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Additional Information


Conflict of Interest in DSR

Any university employee who is responsible for the design, conduct, or reporting of a DSR project, which is conducted under the auspices of the University, must disclose financial or other interests that are, or may be perceived to be, related to the project. If the University determines that such interests are in conflict, steps will be taken to manage or eliminate the conflict.

Disclosure Required:
• If Investigator has any interest or potential interest to disclose after a proposal is submitted.
• Annually to update any existing interests.
• If Investigator's interests are altered in any manner from what has been reported on the most recent Financial Interest Disclosure form.
• Annually for any sponsored project funded by either National Science Foundation (NSF) or National Institute of Health (NIH).

Financial Relationship Reporting Form
Proposal Review and Certification ("Internal")Form
USF Conflict of Interest Policy
Health Science Center Conflict of Interest Policy

Animal and Human Subject Information

• PIs must have approved research protocols in order to conduct research at USF.
• Animal and Human protocols are reviewed by the IRB or IACUC (see appropriate website for schedule and submission deadlines).
• Animal and Human protocols require periodic training and certification of staff members (see appropriate website for details)
• For additional information, see the following websites below:

Division of Research Compliance
Animals - Division of Comparative Medicine
Humans – Institutional Review Board (IRB)
HIPAA Privacy Rule Compliance
BioSafety Program
Radiation Safety Office
Diving Safety Program

Direct Costs

Direct costs are those costs that can be identified specifically with a particular sponsored project. For federally funded projects (including federal flow through), direct costs must comply with Cost Accounting Standards (CAS)

• Must be specifically identified with a particular project—Charge it where you used it!
• Must be allocable (i.e. costs must be charged in proportion to their benefit to a particular project).
• Must be reasonable (i.e. charging costs to a particular project must be done conservatively and reflect the actions of a prudent person).
• Must be allowable (i.e. certain cost, such as entertainment, may not be charged to a Federal grant under any circumstances).
• Also, costs normally included in the institution’s research F&A cost rate (e.g., administrative staff or office supplies), CANNOT be direct charged to a Federal grant.
• Must be timely (cost transfers should occur as soon as an effort is discovered by no later than 90 days after original charge was incurred).
• Must conform to any limitations or exclusions in the Sponsored Agreement.
• Reference USF’s Policy for Charging Costs Directly or Indirectly to Federally Sponsored Projects:

http://www.research.usf.edu/vpfr/policy/charcost.pdf
http://www.research.usf.edu/sr/CAS_Policies_and_Procedures_3.htm
• Reference OMB Circular A-21

Tuition Payment from Grants

• Principal Investigators must specify tuition as a Direct Cost item in the budget when preparing proposals. A specific budget account code will be assigned at the beginning of a project to earmark funds for tuition.
• Principal Investigators should ensure that students whose tuition is paid from a grant are providing effort benefitting the grant.
• Grant Tuition Payment Request forms must be completed and submitted to Research Financial Management for processing.

Cost Sharing / Matching

Cost sharing represents the portion of the total project costs, that are not provided by the sponsor. Cost sharing should be included in a proposal only when required by a sponsor.

OMB Circular A-110, Subpart C. 23 discusses the requirements for cost sharing on federal awards.

• Cost share must be allowable, reasonable and allocable.
• Cost sharing must have an approved internal funding source [project/fund (E&G, RO, Auxiliary, Etc.)], and the authorization of department chair and/or dean.
• Unallowable costs may not be included in the costs shared by the University.
• Funds for a federally sponsored project may not be used as cost sharing for another federally sponsored project.
• Cost sharing must be incurred during the project period.
• Cost sharing must be documented and verifiable from University records (including third party documentation) See Effort Certification.
• Third party cost sharing must be documented.
• Failure to meet cost sharing obligations or the failure to properly document cost share expenditures can result in cost disallowances by the sponsor.

Budget Transfers

Any time a change is needed to the budget of an existing project, it is processed by one of two forms:
• The Budget Transfer Form allows budget to be reallocated within the project.
• The Subaccount Transfer Form is used to establish and reallocate budget between primary and secondary projects.

Sponsor approval may be required before a transfer can be approved by DSR. Please contact your RPS Senior Grants Specialist for details or for assistance in completing the forms.

Expenditure Transfers (Payroll & NonPayroll)

An Expenditure Transfer involves moving expenses from one project / fund (E&G, RO, Auxiliary, etc.) to another. Expenditure transfers must follow Direct Cost guidelines in that they must be allowable, reasonable and allocable.

Payroll Expenditure Transfer (PET) Form
Non-Payroll Expenditure Transfer Form

• Transfers may be used for correcting errors, not for managing or exhausting funds.
• Transfers to grant projects require a full, detailed explanation of why the expense was incorrectly charged as well as plans for amelioration.
• Transfers to Federally funded grant projects after 120 days of the initial expenditure require an explanation of why the transfer was late (department chair’s authorization is required).
• Expenditures that are not allocable or allowable to a particular grant project may not be transferred to that project.
• Certified effort reports in PERT must match GEMS pay history.
Adjustments in salary to any project must be reported to sponsor through your DSR Sr. Grant Specialist

Effort Certification

Federal regulation requires educational institutions to maintain an accurate system for reporting the percentage of time that employees devote to federally funded projects. In accepting federal funding, the University and Principal Investigator agree to comply with this regulation.

PERT (Personnel Effort Reporting Tool), is the university’s system designed to meet federal effort reporting requirements. Employees must complete an effort report in PERT if they meet any of the following criteria:
• Salaries and wages are federally funded.
• Provided committed cost sharing to any project.

References:
• OMB Circular A-21
• PERT policies and procedures
• PERT Training

In the absence of a certified effort report, salaries and wages charged to federal projects must be moved to an unrestricted funding source.

PI Awareness

• The "Basics"
• PI Empowerment
• Grants.gov Workshop
• COS (Community of Science) Workshop
• PERT

Description and registration:
http://www.research.usf.edu/workshops/

Quick Reference Guide
Divisions