Policies and Procedures

Grant Compliance Monitoring System Cost Sharing
Reporting Requirements Retroactive Cost Transfers
Timesheet Reporting Policy Proposal Routing
Prior Approval System Conflict of Interest
Travel Policy Participant Support Cost Guidelines
AIHEC Subaward Selection Processes

Grants Management Policy

GIFTS and GRATUITIES
In order to avoid a conflict of interest or the appearance of a conflict of interest, at no time should an employee solicit or accept gifts from a vendor or contractor or from a potential vendor or contractor except as described below.

Unsolicited personal gifts valued at $25.00 or more cannot be accepted by employees, and should be returned immediately to the donor. If the value of the gift is undetermined it should be returned. Ordinary business courtesies, such as payment for a modest lunch or dinner, are acceptable provided it does not exceed the value listed above. Gifts which are promotional items without significant value, and which are distributed routinely by the vendor to clients, are also acceptable.

Gratuities or gifts of money to the employee cannot be accepted at any time and should be returned immediately to the donor. Employees who have questions regarding this policy should confer, in writing, with their supervisor (or AIHEC's Finance & Administration Director) to determine an appropriate course of action.

All employees are subject to this policy and are expected to comply fully. Instances of deliberate breach of policy, or failure to comply with the policy, will be reported to AIHEC's President and CEO for appropriate action.

HUMAN RESEARCH PARTICIPANTS
Sponsored research involving human subjects, which may include people who are being interviewed and/or electronically recorded, has strict guidelines intended to protect these individuals. Personnel involved in such research need to be informed on how to ensure proper protection of their rights. Proposals that include human research participants must be approved by an Institutional Review Board (IRB) prior to being submitted. A copy of the IRB Guidebook developed by the Department of Health and Human Services (DHHS) is available on-line. Access the full Code of Federal Regulations text defining Protection of Human Subjects regulations as specified by DHHS.

Many federal agencies involved in sponsoring research involving human subjects, have adopted the same set of regulations, referred to as the "Common Rule." The National Science Foundation (NSF) Web site has a page on Human Subjects that is both easy to use and understand and a FAQ's page to help people interpret these regulations.

Grant applications made to the National Institute of Health must provide assurance that all key personnel have been educated in how to ensure proper protection of human subjects. An online course designed to help individuals attain and verify this education can be accessed through the National Institute of Health Web site.

OMB CIRCULARS
The Office of Management and Budget (OMB) has declared that all tribal colleges, "...regardless of whether they are part of an Indian Tribal government..." must follow circular A-21, in addition to A-110 and A-133. There is a similar circular, A-87, entitled "Cost Principles for State, Local and Indian Tribal Governments" that does not apply to tribal colleges and universities.

  1. A-21 Cost Principles for Educational Institutions
  2. A-110 Uniform Administrative Requirements
  3. A-133 Audit Requirements

FEDERAL AGENCY GRANT REGULATIONS
Always read the award documentation that is received from the sponsoring agency. The award letter contains vital information and also generally specifies the Terms and Conditions that govern how an award should be managed. As of July 2008, many federal agencies have standardized terms and conditions in an effort to simplify award management. The information provided below is a general guideline; specific award letters should be referred to at all times for possible exceptions.

Department of Defense

  1. Department of Defense Grant and Agreement Regulations
  2. U.S. Army Research Office: The Army Research Office adopted the Standard Terms and Conditions of many other federal agencies effective July 1, 2008; also refer to the Agency Specific Terms.
  3. Office of Naval Research: The ONR adopted the Standard Terms and Conditions of many other federal agencies effective July 1, 2008; also refer to the Agency Specific Terms.

Department of Education

  1. EDGAR—Education Department General Administrative Regulations

Department of Health and Human Services

  1. Grants Administration Manual

NASA

  1. NASA Grant and Cooperative Agreement Handbook
  2. As of July 1, 2008, NASA will apply the Standard Terms and Conditions to all research, education and training grants. The new Standard Terms "will not apply to cooperative agreements, contracts or other transactions." Also refer to the Agency Specific Terms.

National Institutes of Health

  1. NIH Grants Policy Statement
  2. As of July 1, 2008, NIH will apply the Standard Terms and Conditions to all NIH grants and cooperative agreements with the exceptions noted on the NIH Agency Specific Requirements.

National Science Foundation

  1. As of July 1, 2008, NSF will apply the Standard Terms and Conditions to all new NSF grants and funding increments, and include the NSF Research Terms & Conditions, Agency Specific Requirements. NSF TCUP projects are cooperative agreements, so the Research Terms and Conditions do not apply to them.
  2. Grants Policy Manual
  3. Grants General Conditions
  4. Grant Proposal Guide—This manual is used when developing an NSF application/proposal.

National Endowment for the Humanities

  1. General Grant Provisions for Organizations

USDA

  1. CSREES General Terms and Conditions-B—These terms and conditions apply to the same awards as the General Terms and Conditions-A with the same exceptions; however, General Terms and Conditions-B applies to those recipients who have not had at least three years of managing NIFA funds. Research Terms and Conditions: Effective for awards made on July 1, 2008 or later, these Terms and Conditions have been standardized across multiple federal agencies that support research and research-related activities. This includes education and extension awards made through CSREES. Refer to: Research Terms and Conditions and Agency Specific Research Terms and Conditions.

OSP Resources

  1. NCURA: The National Council of University Research Administrators has an excellent Web site which includes a resource page entitled the Fundamentals of Sponsored Project Administration.