Policies, Guidelines, and Recommendations
The Office of Research and Sponsored Programs (RSP) provides Pepperdine University principal investigators with guidance and information concerning research policies and procedures to support their pursuit and management of external funds for sponsored projects.
A sponsored project is an externally funded, restricted project or activity originated and conducted by faculty, and in some cases staff, with a defined scope of work that provides a basis for accountability and sponsor expectations. In most, if not all cases, a sponsored project is awarded by the sponsor through a Notice of Award document which specifies the terms and conditions of the award.
Eligibility to Submit Proposal for External Support
In order to ensure that research is 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 for projects that are already in progress when the PI 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. Exemptions require the special approval of the Provost, Vice Provost for Research and Strategic Initiatives, and the Dean of the relevant school.
To facilitate the exemption review and approval process, the proposed PI must submit a photocopy of the AUTHORIZATION FOR EXTERNAL FUNDING FORM, the abstract, his/her curriculum vitae (CV), and a completed PRINCIPAL INVESTIGATOR ELIGIBILITY FORM, signed by the proposed PI's department chairperson.
RSP will not submit a grant application or, as in some instances, request transfer of an award from another institution to the University, until an exemption request is approved by those mentioned above.
For further information regarding eligibility, please contact RSP.
Routing - Authorized Signatures/Approvals
The PI must allow adequate time prior to submission for RSP's review and preparation of application materials. Accordingly, RSP must receive all finalized materials at least one (1) calendar week prior to the sponsor's deadline. For example, if a proposal is due on a Wednesday, RSP must receive the finalized application package by the previous Wednesday. Upon receipt of the final application package, RSP will conduct necessary compliance checks and route the proposal for approval and subsequent submission. Materials received after the internal administrative deadline will not be submitted for consideration.
Before a proposal may be submitted for any sponsored project, the Principal Investigator (PI), working in conjunction with RSP, must obtain authorization through RSP's routing system. Authorizations for proposals submitted through RSP are required from the PI, and generally include the Department Chairperson (if applicable), the Dean or Director of the School, the Major Area Budget Manager, the Director of RSP, the Vice Provost for Research and Strategic Initiatives, and the Provost.
Before an award may be accepted for any sponsored project, the Principal Investigator (PI), working in conjunction with RSP, must complete, sign and obtain all other required authorizing signatures on the AUTHORIZATION FOR EXTERNAL FUNDING form. Authorizations for awards submitted through RSP are required from the PI, and generally include the Department Chairperson (if applicable), the Dean or Director of the School, the Major Area Budget Manager, the Director of RSP, the Vice Provost for Research and Strategic Initiatives, and the Provost.
Policies on Conflict of Interest in Research
In accordance with Federal regulations, Pepperdine University has a responsibility to manage, reduce, or eliminate any actual or potential conflicts of interest that may be presented by a financial interest of an investigator. Thus, investigators must disclose any significant financial interest that may reasonably appear to be affected by sponsored projects. Investigators must fully disclose any significant financial interest before the proposal is submitted. Pepperdine also requires disclosure of any family relationship between investigators and persons working with them on sponsored projects.
As of August 2012, new Public Health Service (PHS) regulations require that all PHS-funded investigators (including those funded through the NIH and CDC) file a disclosure—even if it Is a negative report—with each grant proposal, and annually for the life of the grant. The process is as follows:
1. If you are funded by or applying to a PHS sponsor, please see the Policy on PHS/NIH Conflict of Interest in Research; or
If you are funded by or applying to any other sponsor than PHS, please see the Policy on Conflict of Interest in Research; and
2. Complete the Financial Interest Disclosure Form; and
3. Return the form to the RSP (TAC Room 336).
All conflicts of interest or potential conflicts of interest must be resolved before any awarded funds can be spent. Pepperdine University's Institutional Official (see definition within policies) may require a written plan for resolving conflicts.
If a new significant financial interest arises at any time during the period after the submission of the proposal through the period of the award, that interest must be disclosed.
Who Is Covered?
"Investigator" means the principal investigator/project director, co-principal investigators, and any other person at the University who is responsible for the design, conduct, or reporting of research, educational, or service activities funded, or proposed for funding, by an external sponsor. In this context, the term investigator includes the investigator's spouse or domestic partner and dependent children.
What Must Be Disclosed?
Any significant financial interest that would reasonably appear to be affected by the research or educational activities funded, or proposed for funding, by an external sponsor.
Any significant financial interest in an entity whose financial interests would reasonably appear to be affected by the research or educational activities funded, or proposed for funding, by an external sponsor.
What Is Covered?
Significant financial interest means anything of monetary value, including (but not limited to):
- Salary or other payments for services (e.g., consulting fees or honoraria);
- Equity interests (e.g., stocks, stock options or other ownership interests); and
- Intellectual property rights (e.g., patents, copyrights and royalties from such rights).
Significant financial interest does not include:
- Salary, royalties, or other remuneration from Pepperdine University;
- An equity interest that when aggregated for the Investigator and the Investigator's
spouse or domestic partner and dependent children, meets both of the following tests:
- does not exceed $5,000 in value as determined through reference to public prices or other reasonable measures of fair market value; and
- does not represent more than a five percent ownership interest in any single entity;
- Salary, royalties or other payments that when aggregated for the Investigator and the Investigator's spouse or domestic partner and dependent children over the next twelve months, are not expected to exceed $5,000;
- Income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities; and
- Income from service on advisory committees or review panels for public or nonprofit entities.
The exclusions in the first three items do not apply if the compensation or transfer of an equity interest is conditional upon a particular outcome in a sponsored research project.
This section directly addresses the eligibility of faculty with nine-month appointments to receive fourth quarter salary, often known as summer salary or summer ninths.
Several years ago, federal auditors discovered that many PIs who received a total of three (3) summer months of salary from federal sources did not devote 100% effort during those three (3) months to the grant-funded projects. In other words, salary expenditures were being charged to grants when individuals did not work, or salary was being charged in excess of the time spent on the project. Consequently, a number of large fines were threatened or levied against leading research institutions.
The audit also revealed that PIs had charged non-related activities to sponsored projects. These activities included, but were not limited to: proposal writing, committee or administrative work, teaching, university service, and vacations. It is important to remember that only activities directly related to the research projects, such as conducting research, writing progress reports, attending research-related conferences, and or/holding research meetings can be charged to a sponsored project. Also of concern, auditors found salary inappropriately charged in the summer when work was actually performed during the academic year. In response to these findings, a number of leading research institutions have now limited faculty to receiving two or two-and-a-half (2-2.5) summer ninths from federal sources. As of January 1, 2009, the National Science Foundation (NSF) unveiled a significant revision to its salary reimbursement policy, limiting compensation of project personnel to two (2) months of their regular salary paid from NSF grants during a calendar year.
STATEMENT OF POLICY
University faculty compensated for nine-month academic appointments may charge up to two-and-a-half (2.5) months of summer salary on sponsored projects, subject to allowability per the relevant agency. University faculty compensated for eleven-month academic appointments may charge up to one (1) month or 1/11 of the employee's base salary as summer salary on sponsored projects, subject to allowability per the relevant agency. For further information, please contact the Dean and Major Area Budget Manager of your school.
PIs are generally expected to be at the University for the period for which support is sought unless their research requires specific off-campus responsibilities.
If a faculty member already has administrative or other non-research related responsibilities during the summer period, they will be precluded from devoting 100% effort to sponsored projects, and thus from requesting up to two-and-a-half (2.5) months of salary from those projects. Instead, they may capture a percentage of time that accurately reflects the work they will perform on the project.
An exception to exceed the 2.5 months of summer salary on sponsored projects will require a completed REQUEST TO CHARGE OVER 2.5 MONTHS SUMMER SALARY TO SPONSORED PROJECTS FORM from the PI, which indicates the full extent of the effort during the summer period. The request will then require the approval of the faculty member's Division/Department Chairperson, Dean, and the Vice Provost for Research and Strategic Initiatives. In rare circumstances, University faculty compensated for eleven-month academic appointments may be eligible for up to one month of summer salary subject to University approval and relevant agency allowability. The request would require the approval of the faculty member's Division/Department Chairperson, Dean, and the Vice Provost for Research and Strategic Initiatives.
For a copy of the REQUEST TO CHARGE OVER 2.5 MONTHS SUMMER SALARY TO SPONSORED PROJECTS FORM, please contact RSP's Compliance Monitoring Officer.
Non-sponsored funds, such as internal support from the University, may also be used to cover salary for any portion of the summer salary, including the remaining 0.5 month not allowed on sponsored projects.
Rebudgeting of Funds
During the performance of the project, the PI 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. PIs 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. The RSP Compliance Monitoring Officer is available via telephone at (310) 506-6996 to provide further information to PIs regarding any matters related to budget modifications.
Cost Transfer Policy
RSP, with support from the Controller's Office, General Counsel's Office, and University Auditing, has implemented a Cost Transfer Policy, effective immediately. A cost transfer is a movement of costs associated with a transaction between two chartstrings (CFS), of which at least one must be a federally sponsored project. A Cost Transfer Justification Form will be used each and every time that charges need to be corrected BETWEEN federally sponsored projects. Charges will need to be corrected via a transfer FROM a federally sponsored project to another CFS, or changes need to be corrected via a transfer TO a federally sponsored project from another CFS.
Sponsored Project Extensions
The PI 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, he/she must sometimes seek additional time to complete the project, with or without additional funds.
A no-cost extension is a request to extend the termination date of a project without any additional funds.
ALLOWABILITY OF NO-COST EXTENSION REQUESTS
Whether a no-cost extension will be permitted depends upon the sponsor. Some federal sponsors allow the institution to internally approve the extension, while other sponsors require that a formal request for additional time be submitted for their approval.
NO-COST EXTENSION EFFORT LEVEL
PIs must continue to devote the same level of effort as in the period preceding the extension, unless prior approval for the reduction has been received.
CARRY FORWARD OF FUNDS
Relatedly, the carrying forward of funds that are unspent at the end of a multi-year project is dealt with differently by different sponsors.
NO-COST EXTENSION CONTACTS
For any questions, information, or assistance regarding the topics above, RSP should be consulted for the specific requirements of the award and the sponsor.
Reduction of Effort and/or Change of Principal Investigator
When a PI 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 sponsor. In the event of such and absence or effort reduction, the sponsor may require a change in the PI. PIs may also need to be added or removed from a project under other scenarios. Please contact RSP's Compliance Monitoring Officer via telephone at (310) 506-6996 for further information.
Sponsors' record retention requirements (usually three  years for federal sponsors) usually commence on the date that the last financial report is submitted to the sponsor. However, for certain sponsors (NSF for example), the record retention obligations continue until three years from the date that the PI submits the technical report. Notwithstanding sponsor record retention requirements, which vary from sponsor to sponsor, PIs must also review and conform to the University Record Management Policy and University Records Retention Schedule. For questions regarding record retention requirements, please contact the RSP Compliance Monitoring Officer, available via telephone at (310) 506-6996.
If a sponsor seeks an audit of an award, the sponsor 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 must notify RSP immediately if the audit is not sought through RSP. The PI's notice to RSP should include information regarding when and how (i.e. through whom) the sponsor plans to conduct the audit. The PI must also provide to RSP 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 department and/or school. RSP will coordinate with the department 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 Circular A-133: Audits of States, Local Governments, and Nonprofit Organizations and satisfies most federal audit requirements. RSP 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 department may be asked to assist with the audit as deemed necessary and appropriate.
Finally, in addition to the above-described audits, University Auditing Services may conduct internal audits or consults. When such audits or consults are conducted, departments may be called upon to participate in some manner. Internal audits or consults serve numerous purposes. More detailed information regarding these types of audits or consults is discussed at Section 15, entitled Auditing Services, of the University's Financial Policies.
Closeouts and Final Reporting Process
Preparation for the closeout of an award should begin immediately upon receiving the award. The PI must personally review the NOTICE OF AWARD MEMORANDUM, the accompanying agreement, and the budget to ensure accuracy and future compliance.
At a time before the termination date of the award, attention should be given to a complete review of the account in preparation for closeout. The review should involve the collaboration of the PI and his/her Major Area Budget Manager.
After completion of the award period, the PI will work with RSP and their budget manager to complete all closeout requirements on behalf of the sponsor and Pepperdine University.
Capital Equipment Administration Policy
The following are property management standards for capital equipment assets (an article of nonexpendable, tangible personal property having a useful life of more than one year with an acquisition cost or fair market value of $5,000 or more) acquired with federally-sponsored funds:
A. Careful screening should take place before purchasing property and equipment to ensure it is needed. Careful screening may include the following elements and procedures:
- Consider whether existing equipment already owned can meet identified needs; and
- Consider the purchase based on the cost of the proposed equipment and/or the size of the grant recipient.
B. Capital equipment asset records in Pepperdine University's Office of Research and Sponsored Programs will include the following:
- Description of the property/equipment (including make and model);
- Manufacturer's serial number or other identification number;
- Vendor/source of the property;
- Whether the title settles with the recipient or the Federal Government;
- Acquisition Date;
- Cost of the item;
- Percentage of Federal participation in the cost of the item;
- Location of the property/equipment;
- Maintenance procedures implemented to keep the equipment in good condition;
- Condition of the property/equipment as of the date the information is reported; and
- If applicable, the disposition data and sale price.
Note: If a grantee is authorized or required to sell the property/equipment, proper sales procedures must be established to ensure the highest possible return.
C. Equipment owned by the Federal Government is identified to indicate Federal ownership in the award document.
D. In most situations, when discretionary grant funds are used to acquire equipment and nonexpendable personal property, title vests with the organization, subject to obligations and conditions provided by the federal funding agency.
- Award recipients and subrecipients should use the equipment in the program or project for which it was acquired as long as needed, whether or not the program or project continued to be funded by Federal funds.
- When no longer needed for the original project or program, the grantee must use the property in connection with its other federally sponsored activities in the following order of priority:
i. Other projects of the awarding agency needing the property
ii. Projects of other Federal agencies needing the property
E. Per Federal requirements, a physical inventory of the property/equipment must be taken and the results reconciled with the property/equipment records at least once every two years.
- This includes a verification of the existence, current utilization, and continued need for reach item.
- Any difference between physical inspection and accounting records will be pursued to determine the cause of the difference.
- Pepperdine University must promptly and properly investigate and fully document any loss, damage, or theft of nonexpendable property.