Researcher's Handbook

Section 4

University Policies and Guidelines

Centers and Institutes

The University of Florida has approximately 180 approved Centers and Institutes that have been established over the years to support and promote the academic mission of the University by enhancing its teaching and research functions, by facilitating interdisciplinary cooperation and provide campus research instrumentation facilities and services.

Faculty who are members of a Center or Institute may choose to submit their grant or contract applications via their home department or via their Center or Institute. (Note: Faculty in Engineering and IFAS should contact their own college for information regarding this matter.) If submitted via the Center, a project needs signatures from the department chair as well as the center director and respective dean. Centers and Institutes can receive a percentage of indirect cost returns from grants where center or Institute involvement occurs. The PI of the grant can make this declaration of idc distribution through the F&A Manager Tool at the time of award.

All Centers and Institute are required to submit electronically an Annual Report (July 1 - June 30) to the Board of Governors. The annual reporting is coordinated by UF’s Office of Institutional Planning and Research.

For complete information and guidelines about types of centers, responsibilities of centers and how to create a new Center or Institute please visit the Office of Research Center and Institutes Web site.

Classified Research

The University permits faculty the opportunity to engage in classified research. However, the primary mission of any major research university is to disseminate information and advance knowledge in all academic fields. University researchers should be as free as possible to seek new knowledge without constraints, and to share their findings with other scholars.

Before submitting a proposal to a sponsor to conduct classified research, the researcher must submit the proposal for review to the Vice President for Research. The Vice President will review the proposed research activity to determine if it is acceptable as appropriate academic research. Consideration will be given to the restrictions on publications, use of graduate students, the humanitarian nature of the research and the appropriateness of the scientific inquiry within a university environment.

The Vice President will make a recommendation to the President of the University, and the final decision of acceptance or rejection of the proposed research will be made at that level.

Consultant/Contractual Services on Grants

Consultant payments on sponsored projects must represent compensation to individuals who are independent of the university and who render independent services. Consultant payments may not be made by faculty to colleagues where an employer/employee relationship exists. Rather, in these situations colleagues should be compensated for services via the University personnel/payroll system according to percent effort of committed time; or donate their services as professional courtesy. If overload can be demonstrated for short-term teaching situations, permission must be obtained from the Division of Continuing Education (DOCE).

On the whole, it is expected that consulting needs can be satisfied from resources within the University community. When outside consulting services are needed for a grant or contract, all of these conditions must be met:

  • There must be evidence that the services provided are essential and cannot be provided by persons receiving salary support under the sponsored project.

  • There must be evidence that a selection process was employed to secure the most qualified person available.

  • There must be evidence that the charge is appropriate considering the qualifications of the consultant, normal charges, and the nature of the services rendered.

Cost Accounting Standards

To ensure compliance with the Federal government's Cost Accounting Standards (CAS) and OMB Circular A-21, section F.6.b, which establishes the principle that administrative and clerical salaries as well as other items such as office supplies, postage, local telephone costs, subscriptions and memberships (list not all inclusive) should normally be treated as indirect costs, the University of Florida established a policy for charging costs directly or indirectly to federally funded projects.

A copy of the University's CAS policy is posted at Charging Costs Directly or Indirectly to Federally Funded Sponsored Projects

  • Administrative and Clerical Salaries

  • Postage

  • Local Telephone Service

  • Cellular Phones and Service Plans

  • Office Supplies

  • Computer Supplies

  • Computers, Desktops, Laptops, Tablets, iPads and other computer related accessories, items, costing less than $5,000

  • General Purpose Software

  • Subscriptions

  • Memberships

To Direct Charge Administrative And Clerical Salaries

Exemptions to the University's CAS policy to direct charge administrative and clerical salaries will be permitted only when a "Major Project" can be clearly demonstrated and the individuals involved can be specifically identified with the project or activity. "Major Project" is defined as a project that requires an extensive amount of administrative or clerical support, which is significantly greater than the routine level of such services provided by academic departments.

  • The following examples are illustrative of what a Major Project or activity might be where direct charging of administrative or clerical staff salaries may be appropriate.
    1. Large, complex programs such as Designated Research Centers, Primate Centers, Program Projects, environmental research centers, engineering research centers, and other grants and contracts that entail assembling and managing teams of investigators from a number of institutions.
    2. Projects which involve extensive data accumulation, analysis and entry, surveying, tabulation, cataloging, searching literature, and reporting (such as epidemiological studies, clinical trials, and retrospective clinical records studies).
    3. Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences and seminars.
    4. Projects whose principal focus is the preparation and production of manuals and large reports, books and monographs (excluding routine progress and technical reports).
    5. Projects that is geographically inaccessible to normal departmental administrative services, such as research vessels, radio astronomy projects, and other research field sites that are remote from campus.
    6. Individual projects requiring project-specific database management; individualized graphics or manuscript preparation; human or animal protocols; and multiple project-related investigator coordination and communications.

To Direct Charge Other Costs

Exemptions to the University's CAS policy to direct charge any of the items listed below will be permitted only when the items being requested can be clearly demonstrated they are needed to advance the distinctive scientific, technical, and/or programmatic requirements of the work being funded. In the case of computers and cell phones, exemptions will be approved only where it can be shown that the usage of such item is primarily or solely devoted to the project, respectively

CAS and Non-Federal Sponsored Agreements

All costs including these normally indirect charges cited above may be direct charged to a non-federal sponsored agreement, unless the terms and conditions of the award specifically prohibit.

Cost Sharing

UF Cost Sharing Policy

It is the policy of the University that only mandatory cost sharing be submitted to sponsoring agencies. This policy does not preclude exceptions that may be judged appropriate under certain circumstances to leverage a project. Mandatory cost sharing requirements are usually defined by law, statute, agency regulations, or written in the application guidelines for a specific program. When there is mandatory cost sharing a copy of the request for proposal (RFP), regulations or guidelines must be submitted with the proposal along with a written commitment from the individual authorized to commit the resources. All voluntary committed cost sharing being offered to the sponsor in a proposal must be reviewed and committed in writing by the College Dean (without delegation) and forwarded with the proposal to the Division of Sponsored Research (DSR) for approval by authorized institutional representative.

New: The National Science Foundation prohibits voluntary cost sharing. If a Principal Investigator includes any voluntary cost sharing in a proposal being submitted to the NSF they run the risk that the proposal will be returned without review or declined. NSF only allows mandatory cost sharing when required by the NSF Program Announcement. See the NSF Cost Share Policy and Related NSF FAQs.

Cost Sharing Contributions to a Sponsored Project Must Meet All of the Following Criteria:

  1. Are verifiable from the University's records.

  2. Are necessary and reasonable for proper and efficient accomplishment of project or program objectives.

  3. Are not included as contributions for any other federal funded award.

  4. Are allowable under the applicable cost principles.

  5. Are not paid for by another federal funded award, unless authorized by federal statute to be used for cost sharing.

  6. Are provided for in the approved budget when required by the federal awarding agency.

  7. Unrecovered indirect costs may be included as part of cost sharing, unless prohibited by the sponsor.

  8. Conform to other provisions of OMB Circular A-110, part 215.53 as applicable..

  9. In-kind, third party contributions offered as cost sharing, require a commitment letter on company letterhead signed by an individual who is in a position to commit the in-kind contribution. After the fact reporting to the University will be necessary.

Mandatory, Voluntary Committed and Voluntary Uncommitted.

Mandatory cost sharing is required by statute or as condition of a specific solicitation/program announcement. It will normally appear in the award document from the agency. Mandatory cost sharing expenditures are tracked and accounted for and will be reported back to the sponsoring agency in a Financial Report.

Voluntary committed cost sharing is created if a proposal specifically includes cost sharing where none was required. If funded, the PI and the University are "committed" to providing the project with the indicated support. Voluntary committed cost sharing expenditures are not normally reported back to the sponsoring agency, however, it is still required that the University track and document these costs as they are subject to audit.

Voluntary uncommitted cost sharing represents contributions to a sponsored project that are made after the is received. For example the PI decides to spend more time on the grant than proposed and not charge the sponsor for the increased effort. Uncommitted cost sharing is not planned for and is not accounted for in the UF cost sharing system. Uncommitted cost sharing has no impact on proposal preparation.

At Time of Award

When the University accepts an award through Division of Sposored Research with mandatory or voluntary committed cost sharing, the University is making an agreement with the sponsor that is subject to audit. Division of Sposored Research will capture the mandatory or voluntary committed cost sharing amount on the NOA.

Contracts & Grants Accounting will enter the amount noted on the NOA into the University's cost sharing system and provide assistance with tracking and provide official reporting for such cost sharing to the sponsor.

The Principal Investigator and the Department staff have the responsibility of to make sure the cost sharing commitment is met and to provide the appropriate Contracts & Grants Accounting office the documentation necessary to track cost sharing commitments.

Employment of Relatives on Grants/Contracts

When faculty plan to employ a spouse, child or other close relative on government sponsored projects, the agency must be fully informed about the nature of the relationship and the outstanding qualifications which make the services particularly desirable. Furthermore, under University of Florida policy, no such related person can be employed unless the President or President's designee has determined prior to the appointment that there is no conflict of interest (6C1-7.40, Florida Administrative Code).

DSR Handbook Section 4: University Policies and Guidelines. Financial Conflict of Interest

Overview:

A university is made up of highly trained professionals, many of them of national and international reputation, representing a substantial reservoir of human resources. Services of this group are available to the various sectors of society for the mutual benefit of industry, government, the academic community and society at large. Outside activities are encouraged, provided they do not detract from the full and competent performance of institutional obligations. In light of this, investigators whose activities are paid from grants or contracts should be aware of potential conflict of interest situations.

The University's policy on conflict of interest is explained in detail in the University's Guidelines, Policies, and Procedures on Conflict of Interest and Outside Activities, including Financial Interests.

The federal regulations require that the university manage, reduce, or eliminate any actual or potential conflicts of interest that may be presented by outside activities and financial interests of persons involved in sponsored projects funded by the Public Health Service (PHS) including the National Institutes of Health (NIH), the National Science Foundation (NSF), and the American Heart Association (AHA). The primary purpose of the regulations is to prevent bias in the design, conduct, or reporting of research projects. The PHS requires all investigators complete training prior to engaging in research related to any PHS-funded grant or contract and at least every four years, and immediately under the designated circumstances:

  1. Institutional FCOI policies change in a manner that affects Investigator requirements;
  2. An Investigator is new to an Institution; or
  3. An Institution finds an Investigator noncompliant with Institution's FCOI policy or management plan. Information about the NIH implementation of the policy is available through the NIH FCOI page.

In addition, the state of Florida Code of Ethics sets forth standards of conduct for state employees in order to ensure that "public officials be independent and impartial and that public office not be used for private gain other than the remuneration provided by law." To that end, the Code highlights activities that might be of importance to the University of Florida. These are outlined in section IV of the University's "Guidelines, Policies, and Procedures on Conflict of Interest and Outside Activities, including Financial Interests". and include activities such as misuse of position,, doing business with the University, and conflicting employment and contractual relationships.

Definitions

Investigator
The principal investigator, co-investigator, or any other individual responsible for the design, conduct, or reporting of sponsored activities. For the purpose of determining a Significant Financial Interest, an "investigator" also includes an employee's spouse and dependent children.
Outside Activity (OA)
"[A]ll outside employment, compensated activity, and continuing business activity (including managerial interests or managerial positions) …Uncompensated activities and financial interests (including financial interests of an employee's spouse and children)…if they fall within any of the categories described below." Per University of Florida policy, the following outside activities and financial interests must be reported and approved prior to engaging in the activity:
  • Outside activities in which there is more than an incidental use of university facilities, equipment, and/or services.
  • Outside activities in which a university student or other university employee is directly or indirectly supervised by the employee if the employee in any way supervises or evaluates the student or other employee at the university.
  • Management, employment, consulting, and contractual activities with, or ownership interests in, a business entity (or state agency) which does business with the university. In the case of material financial and managerial interests, the information required extends to the spouse and children of the employee, and for managerial interests, to relatives.
  • Management, employment, consulting, and other contractual activities with, or ownership interest in, a business entity which competes with the university.
  • Candidacy for public office.
  • Required use of books, supplies, equipment, or other instructional resources at the University of Florida when they are created or published by the employee or by an entity in which the employee has a financial interest.
  • Professional compensated activities, including, but not limited to, consulting, teaching at another institution, participating in an activity in which an honorarium in excess of travel expenses is to be received, and employment as an expert witness.
  • Business activities, including service on the board of directors or other management interests or position, with regard to a business entity with activities in the same discipline or field in which the faculty or staff member is employed.
  • Any employment, contractual relationship, or financial interests of the employee which may create a continuing or recurring conflict between the employee's interests and the performance of the employee's public responsibilities and obligations, including time commitments. This includes any outside activity in which the employee is required to waive rights to intellectual property and any outside activity or financial interest with a business entity which supports the employee's research or training program at the University.
  • Outside activities and financial interests required to be reported under federal contract and grant regulations.
Significant Financial Interest (SFI)
Is defined by each sponsor as:
Conflict of Interest (COI) or Financial Conflict of Interest (FCOI)
Is defined by the University of Florida policy as "any situation in which a person serves or represents two distinct entities (or persons) or must choose between two conflicting interests… encompasses situations in which a person has actually neglected or breached a duty to one entity to the benefit of another, situations in which a person has used his or her position with one entity to advance personal gain or the gain of another entity, and situations in which there is a potential for breaching a duty to one entity."

Process

  1. Reporting of Outside Activities and Significant Financial Interests
    Is an ongoing activity. A report must be made annually and updated any time there aret changes throughout the year.
  2. Review of OA and SFI disclosures
    The dean or unit director (or designee) and the Institutional Official (or designee) are responsible for reviewing each disclosure to determine if there is a conflict of interest. Under the federal regulations, if a Significant Financial Interest may directly and significantly affect the design, conduct, or reporting of the research a conflict exists. The university, through the department chair and dean or director and the Division of Sponsored Research, is required to manage, reduce or eliminate the conflict. Conditions that might be imposed in such cases include public disclosure of the conflict, modification of the research design, or monitoring of the research by independent reviewers. If adequate measures are not feasible, the employee may have to discontinue the compensated activities or divest him or herself of the financial interest, or discontinue the research. The employee must abide by the conditions under which the sponsored activity is permitted.

    All investigators on PHS, NSF and AHA proposals must fill out and sign a Disclosure of Financial Conflict of Interest form before the proposal is submitted by DSR to these agencies. The form should be part of the package submitted for review and approval through the usual departmental, college and unit approval process. It is the principal investigator's responsibility to ensure that Disclosure of Significant Financial Conflict of Interest form for all investigators (including co-principal investigators and other employees responsible for the design, conduct, and reporting of the research) are obtained on a timely basis in order to meet proposal application deadlines.

  3. Managing conflicts of Interest
    Regardless of whether or not a conflict exists, the proposal will be submitted to the agency. The form is kept on file in DSR and is not sent to the agency. However, an institutional certification that the University's policy is active and in compliance with the federal regulation will be transmitted to the agency. Should the proposal be funded, the University will review the conflict and determine the appropriate management or disposition of the sponsored work and outside activity.

Please contact the Assistant Director for Compliance, Office of Research Compliance, if you have questions or require assistance.

Indirect Cost Policy

The indirect cost rate is negotiated with the U.S. Department of Health and Human Services (UF’s cognizant audit agency) and reflects the rate of reimbursement for real, audited, facilities and administration costs incurred in the conduct of research. Included among these costs are: depreciation and use allowance costs of buildings and equipment, maintenance and repairs, janitorial services and utilities, hazardous waste disposal; libraries; and general administrative costs such as sponsored programs administration, departmental and general administration (accounting, purchasing, legal services, personnel compliance). These costs are "indirect", or general research support costs, because they are not included in the "direct" portion of the budget allocated for specific project research and typically cannot be ascribed to an individual project. They relate to the conduct of research in general, regardless of the source of funding, and therefore must be applied to all grants and contracts .

Effective July 1, 1995, all grants, contracts and agreements accepted from any sponsor to fund University research must be charged the full on-campus and off-campus indirect cost rates established for federal awards (with the exception of clinical trials which have a standard indirect cost rate of 25% of total direct costs [TDC]).

It is recognized that some private foundations, and even some programs of federal and state funding agencies, have an established policy that restricts the rate of indirect cost payment (e.g., research costs associated with competitive grants of the USDA are reimbursed at 14% rate; NIH training grants at 8%, Florida municipalities, Counties and Water Management Districts at 25%). Some other organizations will pay no indirect costs to an institution. The UF can accept funds from these organizations as long as their written policy is provided to the DSR at the time a proposal or application is submitted and the University agrees to cost sharing.

Several faculty have long standing research awards with sponsors that were negotiated initially with a lower indirect cost rate than the standard rate. In these cases, the Director or Assistant Director of DSR will work with the funding agency, faculty member, department or cognizant college office in the interim to identify a source of cost sharing that can be acknowledged in the proposal as a means of reducing the administrative component of the award by, for example, lump sum payments using a short-form letter of agreement. Also, it will be expected that over a reasonable time period, these rates will be increased and brought in line with the prevailing indirect cost rates.

Any modification of the university's indirect cost rate on a proposal or application must be approved by the Director, Associate Director, or Assistant Director of DSR before the proposal/application is submitted.A request to modify the rate must be agreed to by the relevant college dean. This applies to all awards. The standard UF indirect cost distribution percentages will hold for those awards accompanied by full indirect cost reimbursement. All indirect costs that are waived will be recovered from the share that is distributed to the Principal Investigator, Department Chair and Dean.

Click here for the University's Indirect Cost Rates.

Indirect Cost Return and Use Policy

Florida Statute 1004.22 allows each University within the State University System to retain collected overhead or indirect costs from grants and contracts. These funds are to be used to operate and support the sponsored research program of that particular University. The University of Florida's policy which effectuates the purpose of this section of statute follows.

Indirect cost return and use policy

  1. Each year the Office of the Vice President for Research returns a portion of the recovered indirect costs to principal investigators, department chairs, directors of certain authorized centers, if appropriate. If any recovered indirect costs still remain after the allocation of certain central costs and the cost for operating and supporting the sponsored research program, then an additional return is made to the college deans.

  2. The University of Florida Research Foundation (UFRF) applies this policy to all awards administered through UFRF, except that the college deans' returns are set at a maximum of 7.5%.

  3. This return of indirect costs generally occurs in the fall of each year and is based upon the indirect costs collected from grants and contracts during the preceding fiscal year (July 1 - June 30). The proportion of indirect costs returned to principal investigators is currently 10% of the collected indirect costs from the principal investigator's grants and contracts.

  4. All indirect cost funds collected and returned under this policy must be used for expenditures that support research or sponsored training programs at the University of Florida.

Institutional Prior Approval

The University of Florida has established an institutional prior approval system required by federal agencies and authorized by the Federal Demonstration Partnership (FDP). Under this system, authorized officials in the Office of Research provide prior approval for some pre-award costs and post-award changes on sponsored projects as permitted under FDP and other sponsoring agency guidelines. In short, approvals for certain actions can be granted within the university rather than the participating agency.

Institutional Review and Signature

Certain administrators in the Office of Research have been authorized by the University President to enter into research and training agreements on behalf of the University. At the proposal stage, this signature, along with those of other appropriate University officials (i.e., principal and co-principal investigators, department chair, dean/director, and vice president, if necessary) indicates the willingness and capability of the University to guarantee proper accountability and administration of funds. A PI's signature alone on grants and other agreements does not commit the University's resources and cannot be accepted in lieu of the authorized institutional officials in the Office of Research.

All proposals must have institutional review and appropriate signatures via the DSR-1 form (also known as the "Signature Page"). Letters to sponsors requesting changes to an awarded grant or contract must be countersigned in the Office of Research but do not require the DSR-1 form. Such changes include no-cost extensions, rebudgeting, transfer of grants to new institutions, etc.

UF Grant Rebudgeting Controls (KK Level 3 and 5)

Grants and Contracts accepted by DSR (federal or non- federal) where terms of the agreement do not impose re-budgeting restrictions, the "Budget Checking" control will be set at KK level 3. Budget control level 3 allows spending at a direct cost level without the requirement to re-budget funds.

The goal of level 3 Budget Control is to minimize re-budgeting and allow investigators the ability to make timely expenditures needed to advance their projects. For example, if you were invited to present your research results at an international conference which you did not explicitly budget for you may attend and charge the grant award without the need to rebudget funds.

Budget Control will be assigned by the Division of Sponsored Research (DSR) and issued on the NOA (Notice of Award) and recorded into the accounting system by the respective Contracts and Grants Accounting Offices.

Examples of awards that would be assigned a Budget Control Level 3 are as follows:

  • Federal Grants under FDP Terms

  • Federal Grants under Expanded Authority Terms

  • Federal Grants under Standard Research Terms

  • Clinical Trials

  • Fixed Price Agreements (federal and non-federal)

  • Multiple Sponsor Projects

  • Miscellaneous Donor Projects

Budget Control level 5 will be assigned to awards (federal or non-federal) where terms of the agreement impose re-budgeting restrictions. Budget Control level 5 will require re-budgeting approvals be obtained from the Sponsor or the Division of Sponsored Research, as appropriate, prior to allowing grant funds be used for the expenditure in question.

Upon approval from the Sponsor or DSR, The Department's Grant Administrator will need submit a Budget Transfer Form to C&G Accounting form with back-up approving the rebudgeting action.

Regardless of the assigned budget control level, grant and contract funds must always be used in support of allowable costs per the terms of the award.

Release Time

All personnel working on sponsored projects must be relieved of their regular duties by the department chair or other responsible individual for the period of time and percentage of effort devoted to the sponsored project. If such personnel continue to be paid from departmental funds while working on a sponsored project, the portion of their salary and fringe related to the project represents cost sharing to the project. However, if personnel are appointed to and paid from the sponsored project, "salary savings" occur within the departmental budget and can be released for other purposes within the University, subject to administrative approval.

Research Misconduct

It is the policy of the University that each individual faculty, staff member and student is expected to maintain high ethical standards in the conduct and reporting of his/her scientific and scholarly research. Faculty, staff, and students have responsibilities for ethical conduct in research not only to the University, but also to the community at large, to the academic community, and to private and public institutions sponsoring the research activities.

Research Misconduct is defined as fabrication, falsification, or plagiarism in proposing, performing, or reviewing research or reporting the results. It does not include honest error or honest differences in interpretations or judgments of data. It also does not include authorship or credit disputes.

Should alleged incidents of misconduct in research occur, reporting of such possible violations is a shared responsibility, and it is the duty of the faculty, staff members and students to respond in a fitting manner to resolve issues arising from such alleged misconduct. Such an allegation should be brought to the administrative officer to whom the accused reports (e.g., supervisor, department chair, dean or director). The procedures for reporting misconduct may vary depending on the type, seriousness, and technical nature of the alleged misconduct.

Click here for the full policy or call DSR's Program Information Office (392-4804).