1.   PHS Grants Policy Statement, Revised 4/1/84

2.   UCSD Policy and Procedure Manual (PPM)

   150-65 Request for Approval Procedures under Organizational Prior Approval System (OPAS) and Institutional Prior Approval System (IPAS)

   380-4 Budget Adjustment Journal Preparation Procedures

   380-5 Budget Adjustments to Extramural Funds (Federal, State, Local Government and Private Contracts, Grants and Donations)

   522-2 Equipment Screening

   523-10.1 Independent Consultants

INTRODUCTION

The purpose of this policy is to outline the procedure to follow in completing the Request for Approval Under Institutional Prior Approval System (IPAS) requests to expend funds under Public Health Service (PHS) grants.

POLICY

Effective July 1, 1986, the Public Health Service (PHS) revised its policy to allow grantee institutions to expend monies and rebudget certain funds in their research and training grants without referral to PHS. This replaced former PHS policy of requiring the prior approval of PHS officials for these actions.

Principal Investigators or Department Administrators should request assistance from the OCGA concerning any proposed PHS related budget deviation not covered by the revised PHS Grants Policy Statement or by this issuance.

PROCEDURE

1. Preparation of Forms

   1. If the Principal Investigator (PI) has authority in accordance with Section VI. of this issuance to rebudget funds, a Budget Adjustment Journal is all that is required. This should be prepared according to instructions contained in PPM 380-4.

   2. If authority to expend or rebudget funds must be obtained through the Institutional Prior Approval System (IPAS), the Principal Investigator then prepares and submits a Request for Approval Under Institutional Prior Approval System (See PPM 150-65) and a Budget Adjustment Journal (See PPM 380-4). When the Principal Investigator is requesting approval to purchase an item of equipment, a Purchase Order Requisition and an Equipment Screening Certification form (if necessary) must also be attached to the package. The entire package should then be forwarded via the MSO to the Department Chair and the Contract and Grant Officer, OCGA, for review and approval.

   3. If PHS' prior approval is required, the PI must prepare a letter to the appropriate PHS Grants officer whose name is shown on the ``Notice of Grant Award'' specifying the nature of the request, its relation to the purpose of the grant, the amounts involved, and the budget categories affected. The letter should be forwarded to the UCSD Office of Contract and Grant Administration for countersignature and submission to PHS. When approval is received, the PI should prepare and submit a Budget Adjustment Journal and a copy of the PHS approval letter in accordance with PPM 380-4. The Budget Adjustment Journal should be forwarded directly to the Manager, Extramural Funds Accounting.

2. Justification

   The Principal Investigator is responsible for providing a brief but comprehensive explanation/justification describing the scientific, technical or administrative reason(s) for all requests. As a minimum, the justification must address the following:

   1. A brief description of the proposed action;

   2. Scientific, technical or administrative justification for the action. (Include a statement as to the scientific benefit which will accrue to the project as a result of the request);

   3. Explanation for rebudgeting of more than 10% from any category, why the funds are available (specify budget categories, if applicable) and how the lack of funds in this category impacts the continuous operation of the project as outlined in the original proposal.

   4. For requests for travel or the purchase of equipment the following specific areas must be addressed:

      1. Travel

         1. Itemization of cost i.e., airfare, per diem, registration fee, etc.;

         2. Purpose, place, and date(s) of travel;

         3. Relationship to research;

         4. Relationship of the traveler(s) to the research project.

         5. A statement of compliance with Federal regulations regarding the use of U.S. Flag Air carriers (foreign travel only).

      2. Equipment

         1. Description of equipment - If more than one item requested, itemize the description and cost of each;

         2. Justification for the request;

         3. How the proposed purchase impacts the operation of the project as outlined in the original proposal;

         4. The effect the rebudgeting of more than 10% between categories of the approved budget has on the scope of work or objective of the project;

         5. Requests for purchase of equipment over $1,000 must include a completed copy of the Equipment Screening Certification.

   It is of utmost importance that special attention be given to the above required justification(s) which is the most critical element of the prior approval request. The justification not only provides the basis for the required institutional approval, but the established criteria must substantively be answerable to any future questions which may arise, whether UC, agency, or audit.

RESPONSIBILITIES

1. MSO

   Receives request from PI, reviews for administrative purposes, initials and forwards to Department Chair.

2. Departments Chair

   1. Reviews and approves/disapproves the Request for Approval Under Institutional Prior Approval System for scientific propriety, project relevance and effective utilization of institutional resources.

   2. Forwards the approved package to the Contract and Grant Officer, OCGA.

3. Contract and Grant Officer, OCGA

   Upon receipt by OCGA, the Contract and Grant Officer will review the request for consistency with University and PHS policy. When fully approved, the original copy of the request is forwarded to the Manager, Extramural Funds Accounting, a copy is retained by OCGA and the additional copies forwarded to the Principal Investigator, Departmental MSO and Purchasing Division, as applicable. If any questions arise during the review, the OCGA will consult with the appropriate departmental personnel. Should the request be disapproved an explanation will be forwarded to the Principal Investigator for informational purposes or further action.

4. Manager, accounting Office / Extramural Funds Division

   The Manager reviews the Budget Adjustment Journal for conformance with University and PHS financial regulations and a copy returned to the departmental business office. Should additional information be required, appropriate departmental administrators will be contacted.

INSTITUTIONAL PRIOR APPROVAL SYSTEM REQUIREMENTS UNDER PHS RESEARCH AND TRAINING GRANTS