Recognizing that PIs are responsible for most aspects of sponsored research, including compliance with institutional policy and federal regulation, Sponsored Programs Administration (SPA), has developed a series of Sponsored Programs Administration Guidance Documents to familiarize PIs with essential administration and compliance topics. Each document will include a brief explanation of the topic, guidance on how to comply, and web links to campus resources and additional information.
This Quick Guide is intended to provide answers to common questions about grant and contract administration. While this Guide is designed to assist you in managing your sponsored projects, please note it is neither comprehensive nor exhaustive. For specific questions, please review the applicable policy in its entirety, and contact the appropriate offices as needed.
The Knowledge Base contains forms, instruction and training material, minutes, policies, tools and other resources to support your research efforts by topic area.
Sponsored Programs Administration
Service Bldg., 2nd Floor
51 College Road
Durham, NH 03824
Sponsored Programs Administration (SPA) helps prepare and is the authorized UNH entity to submit proposals to external sponsors. SPA negotiates and accepts awards on behalf of UNH;...
A significant majority of UNHs sponsored funding comes from the federal government. As steward of the taxpayer’s money, the government, through the Office of Management and Budget (OMB), has issued principles for determining costs allocable to research and administrative regulations to augment these principles.
The University uses the following federal requirements in establishing its procedures for administering all awards for research and other sponsored agreements:
- OMB Uniform Guidance, Subpart E (Cost Principles)**
- Office of Management & Budget (OMB) A-21: Cost Principles for Educational Institutions
- OMB Circular A-110: Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations
- OMB Circular A-133 : Audits of States, Local Governments, and Non-Profit Organizations
- Federal Acquisition Regulations (FAR): Contracting requirements
The provisions of the OMB Circulars and the FAR are applicable to all agencies that award federal funds. UNH has translated these principles into its policies.
UNH and its principal investigators are jointly responsible for providing appropriate and compliant stewardship of sponsored funds and must comply with federal cost principles.
UNH follows four cost principles. The cost must be (1) allowable, (2) allocable, (3) reasonable, and (4) consistent. Though these principles may change depending on the project, they must be used to determine whether the costs are appropriate for a sponsored project.
1. A cost is allowable when:
- When it serves a business purpose, including instruction, research, and public service.
- It is permissible according to UNH policy and federal regulations, regardless of whether it is a sponsored project.
- It is permissible for a sponsored project according to the terms and conditions of the sponsored agreement.
2. A cost is allocable:
- When the cost provides “benefit” to the project
3. A cost is reasonable when:
- A prudent person would purchase the item at that price.
- The cost is necessary for the performance of the activity
- Incurrence of the cost is consistent with established University policies and practices
4. A cost is consistent when:
- Like expenses are treated in the same manner under like circumstances.
- Consistency means that sponsors pay for costs either as a direct charge or as a Facilities and Administrative (F&A) cost, not both directly and indirectly. The University establishes policies that, if followed, ensure consistency.
OMB Uniform Guidance
In addition to the Cost principals listed above a cost is allowable when:
- The cost cannot be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period.
- The cost is adequately documented.
Both activities and transactions could be considered unallowable due to regulations put in place by the federal government or other sponsor. Unallowable costs may also be identified in the specific terms and conditions of a sponsored project. These can be more specific than those outlined in OMB Uniform Guidance.
For example, if a sponsor specifies that international travel costs cannot be charged to a particular project, then those costs may not be charged to that project, even though general UNH and federal regulations may allow them.
Unallowable activities include:
- Alumni activities
- Organized fundraising
- Commencement and Convocation
- General public relations activities
- Student activities such as intramural activities and student clubs
- Managing investments solely to enhance income
- Prosecuting claims against the federal government
- Defending or prosecuting certain criminal, civil, or administrative proceedings
- Housing and personal living expenses of University officers
Unallowable transactions include:
- Advertising (only certain types are allowable)
- Alcoholic beverages
- Fundraising or lobbying costs
- Fines and penalties
- Memorabilia or promotional materials
- Relocation costs if employee resigns within 12 months
- Certain recruitment costs, such as color advertising
- Certain travel costs, such as first-class travel
- Cash donations to other parties, such as donations to other universities
- Interest payments
- Membership in civic, community, and social organizations or in dining and country clubs
- Goods or services for the personal use of employees, including automobiles
- Insurance against defects in UNH’s materials or workmanship
Grant and Contract Administrators in SPA are available to assist in the interpretation and application of University policy, OMB Uniform Guidance and the OMB Circular A-21 Cost Principles.
**Please note that Federal Awards (including flow-down awards) issued on or after 12/26/2014 are subject to 2 CFR 200 - Uniform Guidance.
Guidance for direct charging administrative costs to sponsored programs.
Administrative or clerical staff must be integral to a project in order to be direct charged to a federal award and must be budgeted and justified in the proposal or have prior written sponsor approval. Under the Uniform Guidance (section 200.413), a project no longer needs to be identified as “major” to include administrative salary, but in general such expenses should be treated as indirect (F&A) costs.
To be integral to the project, the administrative activity should be:
- essential or vital to the project, and described accordingly in the justification;
- budgeted at a percentage of a person-month that reflects that essential nature (a minimum of 10% FTE);
- performed by individuals specifically identified with the project or activity; and
- costs that are not also recovered as indirect costs.
For non-federally sponsored projects, administrative or clerical staff may be direct charged provided they benefit the project and follow those sponsors’ requirements for the award.
Grant and Contract Administrators in SPA are available to assist in the interpretation and application of University policy, Uniform Guidance and the OMB Circular A-21 Cost Principles.
Awards issued on or after 12/26/2014 are subject to 2 CFR 200 - Uniform Guidance
Guidance to help determine if revenue is a gift or sponsored program.
There are numerous ways in which private, programmatic support is offered to and received at the University of New Hampshire, including gifts, grants and contracts. Each varies in how revenue should be accepted and administered, and what the sponsor should reasonably expect to receive in return for providing support.
Why it’s important
Proper classification and processing of gifts, grants, and contracts assures the University's ability to be an appropriate steward, comply with contractual requirements and grant terms specified by a sponsor/donor, meet reporting requirements, and recover its direct and indirect costs.
How to comply
The checklist How to Determine if Revenue is a Gift or Sponsored Program is intended to assist in establishing whether an award is a gift, which should be administered by the UNH Foundation, or a sponsored program, which should be administered by the Sponsored Programs Administration office. The terms “gift” and “grant” are often considered equivalent, which creates confusion in determining how an award should be managed. Use of the term “grant” by a sponsor/donor does not necessarily mean that the award is a sponsored program. The terms of the award—how the money is to be used—determine whether an award is a gift or a sponsored program.
Classification and processing of awards can be complex and requires the exercise of informed judgment; SPA and UNH Foundation Staff are available to assist in the interpretation of how an award should be administered. Final decisions are at the discretion of the Vice President of Advancement and the Senior Vice Provost for Research.
UNH is pleased to accept unrestricted gifts to support the general research of a particular College or Principal Investigator. Gifts provided for general research support are not subject to facilities and administrative costs (F&A, or “indirect cost”) charges. The original gift award letter from the donor and the accompanying check should be forwarded to Diane Schaefer, Director of Foundation Relations, UNH Foundation/University Advancement, (603) 862-4483.
Solicitation of philanthropic gifts for non-research activities and the processing of equipment gifts and other gifts for research programs are coordinated through the UNH Foundation. All Principal Investigator-initiated research proposals in response to a program announcement or Request for Proposal should be processed through the Sponsored Programs Administration office.
Subrecipient vs Contractor Agreement
Under the OMB Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, which went into effect on 12/16/2014, the term “vendor” was replaced with “contractor.” The terms vendor and contractor substantially have the same meaning and may be used interchangeably in other guidance. For consistency purposes, when UNH provides funds from a federal award to a non-federal entity, the non-federal entity receiving these funds is classified as a subrecipient or a contractor based on the nature of the agreement and the criteria in 2 CFR §200.330 (link is external).
A cost transfer moves costs from one account to another to correct an error, reimburse service center or departmental costs, or for other reasons associated with a department’s regular financial operations; it may not be used as a means for managing project funds (e.g., spending down an award that is expiring).
Cost sharing is the portion of project costs not reimbursed by the sponsor and may be in the form of cash or in-kind contributions. The general policy of the University is to assume a cost-sharing commitment only when required by the sponsor or by the competitive nature of the award, and then to cost share only to the extent necessary to meet the specific requirements. All cost-sharing commitments must be included on the Proposal Routing Cost Share Form and must be approved by the University RC-unit responsible for these funds. Cost sharing is most commonly required under federally-sourced grants.
Effort certification is the mechanism used to verify that salaries and wages charged to each sponsored agreement are reasonable in relation to the actual work performed.
Financial Conflict of Interest in Research
A financial conflict of interest in research exists when an individual (or his/her immediate family) has a financial interest that affects, is affected by, or has the potential to affect or be affected by, the individual’s research activities.
Research Involving Humans, Vertebrate Animals, & Biological Materials
Federal regulation and UNH policy require that (1) all UNH research activities proposing to involve human subjects must be reviewed and receive written, unconditional approval from the UNH Institutional Review Board (IRB) for the Protection of Human Subjects in Research before commencing; (2) all research, teaching/instruction, and testing activities involving the care and/or use of vertebrate animals must be reviewed by and receive approval from the UNH Institutional Animal Care and Use Committee (IACUC) before commencing; and (3) all research and teaching/instruction actvities comply with all federal, state and local regulations and guidelines applicable to biohazardous materials.