Compensation Policy
These policies include information regarding compensation from grants and sponsored programs at Manchester University. Accompanying the policies is a time and effort report template. All Manchester University employees receiving compensation from federal grants and sponsored programs are required to complete a time and effort report each reporting period. The grants office will contact you with the appropriate report and instructions when applicable.
Data Collection
When collecting data under a federal award, Manchester University researchers should abide by the Paperwork Reduction Act. The following summary guidelines are from NSF's Research Terms and Conditions Appendix C National Policy Requirements: "The recipient shall not represent to respondents that such data are being collected for or in association with the awarding agency without the specific written approval of the cognizant awarding agency official of such data collection plan or instrument. However, this requirement is not intended to preclude mention of awarding agency support of the project in response to an inquiry or acknowledgment of such support in any publication of these data."
Direct vs. Indirect Costs
When creating a grant budget, make sure you appropriately classify direct and indirect costs. When spending funds, make sure you do not charge items to a grant that are considered indirect costs.
Federal Funding Accountability and Transparency Act and Government-Wide Debarment and Suspension
Manchester is compliant with the Federal Funding Accountability and Transparency Act of 2006 (FFATA), and provides information about certain federally-funded subawards and vendor agreements on www.fsrs.gov as required. Manchester is also compliant with Government-wide Debarment and Suspension requirements, which include certification of compliance for certain federally-funded subawards and vendor agreements.
Before making subawards in excess of $25,000 and subcontracts/vendor payments in excess of $30,000, Manchester checks organization statuses on SAM.gov. Subawardees and vendors who meet these criteria must be registered. Manchester reports subawards in excess of $25,000 and subcontracts/vendor payments in excess of $30,000 on the Federal Funding Accountability and Transparency Act Subaward Reporting System site at www.fsrs.gov as well as completing the Entity Management System in SAM. As a Principal Investigator, Project Director, or grant lead person, you must notify the Director of Grants and Sponsored Programs or Office of Institutional Effectiveness if you are planning a subaward in excess of $25,000 or subcontract/vendor payment in excess of $30,000 related to your grant(s).
See the document below for more procedural information.
Financial Conflict of Interest Policies and Forms
The policies and processes detailed here are designed to promote objectivity in research and to ensure that the design, conduct and reporting of research conducted at the University and sponsored with federal funds are not biased by any perceived or real financial conflict of interest (FCOI) of an Investigator.
This policy is intended to comply with the current federal regulations governing FCOIs entitled "Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought" (42 C.F.R. Part 50, Subpart F) and other relevant federal agency regulations. A list of PHS-funded agencies is below for your reference. Researchers must review the policy below and fill out the attached form before submitting proposals to federal agencies, and update the form annually if funded. Researchers must also complete the NIH training below prior to engaging in
PHS-funded research.
NIH FCOI Training
Participant Support Costs
If your budget includes participant support costs, those funds should be kept separate from other grant funds, and cannot be re-budgeted without written sponsor approval.
Program Director/Principal Investigator Assurance
It is a compliance requirement that applicant organizations to the Public Health Service (PHS) must secure and retain a written assurance from each PD/PI prior to submitting each application to the PHS. This assurance form and more information is included below.
Record Retention
Except for general information, the University will retain federal, passthrough, and private sponsored project records for three years after the last financial report submission unless otherwise specified by the funder. This is consistent with 2 CFR 200.333, Retention requirements for records.
When reporting is not required, records will be retained for three years after the date of the last expenditure.
Research Misconduct - Responsible Conduct of Research Policies
It is Manchester’s policy that all scholarship and research be characterized by the highest standards of integrity. The policy and procedure document below details Manchester's policies and procedures with respect to allegations of misconduct in scholarship and research and meets Manchester’s responsibilities under federal regulations. The Responsible Conduct of Research document below details Manchester's training requirements for the responsible conduct of research.
If you have completed CITI training in the past (with Manchester or with a previous institution), click Log In and enter your username and password. If you have not completed CITI training in the past, create a new account by clicking Register. If you have completed CITI training in the past with another institution, logging in with your old credentials will retain your training history. Once in CITI, you can affiliate your account (including your previous training) with Manchester.
Note: Manchester pays for a university-wide subscription to the CITI Program, so there is a no additional cost when new students, faculty, and staff sign up for the program.
Subaward Management and Subrecipient Monitoring
Manchester University will follow the Uniform Guidance 200.331 as it relates to subawards and subrecipients of federal funds.
Other
Confidential Compensation Information
Some grant budgets contain confidential salary or wage information. If you are involved with this type of grant, note that it is covered under the confidentiality agreement (on file with HR) that you signed when you started at Manchester, several years ago, or more recently. If you do not have an agreement on file and are involved with this type of grant, HR or the Office of Institutional Effectiveness will contact you to complete an agreement.
Cost Share from a Third Party
In rare cases, a Manchester University grant proposal may list cost share from another organization (note that unless otherwise specified, federal dollars cannot be used as a match on a federal grant). In these cases, the project lead should work with the Director of Grants and Sponsored Programs to make sure the University has a letter of commitment on file for the cost share from the third party prior to submission of the proposal. At the end of the project or after the cost share is provided, the University will also require a letter certifying that the cost share was provided, and that it originated from non-federal sources (unless otherwise specified).
Drug-Free Workplace
Manchester is compliant with the Drug-Free Workplace Act of 1988. See the employee handbook or student handbook for more details.
Equipment
In a grant budget, "equipment" is usually any single item over $5,000. If you are writing equipment into your budget, contact the Director of the Physical Plant and Grounds or Chief Technology Officer for more information.
Intellectual Property, Patents, Trademarks, and Copyrights
Please see Manchester University's Intellectual Property Policy for more information. When applicable to federal grants and sponsored programs, the university will appropriately allow federal use of copyrightable data, comply with the Bayh-Dole Act, redact proprietary information, and be compliant with related agency requirements for subcontractors.
Student Research Assistants
If you are planning to hire a research assistant through your grant, you must meet the Research Assistant/Internship requirements outlined by the Office of Career and Professional Development. Please contact Tish Kalita for more information.