9.02 Grants and Gifts
Purpose
This policy delineates the roles of the Office of Research and Sponsored Programs (RSP) and the UNI Foundation (Foundation) in seeking and managing external funding.
Background
The University of Northern Iowa receives external funding both for sponsored projects (in the form of grants, cooperative agreements, and contracts) and as gifts. Policy 9.01, Grants, Contracts, and Sponsored Agreements, establishes RSP as the university’s authoritative agent and liaison with external funders, with the exceptions defined in this policy. Such exceptions are based on funder restrictions, funder intent, and compliance oversight requirements.
Definitions
Funder: Any entity that supports the university’s research and educational mission with externally sourced funding. Depending on the type of support, funders may also be known as sponsors, donors, partners, or contributors.
Gift: A contribution received for either restricted or unrestricted use in furthering the university’s research and educational mission. A gift is something of value that is given to the university by a donor who expects no consideration in return, other than recognition of the gift and its disposition in accordance with the donor’s wishes and agreed upon use. Some donors refer to their gifts as grants or charitable grants.
Grant: A financial assistance award that supports a public purpose; in this case a sponsored project award that furthers the university’s research and educational mission.
Sponsored Project: A project funded by a grant, contract, cooperative agreement, or other binding arrangement for use in furthering the university’s research and educational mission. A sponsored project has a scope of work with project milestones that are a related, reciprocal transfer or creation of something of value in exchange for the sponsored funding received.
Policy Statement
- Faculty, staff, and students should contact RSP or the Foundation for guidance and assistance as early as possible when developing a proposal for external funding. If uncertain about which office is the appropriate point of contact, contact RSP for clarification.
- It is the policy of the university and the UNI Foundation to recover overhead costs in the form of facilities and administrative (indirect) costs and gift fees at the highest rate allowed by a funder, regardless of whether a proposal is submitted by RSP or the Foundation. Exceptions to this policy consistent with the Guidance for Recovering Facilities and Administrative Costs may be requested using the F & A Reduction Request Form found on the RSP website. Overhead recovery rates will not be used to determine which unit will submit a proposal or administer an award.
Proposal Submission
3.1 Proposals Submitted by RSP
RSP is responsible for submitting most proposals for sponsored projects, including all proposals for:- Funding from international, federal, state, or local government or quasi-government entities, or funding that flows through one of these entities
- Funding from industry, industry associations, or commodity associations for sponsored projects
- Funding that will be awarded as a contract or cooperative agreement
3.2 Proposals Submitted by the Foundation
The Foundation is responsible for submitting proposals for gifts and for certain sponsored projects that may be awarded as grants. When only 501(c)3 nonprofit organizations or university foundations are eligible applicants, the Foundation is responsible for submitting the proposal regardless of the type of funder.
3.3 Compliance Oversight Considerations
RSP has oversight responsibility for certain regulatory compliance areas to which the university is subject. Sometimes it is known in advance that an award would be managed by RSP due to compliance oversight requirements, but the proposal must be submitted and the award accepted by the Foundation because of funder restrictions on eligible applicant types. In this case, the proposal will be reviewed by both RSP and the Foundation before submission. The project budget will include UNI facilities and administrative (indirect costs), if allowed. The following compliance issues require oversight by RSP:- The award contains restrictive provisions for intellectual property rights
- The award restricts or monitors publications or use of results
- The award restricts the disposition of tangible property
- The project involves export controlled items or information (see UNI Policy 13.14 Export Controls and “Export Controls” information on the RSP website)
- The award contains complex and/or frequent management and reporting requirements that may be more easily met through the university’s post-award administration and accounting systems
- Other compliance issues by agreement of RSP and Foundation leadership
- Award Acceptance and Management
Typically, whichever unit submits a proposal is also responsible for accepting and managing the subsequent award. But in some cases, the terms and conditions of an award differ from the funder’s representation of the funding type at the proposal stage. RSP and the Foundation will, upon receipt of an award, conduct an administrative review to determine whether the award should stay with the submitting unit or be transferred to the other unit for acceptance and/or management.
4.1 Foundation Award Transfer to RSP
If the Foundation receives an award that is subject to a compliance oversight restriction in Section 3.3, the award will be transferred from the Foundation to the university for administration by RSP, in consultation with the Foundation and with funder approval. If the award includes facilities and administrative costs, the Foundation may first assess the gift fee. The Foundation may review the project’s final narrative and financial reports before they are submitted to the sponsor.
4.2 RSP Award Transfer to the Foundation
If RSP receives an award that should properly be classified as a gift, and the award is not subject to any of the compliance oversight restrictions in Section 3.3, the award will be transferred to the Foundation according to procedures developed by the university and the Foundation. The Foundation will apply the appropriate gift fee to the gift.
- Determinations on cases that are not clearly addressed by this policy, and any exceptions to this policy, will be made by agreement between RSP and Foundation leadership.
Related Policies
9.01 – Grants, Contracts, and Sponsored Agreements
UNI Foundation and Office of Research and Sponsored Programs, approved March 14, 2022
University Council, approved September 19, 2022
President and President’s Cabinet, approved October 10, 2022