Extramural Funding Policies and Procedures

In order to ensure that research and projects supported by extramural funding are conducted by those who have the requisite training and education, as well as an appropriate relationship with the University, the University generally will only support proposals and awards for projects when the Principal Investigator (PI) or Project Director (PD) holds an appointment by the University as an assistant professor, associate professor, professor, and/or distinguished professor, or is a full-time staff member of the University. 

Other members of the University community must obtain an exemption to University policy in order to serve as a PI or PD. Exemptions require the approval of the Provost, Vice Provost, Department Chairperson, if applicable, and the Dean of the relevant school. The Principal Investigator or Project Director Eligibility Exemption Form must be signed by the appropriate approvers to ensure that the applicant meets the requirements and assurances for exemption.

All grant proposals to external sponsors must be submitted through RGFR. The PI/PD must allow adequate time prior to submission for RGFR's review and preparation of application materials. Accordingly, RGFR must receive all finalized materials at least one (1) calendar week prior to the sponsor's deadline. For example, if a proposal is due to the sponsor on a Wednesday, RGFR must receive the finalized application package by the previous Wednesday. Upon receipt of the final application package, RGFR will conduct necessary compliance checks and route the proposal for internal review and approval, and subsequent submission. Materials received after the internal administrative deadline will not be submitted for consideration without additional approval.

Before a proposal may be submitted for any sponsored project, the PI/PD, working in conjunction with RGFR, must obtain authorization through RGFR's internal review and approval routing system, Cayuse. Authorizations for proposals and awards include the: 1) PI/PD, 2) Department Chairperson (if applicable), 3) Major Area Budget Manager, 4) Dean or Director, 5) Associate Provost, 6) VP for Advancement (private funders) 7) Vice Provost, and 8) Provost (proposals and awards $50K and above).

• Summer Salary Policy

Subrecipient/Subaward Policy Overview

Indirect Costs (Facilities & Administrative - F&A)

Policy on Conflict of Interest in Research

Policy on PHS/NIH Conflict of Interest in Research

University Conflict of Interest Policy

Responsible Conduct of Research Training Requirements

For each proposal to NSF that proposes to conduct research off-campus or off-site, the submitting organization's authorized organizational representative (AOR) must complete a certification that the organization has a plan in place for this proposal regarding safe and inclusive working environments. See Chapter II.E.9 of the Proposal and Award Policies and Procedures Guide (PAPPG) for more information.

Proposals that propose to conduct research off-campus or off-site, must submit a plan that addresses how the following types of behavior will be addressed:

• Abuse of any person, including but not limited to harassment, stalking, bullying, or hazing or any kind, whether the behavior is carried out verbally, physically, electronically, or in written form; and
• Conduct that is unwelcome, offensive, indecent, obscene, or disorderly

This plan should also identify steps the proposing organization will take to nurture an inclusive off-campus or off-site working environment, e.g., trainings; processes to establish shared team definitions of roles, responsibilities, and culture, e.g., codes of conduct; and field support, such as mentor/mentee support mechanisms, regular check-ins, and/or developmental events.

Communications within the team and to the organization should be considered in the plan, minimizing singular points within the communications pathway (e.g., a single person overseeing access to a single satellite phone). Any special circumstances, such as the involvement of multiple organizations or the presence of third parties in the working environment, should be considered.  The process or method for making incident reports as well as how any reports received will be resolved should also be accounted for.

The organization’s plan for the proposal must be disseminated to individuals participating in the off-campus or off-site research prior to departure.

Disclosure of Other Support and Affiliations

For a cost to be allowable, it must be:

• Necessary: necessary and reasonable for the performance of the award
• Reasonable: if it does not exceed an amount that a prudent person would incur under the circumstances prevailing when the decision was made to incur the cost
• Allocable: if the cost is assignable to and incurred specifically for the award.

Additionally, the cost must be consistently treated, adequately documented, and conform to any limitations or exclusions set forth in federal or funder guidance, in addition to university policy.

The PI/PD has primary oversight to ensure that all charges and budget revisions are made in accordance with the terms and conditions of the award.

Cost Transfer Policy

Procurement Policy

Capital Equipment Administration Policy Overview

The Federal Government prohibits expending federal funds on goods and/or services from any entity suspended or debarred from doing business with the federal government. 

Procurement: A procurement contract is considered a “covered transaction” if it is for an amount equal to or greater than $25,000. Procurement of goods and/or services of a covered transaction with federal funds from a supplier or contractor shall be checked for debarment and suspension before purchasing and/or awarding a contract or subaward. 

To ensure that Pepperdine University is not doing business with vendors who have been suspended or debarred from doing business with the Federal government, the PI/PD is responsible for ensuring the eligibility of vendors of goods or services that will cost $25,000 or more prior to the acquisition of goods or performance of services. For procurements $25,000 or more, the department/school is required to reach out to RGFR to conduct a debarment and suspension check before creating a purchase order or making a payment. Results from the SAM.gov search shall be made part of the purchase order/contract documentation.

The department/school may also verify debarment and suspension by obtaining certification from the entity, or adding a clause or condition to the covered transaction with the entity. The department/school must provide the certification, clause, or condition to RGFR for review and documentation.

Project changes requiring funder approval and revisions that can be tracked internally depend on funder terms and conditions. Please reach out to RGFR prior to making any project revisions.

Budget Revisions

Rebudgeting is the transfer of funds from one budget category or line item to another. During the performance of the project, the PI/PD may realize that modifications to the budget are necessary. Many sponsors are flexible with respect to how project funds are expended, and generally allow budget changes that are necessary to carry out the project, without changing the scope of the funded project. PIs/PDs must know the specific requirements for their awards and, if necessary, request prior approval for budget modifications. 

Rebudgeting to include vertebrate animal care costs or human subject costs is not permitted without prior IACUC or IRB approval. RGFR is available via telephone at (310) 506-6996 or email (rgfrinfo@pepperdine.edu) to provide further information to PIs/PDs regarding any matters related to budget modifications.

No-Cost Extensions

A no-cost extension (NCE) is a request to extend the termination date of a project without any additional funds.

The PI/PD must plan and manage project work in an efficient manner such that the project will be finished within the timeframe and funds authorized. Despite a PI's best efforts, they must sometimes seek additional time to complete the project, with or without additional funds. PIs/PDs must obtain approval for a no-cost extension from RGFR. RGFR will contact the funder for approval of the no-cost extension.

For common project changes, such as one-time NCEs, some funders (most NIH and NSF grants) require only prior notification of the change, i.e., grantee-approved requests, and once we notify the funder of the project change, it’s immediately effective. 

Reduction of Effort and/or Change of Principal Investigator/Project Director

When a PI/PD will be absent from a project for three (3) or more consecutive months or reduce effort by 25% or more, the PI must seek prior approval from the University and the funder. In the event of such an absence or effort reduction, the funder may require a change in the PI/PD. PIs/PDs may also need to be added or removed from a project under other scenarios. 

Change in Scope

Significant changes in the project or research from what was originally proposed and approved always require notification and/or approval from the funder.  This includes change in objectives, major activities, methodology, and delays or adverse conditions that may affect the ability to carryout the project. 

Effort Reporting Policy

Funders' record retention requirements (usually three [3] years for federal sponsors) usually commence after the end of the calendar year in which the expiration/termination of the sponsored agreement occurs.. Notwithstanding funder record retention requirements, which vary from funder to funder, PIs/PDs must also review and conform to the University Record Management Policy and Schedule. For questions regarding record retention requirements, please contact RGFR, available via telephone at (310) 506-6996 or via email (rgfrinfo@pepperdine.edu).

If a funder seeks an audit of an award, the funder or its designated representative must perform the audit or otherwise arrange for the audit to be conducted at its own expense. When an audit is sought, the PI/PD must notify RGFR immediately if the audit is not sought through RGFR. The notice to RGFR should include information regarding when and how (i.e., through whom) the sponsor plans to conduct the audit. The PI must also provide RGFR with reasonable assistance throughout the audit process. If costs charged to the audited sponsored project are disallowed in the course of the audit, those costs will be borne by the PI's/PD’s department and/or school. RGFR will coordinate with the department and/or school to prepare and submit a revised final invoice and/or Financial Status Report if required as the result of the audit.

Separate from any audit initiated by the sponsor, a certified public accounting firm performs an annual financial audit of the University's accounting records. The annual audit includes a review of sponsored project accounts funded by federal agencies or institutions, and a determination of the University's compliance with federal regulations. This audit is conducted in accordance with OMB Uniform Guidance and satisfies most federal audit requirements. RGFR works closely with General Accounting, which serves as the University representative to coordinate this audit, to respond to all inquiries regarding University sponsored project accounts posed by the accounting firm during the course of the audit. However, the PI's/PD’s department may be asked to assist with the audit as deemed necessary and appropriate.

Finally, in addition to the above-described audits, University Assurance and Advisory Services may conduct internal audits or consults. When such audits or consults are conducted, departments may be called upon to participate in some manner. 

Preparation for the closeout of an award should begin immediately upon receiving the award. The PI/PD must review the Notice of Award Memorandum, the accompanying agreement, reporting requirements, and the budget to ensure accuracy and future compliance.

In advance of the project period end date, attention should be given to a complete review of the account in preparation for closeout. The review should involve the collaboration of the PI/PD and their Major Area Budget Manager.

After completion of the award period, the PI/PD will work with RGFR and their budget manager to complete all closeout requirements on behalf of the sponsor and Pepperdine University. PIs/PDs will be required to review, complete, and sign a Grant Completion Checklist to closeout the grant project.

University Policy on Patents and Copyrights

Ownership and publication rights to data, materials, records, and any other form of intellectual property developed on sponsored projects will be specified in the terms of the grant agreement.

Public access means that research outputs be made freely accessible for all to read. Public access does not require that outputs be free of copyright or reuse permissions. 

All federal agencies with research and development expenditures are subject to the 2022 Office of Science and Technology Nelson Memo guidance, which provides free, immediate (without embargo), and equitable access to research that is federally funded. It applies to all federal agencies, including those providing funding in the Humanities & Social Sciences, and applies to both peer-reviewed publications and underlying scientific data.

Open access provides both free and unrestricted online access to read published research outputs with the addition of reduced copyright restrictions. Open access publications are released with a copyright license (such as a Creative Commons license) that allows some type of reuse, re-distribution, modification, or adaptation. 

Pepperdine Libraries' Digital Publications is a repository for research and scholarly output selected by individual university departments and centers on campus. Our publishing platform, Digital Commons, provides instant access to full text works and preserves these materials in an open access secure digital environment.

Research, Grants, and Foundation Relations works closely with faculty/staff, Advancement Services, and General Accounting to determine whether a contribution to the university qualifies as a gift or grant.  The following factors are considered and are typically indicative of a grant:

• Specific project, research, activity, or scope of work
• Specified period of performance
• Line-item budget for expenditures
• Reporting requirements or deliverables

RGFR routes private grants and gifts through Advancement Services for processing.