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ORGANIZATIONAL PRIOR APPROVAL SYSTEM
REQUIREMENTS FOR NATIONAL SCIENCE FOUNDATION (NSF)
RESEARCH GRANTS
REFERENCES AND RELATED POLICIES
NSF Grant Policy Manual, Revised April, 1983
NSF Grant General Conditions (F.L. 200, October 1987)
UCSD Policy and Procedure Manual (PPM)
150-65 | Request for Approval Procedures under Organizational/Institutional
Prior Approval Systems (OPAS/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 the
Organizational Prior Approval System (OPAS)
to expend funds under National Science Foundation (NSF) grants.
POLICY
Effective October 1, 1987, the NSF revised its Grant General Conditions,
NSF F.L. 200, which allows grantee institutions to expend monies and
rebudget certain funds in their research grants without referral to
NSF for prior approval.
Principal Investigators or Department Administrators
should request assistance from the
OCGA concerning any proposed NSF related budget deviation not covered by
the NSF Grant Policy Manual or by this issuance.
PROCEDURES
Preparation of Forms
If the Principal Investigator (PI) has the authority
to rebudget funds, in accordance with Section VII. of this issuance,
a Budget Adjustment Journal is all that is required.
This should be prepared according to instructions contained in PPM 380-4.
If authority to expend or rebudget funds must be obtained through
the Organizational Prior Approval System (OPAS), the
Principal Investigator then prepares a Request for Approval
Under Organizational 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, the Purchase Order Requisition and an Equipment
Screening Certification form (if necessary) must also
be attached. 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.
If NSF prior approval is required, the PI must prepare a
letter to either of the
NSF Officers, as shown on the ``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 the agency.
When approval is received, the PI should prepare and submit a Budget
Adjustment Journal and a copy of the NSF approval letter in accordance
with PPM 380-4.
The Budget Adjustment Journal should be forwarded directly to the
Manager, Extramural Funds Accounting.
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:
A brief description of the proposed action;
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);
Explanation for rebudgeting 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.
For requests for travel or the purchase of equipment, the
following specific areas must be addressed:
Travel
Itemization of cost i.e., airfare, per diem, registration fee, etc.;
Purpose, date, and place of travel;
Relationship to research;
Relationship of the traveler(s) to the research project;
A statement of compliance with Federal regulations regarding the use
of U.S. Flag Air Carriers (foreign travel only); and
A copy of the travel itinerary or meeting invitation (foreign travel
only).
Equipment
Description of equipment - if more than one item
requested, itemize the description and cost of
each;
Justification for the request;
How the proposed purchase impacts the operation of the
project as outlined in the original proposal; and
Requests for purchase of equipment over $1000 must include a
completed copy of the Equipment Screening Certificate.
It is of utmost importance that special attention be given to the
above required justification(s) as it is the most critical element
of the prior approval request.
RESPONSIBILITIES
MSO
Receives request from PI, reviews for administrative purposes,
initials and forwards to Department Chair.
Department Chair
Reviews and approves/disapproves the request for scientific
propriety, project relevance and effective utilization of
institutional resources.
Forwards the approved package to the Contract and Grant Officer,
OCGA.
Contract and Grant Officer, OCGA
Upon receipt by OCGA, the Contract and Grant Officer will review the
request for
consistency with University and NSF 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 for further action.
Manager, Accounting Office/Extramural Funds Division
The Manager reviews the Budget Adjustment Journal for conformance
with University and NSF financial regulations and returns a copy to the
departmental business office.
Should additional information be required, appropriate departmental
administrators will be contacted.
ORGANIZATIONAL PRIOR APPROVAL SYSTEM REQUIREMENTS UNDER NSF
RESEARCH
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CLASSIFICTION |
AUTHORITY |
| 1. |
Alterations and Renovations
A. Expenditures less than $10,000
B. Expenditures over $10,000 which are considered construction, as opposed
to alterations and renovations |
UCSD Contract & Grant Officer
NSF via OCGA for endorsement |
| 2. |
Capital Expenditures for land or Buildings |
NSF via OCGA for endorsement |
| 3. |
Changes in Objectives or Scope |
NSF via OCGA for endorsement |
| 4. |
Changes of Principle Investigator or level of Principle Investigator
Effort
A change of Principle Investigator (PI) is defined as an anticipated
absence for more than 3 months during and continuous period without the
active direction of an approved PI. The request must be submitted at least
thirty (30) days before the departure of the approved PI.
A change in the level of effort is defined as a substantial increase
or decrease in the PI's effort which affects the project/proposal as approved
or the successful progress/completion of the project. |
NSF via OCGA for endorsement |
| 5. |
Consultants
The daily consultant rate paid to an individual not employed by the University
may not exceed the maximum rate paid to a GS-18 Federal employee.
(NOTE: University Academic personnel who desire to act as professional consultants
in connection with research projects under the auspices of the University
should contact the Academic Personnel Office to determine allowability in
accordance with University policy, conflict of interest and other related
policies.)
|
UCSD Contract & Grants Officer |
| 6. |
Contractual Third Party Costs
This classification includes subcontracts and consortium agreements. |
UCSD Contract & Grant Officer |
| 7. |
Equipment
Equipment (including sales tax)-is defined as tangible nonexpendable
property with a unit cost of $500 or more and a useful life of two years
or more.
A. General Purpose - General Purpose Equipment is not used primarily
or for endorsement exclusively for scientific purposes.
B. General Purpose used as Special Purpose - General Purpose Equipment
is used primarily or exclusively for scientific purposes.
C. Special Purpose
1) Under $1,000 per item
2) Over $1,000 per item
(each item over $1,000 requires screening) |
NSF via OCGA for endorsement
UCSD Contract & Grant Officer
Principal Investigator UCSD Contract & Grant Officer |
| 8. |
No-Cost Extensions
One time only for up to six (6) months beyond flexibility period. The
justification for the request will include a brief summary of progress to
date, funds remaining and their future use and plans for completion of project
for which extension is requested. The fact that funds remain upon expiration
is not in itself sufficient justification for an extension. The request
with justification must be submitted no later than 30 days prior to the
grant period expiration date. |
UCSD Contract & Grant Officer with written notification to the
NSF Grant Officer |
| 9. |
Personnel Costs |
Principle Investigator |
| 10. |
Pre-Award Costs
Up to 90 days prior to the effective date of award. Form FO2141, Request
for Advance Approval to Establish Accounts & Incur Expenses, is
required for this action and must be approved prior to incurrence of the
cost. |
UCSD Contract & Grant Officer |
| 11. |
Related Projects
A. Provided no significant change is made in the objectives or scope
of an individual NSF grant, allowable grant costs may be committed or otherwise
expended between two or more active NSF grants held by the same Principal
Investigator during the grant periods. Sufficient documentation shall accompany
the Principal Investigator's request to enable OPAS to determine that the
projects have a scientific or technical commonality.
B.Other Uses of Relatedness (e.g, collaboration of two Principal Investigators
with separate projects) |
UCSD Contract & Grant Officer
NSF via OCGA for endorsement |
| 12. |
Retoactive Approval
NSF allows retroactive approval only under "unusual circumstances"and
requires substantially more justification. Specifically, such approvals
require a detailed explanantion as to why prior approval was not obtained
on a timely basis. |
NSF via OCGA for endorsement |
| 13. |
Travel
Must be directly related to and show promise of enhancing the capability
of carrying out the sponsored research objectives.
A. Domestic
1) Cumulative expenditures less than $500 or 25% over the amount budgeted,
whichever is greater
2) Cumulative expenditures which exceed $500 or 25% over the amount budgeted,
whichever is greater.
B. Foreign
Foreign travel is defined as any travel outside the U.S. (50 states)
and Canada.
1) Each trip (exclusive of solicited travel approved by award)
2) Dependent Travel, when
a) Individual scientist is a key person who is essential to the research
on a full-time basis.
b) Individual scientist's residence is away from home and in a foreign
country for a continuous period of six months or more and is essential for
the effective performance of the project.
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Principal Investigator
UCSD Contract & Grant Officer
UCSD Contract & Grant Officer
UCSD Contract & Grant Officer |
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