Backup Code Policy

To support strong financial stewardship, regulatory compliance, and effective grant management, the Office of Sponsored Programs (OSP) has implemented a policy requiring all externally funded sponsored awards to maintain a designated backup account code.

Sponsored projects operate under strict sponsor, federal, and institutional guidelines governing how funds may be used. In some cases, expenses initially charged to a grant may later be determined to be unallowable, insufficiently documented, or outside the project’s authorized period. When this occurs, institutions must ensure these costs are promptly and appropriately transferred off the sponsored account.

The backup account requirement establishes a clear, proactive framework for managing these situations. By identifying an alternative funding source at the outset of an award, the university reduces administrative delays, ensures compliance with Uniform Guidance cost principles, and provides transparency and accountability across all stakeholders.

This policy applies to all Principal Investigators (PIs), department leadership, and budget managers responsible for sponsored projects and reflects the university’s commitment to responsible financial management of externally funded activities.

Code in Advance of Award

A Code in Advance of Award may be requested in special circumstances when an award is expected but the award letter has not yet been received.

The PI should consult OSP, which will assess the award’s risk level with the Associate Provost for Scholarship and Creative Activities (APSCA) and notify the PI whether the request can proceed.

If approved, a backup code must be identified through the PI’s Chair, Dean, Provost Office, or another supporting department. The code provider must agree to cover all charges if the grant does not materialize.

Conflicts of Interest

 describes Âé¶¹ÊÓÆµâ€™s policies regarding conflicts of interest in relation to sponsored projects. These policies ensure faculty and staff maintain credibility and integrity, preserving public trust in the university’s sponsored activities. These policies also meet certification requirements for funding agencies such as the NSF and PHS. If a conflict of interest arises, you must complete and submit the Disclosure Form and Questionnaire within 30 days to the Office of Sponsored Programs.

Effort Certification Types

Summer Salary Effort Certification: For compensation paid during the summer for faculty on 9-month appointments.

Grant-Funded Course Buyout Effort Certification: For grant-funded release from teaching responsibilities.

Ongoing Institutional Effort Certification: For employees whose regular institutional salary is partially charged to a sponsored project at a stable percentage over an extended period.

Variable Monthly Effort Certification: For employees whose grant-funded effort changes frequently or when a sponsor requires monthly certification.

Equipment on Grants

Purchasing equipment on grants requires compliance with sponsor requirements, university oversight processes, and responsible stewardship of sponsored funds. Equipment generally includes tangible property with a useful life greater than one year but it also includes technology purchases such as software and software licenses.

provides additional information.

Export Control Regulations

It is important that all persons involved in sponsored research/grants at Âé¶¹ÊÓÆµ understand the . Exports are regulated by several federal agencies. While the conduct, products, and results of fundamental research are generally excluded from federal export or “deemed exportâ€� controls, there may be some activities that would not be excluded and would require an export license. These laws impact research, foreign travel and the transfer of technology and information to certain countries. The laws also impose severe criminal and civil fines for noncompliance.

External Grant Authorization

This should be completed for any proposal prior to submission of application. Once you complete and submit the form, it will be routed for signatures and will be returned to the Office of Sponsored Programs. Directions for those submitting and those approving are below.

Financial Integrity

Administered internally, the Âé¶¹ÊÓÆµ Internal Audit Office is a resource that allows all Âé¶¹ÊÓÆµ faculty and staff to report workplace concerns dealing with moral, legal, and ethical standards in financial integrity or compliance.

Grant Record Retention

The grant record retention policy follows the Record Retention Policy under Âé¶¹ÊÓÆµâ€™s Office of Business, Finance & Technology. The policy states the retention period is the term of the grant award plus 7 years. The award letter should be used to determine the end date of the term of the grant.

Grant Related Travel

As part of our ongoing efforts to ensure compliance with grant guidelines and audit requirements, please be advised that effective immediately, all grant-related travel and meal receipts must include the following documentation:

An itemized hotel bill that includes the traveler’s name, hotel location, check-in and check-out dates, and a breakdown of charges (e.g., lodging, meals, parking).
An itemized restaurant receipt is also required when meals are charged to the hotel room.
An itemized and summary receipt showing the tip amount for all meal expenses (this can be handwritten).
Name(s) of the individual(s) who traveled or incurred the expenses.
Details of the expense (e.g., meals, lodging, transportation).
Relationship to the grant (e.g., PI, Co-PI, student, collaborator, etc.);
Purpose of the expense in relation to the grant activity (e.g., working lunch to discuss project milestones, student recruitment, conference networking, etc.)
This information should be either written directly on the receipt, included in an attached note, or entered as a comment in WORKS for each transaction. This level of detail is essential for audit readiness, accurate reporting and to maintain transparency and accountability under the terms of the grant.

Please note that Missing Receipt Affidavits are not an acceptable method for documenting grant expenditures. Any expenses submitted without proper receipts and documentation will be reallocated to your department or discretionary funds.

Indirect Cost Return Share Policy

Grants with indirect costs requested will be allocated to the project director(s), dean(s), and department chairs(s) as outlined in the 

Institutional Review Board

°Õ³ó±ðÌý assesses the risks and potential benefits of the research investigation, ascertains the appropriateness of the methods used to gain participant consent, and protects the rights and welfare of human participants.

Intellectual Property Policy

°Õ³ó±ðÌý describes Âé¶¹ÊÓÆµâ€™s commitment to providing an environment that supports the creation of intellectual property by faculty, staff, and students in the course of their research, teaching, and learning activities. As a matter of principle and practice, the University encourages all members of the Âé¶¹ÊÓÆµ community to publish without restriction the outcome of these activities in order to share openly and fully their findings and knowledge with colleagues and the public.

Miscellaneous Policies and Compliance

Misconduct in Research

 describes Âé¶¹ÊÓÆµâ€™s policy and procedures related to misconduct in scientific research. The purpose of this policy is to promote academic practices that prevent misconduct in research and to maintain standards to ensure ethical conduct of research and detection including appropriate handling of abuse of these standards. This policy is also the basis for specific certifications required by various federal agencies from those seeking external grant support.

NIH Public Access Policy

To advance science and improve human health, NIH makes the peer-reviewed articles it funds publicly available on PubMed Central. The requires scientists to submit final peer-reviewed journal manuscripts that arise from NIH funds to PubMed Central immediately upon acceptance for publication.

Open Access Resources

The library is available to help you across the entire research and publishing lifecycle. If you are getting started on a project, the library can help with topic development, finding and reviewing literature (including enhanced reviews like systematic reviews and meta-analyses), and reference management. When you’re ready to publish, we can help identify potential venues for your work, understand author rights and open publishing, and navigate APCs with our transformative agreements. Once your work is published, the library can enhance your research impact measurement and visualization projects, among many more services and tools for faculty, staff, and students.

Participant Gift Cards

Gift cards purchased with external funds must meet AAR, including this information:

Date Purchased
Purchased By
Type/Vendor
Amount
Card Serial #
Issued/Returned
Issued By
Purpose/Visit
Recipient Name/Study ID
Recipient Signature (if using a name)
If the total participation incentive is greater than $75 total over the full study a social security number will be required for payment.

Personnel Engagement- Employee vs Non-Employee Roles

This policy clarifies when individuals working on sponsored projects must be hired as employees rather than through contracts, vendors, or subawards. The policy is intended to ensure compliance with sponsor requirements, institutional research integrity standards, and University employment and conduct policies.

For more general information, see 

For help with deciding how to classify individuals, see 

Principal Investigator Eligibility

The following  provides institutional requirements for individuals who may serve as a PI on an externally sponsored project at Âé¶¹ÊÓÆµ. Exceptions to this policy may only be made with the prior approval of the Provost’s Office.

Proposal Submission Deadline Policy

OSP requires receipt of all final proposal documents by 8:00 a.m. five (5) business days prior to the sponsor’s submission deadline.

Proposals received after the five-business-day deadline may not receive a comprehensive review and will be subject to the late submission procedures outlined below.

OSP strongly recommends submitting proposals at least one business day before the sponsor’s published deadline whenever possible to reduce the risk of delays caused by technical or system-related issues.

Responsible Conduct in Research

Outlines a plan to comply with the America COMPETES Act, which requires institutions to provide training and oversight on ethical research practices for students and researchers involved in NSF and NIH funded research projects submitted after January 4, 2010. PIs should identify students hired for these projects, notify the Office of Sponsored Programs within a week, ensure they complete Responsible Conduct of Research (RCR) training, and submit the completed RCRT form within 60 days of employment.

Requesting a Grant P-Card

P-Cards specifically for grants can be requested from Purchasing in order to make grant-related purchases. Grant P-Cards differ in that purchases are reviewed by OSP to ensure that they meet the sponsor’s requirements and university front-end and audit compliance standards. elaborates on the steps required to setup a new grant P-card.

Requesting a Rebudget

External rebudget requests must be submitted for approval and require coordination with OSP. How, and whether, a rebudget can be requested depends on the sponsor and the award terms. No unbudgeted items should be purchased prior to rebudget approval.

Safety Policies and Compliance

Students Working Under Grants

Student workers must be paid hourly. Students are eligible to work up to 20 hours per week when classes are in session.

Students may be paid with a stipend only as “participants� participating in a grant sponsored program. This needs to be approved by OSP prior to making any determinations.

Subaward vs. Contractor vs. Vendor

Generally, the determination of the relationship with an entity is verified through the institutional review of the proposal narrative, budget justification, and other related proposal documents, as well as through discussions with key personnel prior to proposal submission.

When the relationship remains unclear, this form may provide assistance in making an accurate determination. None of these classifications apply to Âé¶¹ÊÓÆµ employees.

Subrecipient Monitoring

°Õ³ó±ðÌý outlines how to assess whether subrecipients can properly handle federal funds. Âé¶¹ÊÓÆµ must comply with the requirements of OMB federal regulation 2 CFR part 200, as well as with university policies and sponsor requirements. As the Prime Recipient, the University remains responsible for the management of funds and must comply with subrecipient monitoring requirements.