not required.

Air Transportation (Documentation required)

Commercial Airlines: Travelers are expected to make advance bookings, using the least expensive logical fare via the most direct route (or other reasonable route that results in a lower fare). Travelers may not specify particular airlines in order to accumulate mileage under promotional plans such as frequent flyer programs.

Chartered Aircraft: The funding source must approve in advance the use of chartered aircraft. Approval must accompany the expense account for payment or reimbursement to be made.

Rail Transportation (Documentation required)

Travelers should make advance bookings, using the least expensive fare via the most direct route (or other reasonable route that results in a lower fare).

Ground Transportation (Documentation required)

Air vs. Automobile: If a traveler chooses to drive rather than fly while on Research Corporation business, reimbursement will be based on actual in-transit expenses (mileage, hotels, meals, etc.) not to exceed the lowest available commercial air fare plus local transportation to and from the airport.

State Owned Vehicles: State owned vehicles may be requested from the WVU Motor Pool. Availability is limited and should be requested in advance. The operator of all vehicles must possess a valid driver's license. Additionally, the operator is personally responsible for any fines or penalties resulting from citations, charges, or warrants. Fines or penalties are not reimbursable expenses.

Privately Owned Vehicles: Privately owned vehicles may be used when traveling on WVU Research Corporation business. Reimbursement will be made (excluding commuting mileage) at the per mile rate established by the Internal Revenue Service. This rate is intended to cover all operating costs of the vehicle (including gas, maintenance, depreciation, insurance, etc.), and no additional reimbursements will be made. See the Research Corporation Business Use of Personal Vehicles Policy for further information.

Commercial Rental Vehicles: Reimbursement for commercial rental vehicles will include the rental fee for an appropriate size vehicle, mileage fee, and gasoline costs. Travelers are requested to fill the gasoline tanks prior to returning the vehicle. See Rental Vehicle Policy- Additional Insurance/Waiver Options for further discussion.

Miscellaneous Ground Transportation: Reimbursable expenses (at actual amounts incurred) include, but are not limited to, garage and parking fees, tolls and charges (including baggage handling costs), limousines, taxis, and public transportation for service to airports, hotels, meeting places, and appointments. Travelers are encouraged to use courtesy transportation if provided by a hotel, event sponsor, or other facility. Receipts are required only if individual expenses exceed $50.

Lodging Expenses (Documentation required)

Hotel expense reimbursement is made for standard rooms at the least expensive single rate available. All taxes and occupancy charges are included. In cases of double occupancy by two Research Corporation travelers, lodging costs may be claimed fully by one traveler with no claim being made by the other or each may be reimbursed 50% of the total room charge on their respective expense account. In case of double occupancy, where one of the occupants is not on Research Corporation business, hotel reimbursement will be based on the least expensive available single rate.

Meal Allowances

Reimbursement for meals is limited to the Authorized Daily Rate (ADR) issued by the General Services Administration for the destination city (the location where business is conducted). Specifically excluded from reimbursements are alcoholic beverages and entertainment expenses. Where a percentage of the ADR is used, round the calculated amount up to the next whole dollar. ADRs are available from Payroll and Travel Accounting.

Meal expense reimbursement for days of departure and return should be the appropriate percentage up to the allowable 100% of the ADR per the chart below.

	Day of Departure			Day of Return

Prior to 7:00 a.m. - 100% Prior to Noon - 20%

Prior to Noon - 80% Prior to 7:00 p.m. - 40%

Prior to 7:00 p.m. - 60%

After 7:00 p.m. - 0% After 7:00 p.m. - 100%

When meals are provided for a traveler, the traveler's ADR will be reduced by an appropriate amount. For the purpose of determining the amount of deductions for meals on a uniform basis, allowances for meal expenses will be deducted as follows:

			Meal Provided		Amount of Deduction

			Breakfast			20% of ADR

Lunch 20% of ADR

Dinner 60% of ADR

Meal expense compensation for single day travel (when there is no overnight stay) is allowed when travel is completed three or more hours after the end of the normal work day. Reimbursement of meal expenses will be made at 60% of the ADR. Per IRS regulations, this is a taxable item and will be included in the employee's taxable wages if the employee chooses to seek reimbursement.

Registration Fees (Documentation required)

Registration fees at conferences may be direct billed. If required, advance payment is permitted and should be requested through the travel accounting office. The traveler will not receive any allowance for lodging or food that has been included in registration fees.

International Travel

The WVU Research Corporation recognizes the unique needs of travel outside the United States. Because it is not possible to anticipate the complexities involved in international travel, the Research Corporation will make accommodations for the inconveniences of such travel (i.e., using a specific travel agency or credit card, specifying the use or non-use of particular airlines, inability to arrange travel details in advance, payment of laundry fees, issuing cash advances, etc.). Federal sponsors frequently place restrictions on international travel and require the use of U.S. flag carriers. PIs are responsible for ensuring compliance with this requirement.

Payment of Travel Expenses

Direct Billing - Travelers may direct bill for appropriate travel expenses (i.e., airfare and registration fees). The department is responsible for submitting the appropriate support documents to the Research Corporation for payment. Payment will be processed directly to the vendor, in advance if necessary. Travelers do not have to obtain specific approval to direct bill.

Cash Advances - Cash advances for expenses that cannot be direct billed are generally not available through the WVU Research Corporation.

International or Extended Travel. The WVU Research Corporation provides cash advances to travelers when, because of the unique nature or extensive length of international travel, the majority of expenses cannot be paid by direct bill or credit card. These advances will normally be for international travel to remote locations. Advances are limited to 80% of the estimated travel expenses that cannot be direct billed or paid by credit card. Reconciliation of such advances is required within three business days after the traveler returns.

Requests for advances (signed by the traveler and approved by the PI) should be forwarded to the executive director 15 business days prior to departure. Failure to settle advances in a timely manner may result in collection procedures and in the advance amount being reported as gross income per IRS regulations.

Travel Arrangements

Extended Travel. A traveler may elect to achieve a lower overall trip cost through the use of restricted discounted airfares by extending the trip to cover specific travel days at the beginning or end of a trip (i.e., staying over Saturday to obtain a Super Saver fare). The traveler will be reimbursed travel expenses for this extension when such "extra" expenses (lodging, meals, other transportation costs, etc.) do not exceed the amount of savings realized from the discounted airfare.

Personal/Business Travel. When personal travel is combined with business travel, the traveler will be reimbursed for the lowest available fare for only the business portion of the trip. The traveler must maintain careful records to separate the nonbusiness from the business expenses. Any additional costs incurred due to stopovers or route modifications made for the convenience of the traveler will be borne entirely by the traveler.

Cancellation or Modification (Documentation required). Costs associated with the cancellation or modification of travel arrangements are reimbursable expenses only when incurred to obtain a lower overall trip cost or as the result of an event outside the control of the traveler (i.e., meeting was canceled or changed, airline bankruptcy, etc.). Costs incurred for cancellation and modification of travel arrangements made for the convenience of the traveler are not reimbursable.

For further information on the WVU Research Corporation Travel Policy, contact the Travel Accounting Office at 293-2461.

PROJECT CLOSEOUT

Closing project accounts is a vital part of the overall research process. Therefore, you must work closely with the OSP, the SRA, and your departmental office personnel to ensure that all phases of the closeout process are completed in a timely manner. As with any major endeavor, your project account cannot be closed until all closeout activities required by the sponsor, WVU Research Corporation, and the University are completed. This often over-looked aspect of project management requires your input and personal attention.

Federal agency and other external auditors frequently focus on the closeout procedures. The effectiveness of the closeout process has an impact on external perceptions of the institution's ability to administer sponsored awards. Future awards to you and other PIs may depend on whether or not federal and sponsor closeout requirements have been met properly.

No-Cost Extensions

Approximately 90 days before the end date of the award, you must determine if the sponsored activity will be completed on schedule. If all associated sponsored activities cannot be completed by the end date of the award, it is vital to immediately contact the OSP to determine the method to obtain a no cost extension.

Technical Reports

The end product of almost every sponsored project is the final technical report. In addition, during the course of many projects, the sponsor requires certain periodic reports either monthly, quarterly, annually, progress, scientific, interim, or other. Timely submission of the required reports is expected by sponsors and is your responsibility as the PI. Some sponsors have general requirements for the submission of reports; others are very specific as to format, typography, figures, spacing, etc. Check your award documentation for specific requirements or contact the OSP for additional information.

For reports distributed directly by project personnel, a copy of the transmittal letter should be sent to the OSP to be kept on file for possible sponsor audit.

Other Non-Financial Closeout Documents

Various other non-financial closeout documents may be required at the closeout of the project period. Such documents may include, but are not limited to, property reports, intellectual property reports, and patent reports. Filing of such non-financial closeout documents is coordinated through the OSP. In many cases, final payment is withheld until all close-out documents are submitted. Therefore, it is imperative for the PI to work closely with OSP throughout the close-out process.

Financial Closeout Activities

Federal regulations require the final financial report and final request for reimbursements by filed 90 days after the end date of the award. In order to facilitate the timely filing of these reports, all financial activity must be completed within 30 days of the end date of the sponsored award. You and your departmental support staff are responsible for ensuring that all financial activity is completed in this time period. Any financial activity not completed in this time period may become the financial responsibility of the department even if the expenditure would otherwise have been allowable on the sponsored award. All obligations of the sponsored award must be recorded in the institutional accounting system prior to the end date of the award. The additional days after the end date are intended for the department to review expenditures on the award and make corrections as necessary.

A frequently misunderstood issue arises regarding the use of encumbrances and departmental purchase orders (DPOs). Federal regulation requires all expenditures to be directly allocable to the project. Therefore, receipt of merchandise or the completion of the service must occur on or prior to the end date of the sponsored award. Items encumbered prior to the end date but not received are not allocable expenditures to the project. You and your office staff are strongly encouraged to limit purchases and particularly the use of DPOs and procurement card purchases during the last month of the award.

You will find at appendix three, a complete checklist and time line of all actions which must be completed no later than 30 days following the end date of your award. It is your responsibility as the PI to ensure these actions have occurred.

The SRA is responsible for filing the final request for reimbursement and the final financial reports. This office is available to answer questions regarding any aspect of the financial closeout of sponsored projects.

Records Retention

All financial records and technical information must be retained for three years after the filing of the final reports. This time period may be extended if an audit is initiated by the agency.

REGULATED ACTIVITIES

Human Subject Program Guidelines

Programs involving human subjects require review and approval in accordance with University policies and guidelines. PIs seeking support from agencies outside the University should submit protocols to the Institutional Review Board for the Protection of Human Subjects (IRB) prior to submitting the proposal to an agency. Project initiation will not be authorized until IRB approval has been given.

Some human subjects are remunerated because of the nature of their service to projects. Since the method of payment to subjects requires special arrangements, PIs who wish to pay subjects are asked to contact the manager of Payroll and Travel Accounting to discuss such arrangements.

Copies of the IRB guidelines are available in departmental and college offices. Individual copies may be obtained by contacting the IRB staff in OSP at 293-7073.

Use of Animals in Research

Sponsored activities involving living vertebrate animals require review and approval by the University's Institutional Animal Care and Use Committee (IACUC). PIs should submit animal protocols to IACUC prior to submitting a proposal to an agency. Project initiation will not be authorized until IACUC approval has been given.

Copies of the University's policy statement and guidelines for use of animals in research are available in departmental and college offices. Individual copies of the guidelines and informationon submission of protocols to the IACUC are available from the IACUC staff at 293-7073.

Biohazards

The Institutional Biohazard Committee (IBC) must review and approve all projects involving the use of recombinant DNA, infectious agents of plants, animals, and humans; serum and/or tissues from humans or subhuman primates. This review and approval should normally be completed before the submission of a proposal, but in all cases approval must be given before beginning work involving the covered materials.

Copies of the Biohazards policy and protocol forms are available in the libraries and in departmental and college offices. Individual copies and information on submission of protocols to the IBC may be obtained from the OSP at 293-7398.

Radiation Safety

Projects involving the use of radioactive material must be reviewed and approved by the Radiological Safety Committee before any materials can be ordered and work begun. University policy also requires training for personnel, which must be completed before a project utilizing radioactive material can start.

For additional information on protocols and related requirements, contact the Radiation Safety Office at 293-3413.

Conflict of Interest

Research Corporation and University policies on conflict of interest have been revised to conform to federal regulations; these policies are effective October 1, 1995. Additionally, policies articulated in the Board of Trustees Policy Bulletin 43 governs all University faculty, staff, and students. Copies of the policy bulletin are available in your college office or from the OSP.

The University's Conflict of Commitment policy is being developed and will be promulgated with the conflict of interest policy early in the fall. For additional information, contact the OSP at extension 293-3998.

Scientific Misconduct

The WVU and Research Corporation policy entitled "Policy and Procedures for Review of Alleged Misconduct in Research and/or Scholarship" provides for compliance with federal provisions found in Code 42 of Federal Regulations Part 50.

The concept of "integrity in research and scholarship" embraces a wide range of issues and practices, although it is concerned primarily with markedly irregular practices in research and other scholarly activities, commonly known as "scholarly misconduct." Specific definitions are found in the policy but may be summarized as fabrication, falsification, plagiarism, and other actions which seriously deviate from accepted standards; material failure to comply with federal, state or other requirements associated with the conduct of research or scientific research. The policy is available in your dean's office or from the OSP by calling 293-7398.

DRUG STUDIES, CLINICAL TRIALS, AND OTHER FIXED PRICE AWARDS

Administration

Drug studies, clinical trials, and other fixed price awards are differentiated from other sponsored awards in that the reimbursement to the institution is not directly related to the costs incurred to perform the agreed upon tasks. All such awards are processed through OSP and receive the appropriate endorsements of the institution prior to work beginning. It is important the sponsored award agreement contain specific start and end dates for the award, a total award amount, and the method of invoicing. Invoicing is typically done on a flat fee basis for the entire award or on a flat fee basis for each individual patient trial.

The administration of these awards is similar to any other sponsored award. A designated account is established to accumulate the associated tasks. It is your responsibility as the PI to ensure that all associated costs, including a portion of your contractual salary, are identified and recorded.

As reimbursement is not related to costs incurred, the potential exists for costs to exceed reimbursement or for reimbursement to exceed costs. Careful budgeting in the proposal should prevent costs from exceeding reimbursement. However, if this occurs, the department will be responsible for any cost overrun. It is important that the award agreement discuss the disposition of cash residuals. Typically agreements state that upon completion of the agreement, any cash residuals may be used at your discretion. Such residuals are the property of the institution and are distributed and used according to institutional policy.

Positive Cash Residuals

Drug studies, clinical trials, and fixed price awards frequently have additional cash at the end of the project period. Such cash will be disposed of according to the award document and institutional policy. Such residual cash may not be spent from the sponsored award account for purposes unrelated to the award tasks. The end date of the sponsored award may not be extended for the purposes of expending residual cash.

Institutional policy allows the cash residual to be transferred to a WVU Foundation account or to a WVU departmental account. The SRA will perform the transfer upon receipt of a transfer request from the PI and approved by the chairperson and dean or director. A form letter for the transfer appears in appendix 4 of this guide.

Unrelated Business Income Tax (UBIT)

All drug studies, clinical trials, and fixed price awards will be examined to determine the applicability of UBIT. The estimated liability for UBIT will be deducted from the award prior to the transfer of residual cash to departmental accounts. The responsibility for any additional liability to the Internal Revenue Service rests with the department.

Drug Studies and Clinical Trials

Drug studies and clinical trials are typically sponsored by private sponsors for the purposes of testing new drugs or medical device. Frequently, these awards are reimbursed based on the number of patients involved in the study or the number of tests completed. It is your responsibility to ensure that such information is maintained at the departmental level and communicated in a timely manner to the SRA.

The indirect cost rate for any drug studies or clinical trials is set at a standard rate (currently 15%) and is applied to the entire award budget at the initiation of the award.

Fixed Price Awards

Fixed price awards may arise in any number of circumstances. It is essential that the terms of the award clearly state that this is the nature of the award. The appropriate institutional indirect cost rate is used for these awards. Like research awards, the indirect cost rate is applied to modified total direct costs as defined by institutional policy. Additionally, at the termination of the award, the indirect cost rate will be applied to any remaining cash residual prior to transfer.

MODIFICATIONS TO SPONSORED AGREEMENTS

Change in Status of the Principal Investigator

Whenever your participation on a project will change significantly (such as when the project will continue without your active direction during any continuous period of more than three months, when you withdraw from the project entirely, or when you propose to devote substantially more or less effort to the project than was anticipated at the time of award), it is your responsibility to notify the OSP as soon as possible. Since approval of a project is, to some extent, based on your participation and qualifications, grantee institutions are required to notify the awarding office of the alternative plans for conducting the activity. The awarding office should be made aware of your change in status no later than 30 days before the expected date of departure or change in participation.

Approval from the awarding office may be required and must be requested before your actual change in status. In such cases, if the arrangements proposed by the grantee, including the qualifications of any proposed replacement, are not acceptable to the awarding office, the award may be terminated. If the grantee wishes to terminate the project because it cannot make suitable alternative arrangements, it should notify the awarding office of its intent, and the award office will forward closeout instructions.

Transfer of Principal Investigator

When the PI transfers from one domestic institution to another domestic one or from a foreign institution to a domestic one, the project under the same PI may be supported at the new institution for the remainder of the previously approved project period at an amount not to exceed that previously recommended for direct costs. The change may be made without competitive review provided that the original grantee institution agrees in writing to relinquish the project, the new institution submits a new application form for support of the project, the investigator plans no significant change in research objectives and level of direct cost funding, and the facilities and resources at the new location allows for successful performance of the project. If these conditions are not met or if other programmatic or administrative requirements are not met, the awarding office may require a competitive review.

PUBLIC RELEASE OF PROJECT INFORMATION

Acknowledging Sponsor Support

When preparing journal articles, presenting papers, giving lectures at conventions, etc., you should recognize the sponsor that made the research possible. It is often true that, without the sponsor's support, the University would not have had the opportunity to conduct the research. Acknowledgment of sponsors could very well further your and the University's position for future awards. Occasionally however, sponsors do not wish to be acknowledged. Questions on this issue should be directed to the OSP.

PATENTS AND COPYRIGHTS

Patents

All sponsored agreements received from federal agencies, and from many other sponsors as well, contain provisions for the identification and administration of inventions. In all federally funded projects, inventions that are "conceived" and inventions that are actually reduced to practice for the first time are subject to reporting requirements and the transfer of certain rights to the sponsor. With respect to inventions, conceived is defined as either a new or improved device, composition, plant, or method together with some practical use or advantage for it and an effective means for producing it or carrying it out. Suggestions in project reports for additional research or development activities often describe such "conceptions" of project inventions.

You should review the research periodically to identify any discoveries or improvements that may be patentable. While it is helpful in evaluating and patenting an invention to obtain as much information as possible concerning its scope and advantages, it is also important to apply for a U.S. patent prior to public use or disclosure of the invention. It is possible to apply for a U.S. patent within one year following public use or disclosure. However, since prompt publication of results is often of paramount importance to academic researchers, early identification and reporting of project inventions are critical in order to avoid sacrificing potentially valuable patent rights and to minimize publication delays for preparation of patent applications where such delays are provided for in the sponsored agreement. Project inventions should be reported to the OSP as early as possible to ensure you obtain the strongest possible patent protection while accommodating the inventor's publication plans and fulfilling any reporting and review requirements of the sponsored agreement.

Keep in mind that, in many fields, wide use of even a beneficial invention is unlikely in the absence of patent protection. This applies particularly where high costs will be incurred in perfecting the invention and securing regulatory approval of its use. Under the University's policy on patents and copyrights, the individual inventors receive a share of the royalties or other income from project inventions.

Copyrights

Project reports and scholarly publications describing project activities and results are not ordinarily required by institutional policy or by provisions of the sponsored agreement to carry notice of copyright. However, if such publications contain copyright-protected material of others, you must obtain permission to use that material, acknowledge its provisions, and follow the conditions of such permission (i.e., acknowledgment and notice of copyright).

Other project-developed works protected by copyright, especially computer software and its documentation, should be marked with a notice of copyright to include computer readable copies and drafts. You need include in the notice only the year of the latest revisions. If you incorporate the copyright-protected material of others, you must obtain permission to use and publish such materials. In the case of computer software, you must observe the terms of any licensing agreement under which it was made available.

Where the sponsored agreement contemplates that such works will be produced and delivered to the sponsor, or provides that the sponsor will have the right to undertake the commercial development of any such works that may be produced in the project, these works should be promptly reported and delivered to the sponsor in accordance with the terms of the sponsored agreement. Your OSP representative should be consulted as to such requirements. If questions arise about copyright protection of project-developed works or about the use of copyright-protected works of others, please consult the OSP.

If you believe a project-developed work has significant potential for commercial development and rights have not been exclusively allocated to the sponsor, you should contact the OSP. The OSP will work with you to evaluate and develop that potential. Under the University's policy on patents and copyrights, faculty receive a share of the royalties or other income from project-developed works.

For additional information on either of the patent or copyright policies contact the OSP at 293-7398.

APPENDIX 1

FLOW CHART OF SPONSORED AWARD PROCESS

WVU Research Corporation - 293-3449

Controller's Office of Sponsored Research Accounting - 293-4002

Office of Sponsored Programs - 293-3998

Payroll and Travel Accounting - 293-5700

Accounts Payable - 293-3121

Purchasing and Inventory Management - 293-5711

Environmental Health and Safety - 293-3792

Facilities Management - 293-7309

Telecommunications - 293-3531

Computing Services - 293-3011

Human Resources - 293-3430

FULL CLOSEOUT PROCESSING CHECKLIST

The financial close out of a sponsored award is a combined effort between you as the PI, your departmental support staff, the Office of Sponsored Programs (OSP), and the Controller's Office of Sponsored Research Accounting (SRA). The checklist below should serve as a time line and to assist you in ensuring that the federal and institutional requirements for your sponsored award are met. The time line is based on the federal regulation that requires financial close out to be completed 90 days after the end date of the sponsored award. Please note that some award documents require close out to be completed in a shorter time frame.

Three Months Prior to Award Expiration Date:

OSP

- Provides a reminder notice on impending expiration

PI

- Determine if sponsored activity can be completed by expiration date of the award. If not, contact the OSP to request a no cost extension.

- Confirm that cost sharing expenditures are being made according to budget and will fulfill the award requirement by the expiration date.

One Month Prior to Award Expiration Date:

PI

- Determine if any additional purchases are required for your sponsored award. All goods and services must be received and completed by the end date of the award.

- Limit the use of departmental purchase orders (DPO) and procurement card purchases to those items which can be received prior to the award expiration as well as invoiced within 30 days.

- Correct any overexpenditure conditions that exist or are anticipated.

0 to 30 Days After Award Expiration Date:

PI

- Complete and file technical reports.

- Ensure that no overexpenditures have occurred on your sponsored award.

- Ensure that all cost sharing has occurred, been appropriately documented, and been communicated to the Controller's Office of Sponsored Research Accounting.

- Ensure that all effort reports have been signed and returned.

- Cancel or assign to alternative funding:

all personnel costs

all long distance telephone access accounts, and other telephone related charges

all WVNET accounts

all postage accounts

all outstanding purchases orders

- Obtain and process all final vendor invoices directly related to goods and service directly charged to the sponsored award.

- Process all cost transfers/expenditure reductions necessary to appropriately allocate expenditures to the sponsored award and to correct any clerical errors.

- For fixed price awards, drug studies, and clinical trials only, forward form letter to direct Sponsored Research Accounting regarding disposition of any positive cash residual.

31 to 90 Days After Award Expiration Date

PI

- Assist the OSP and Sponsored Research Accounting in the closeout process.

Controller's Office of Sponsored Research Accounting

- Close any outstanding purchase orders.

- Verify that no further liabilities are recorded in the institutional accounting system.

- Review fringe charges through life of award and make any necessary corrections.

- Review indirect cost charges through life of award and make any necessary corrections.

- Document cost sharing and verify that cost sharing requirement has been met.

- Verify that award budget has be spent appropriately.

- Prepare final invoice.

- Prepare final financial report.

- Perform UBIT analysis if appropriate.

- Transfer or return to agency any positive cash residual as appropriate.

After Award

PI

- Respond to any subsequent audit requests.

Controller's Office of Sponsored Research Accounting

- Complete collection process.

- Verify fund and all related organizations may be purged at appropriate time.

- Archive physical file for retention.

- Respond to any subsequent audit requests.

APPENDIX 4

STANDARD LETTER FOR TRANSFER OF CASH RESIDUAL

MEMORANDUM

To: Jane Doe Assistant Controller Sponsored Research Accounting

From: Principal Investigator Date:

RE: Transfer of Residual Cash Balance from WVURC FAO:
to WVU Foundation Account __________________
or WVU FAO: ______________________________

This transfer of funds remaining from the identified fixed-price project (clinical research, testing, evaluation, etc. ) is requested and endorsed in accordance with the following:

Total Value of Contract $ __________________________

Residual Balance $ __________________________

• All outstanding encumbrances/purchase orders have been cleared.
• All sponsor requirements have been met, technical and other project reports filed and the sponsor does not make any claim on this cash balance.
• Any transfer payments for expenses incurred in the performance of the project have been made, i.e. personal service reimbursements (UHA, WVU, etc.), clinical laboratory fees and similar costs associated with the operation of the project.

It is understood that before the transfer of cash is made, the award will be reviewed for unrelated business income tax (UBIT) liability as required by Internal Revenue Service regulations. Should the award be liable for UBIT, an amount will be withheld from transfer equal to 31% of the residual cash balance plus total of all non deductible (taxable) expenditures. Remaining cash (after withholdings) will be transferred to the designated WVU Foundation or WVU fund area organization according to University policies.

In the event that the total withholding is determined to be greater than actual UBIT liability, excess withholdings will be transferred to a departmental account. If actual UBIT liability is greater than withholdings, the college/school shall remain responsible.

Approved: Departmental Chairperson ____________________________________

Approved: Dean_______________________________

APPENDIX 5

The Sponsored Award Worksheet is available from the Controller's Office

Last Updated: February 29, 1996