Research Policies
IMPORTANT POLICIES TO READ AND UNDERSTAND
As employees of the University, it is the responsibility of all faculty and staff to read, understand, follow, and enforce Villanova policies. Below are some of the policies related to sponsored research. All Villanova policies are located in the Villanova Policy Library and are accessible through MyNova. Questions about a policy/procedure should be directed to the “Responsible University Division/Department” listed on the last page of each policy/procedure document. For help accessing the Policy Library, contact Villanova’s University Compliance Office.
Important Note: This list is not exhaustive.
Pre-Award and Proposal Development Policies |
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Outlines who is eligible to serve as Principal Investigator/Co-Principal Investigator (PI/Co-PI) on proposals for external funding submitted by, and on sponsored projects awarded to, VU through the Office of Grants and Contracts (OG&C).
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Faculty/Staff who do not automatically qualify for PI/Co-PI under the policy above may submit a request for an exception.
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All sponsored award proposals must adhere to this policy.
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Pre-Award and Proposal Development – Additional Guidance |
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Fundamental Research Exclusion
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VU is restricted to conducting research that qualifies for the fundamental research exclusion (FRE).
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When contracting with a military agency, this letter MUST be included in the proposal package, even when VU is participating as a subcontractor.
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Summary of the broad principles applicable to engagements with industrial/commercial entities for sponsored research.
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Limited submission opportunities (LSOs) are funding opportunities where the sponsor has placed a limit on the number of applications that may be submitted by an institution in response to that opportunity. When an Investigator/Research Team identifies an LSO this guidance outlines the required process to follow.
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NSF Safe and Inclusive Working Environment Plan for Off-Campus or Off-site Research |
If a project involves off-campus or off-site research, grantees are required to have a project-specific plan in place that ensures a safe and harassment-free environment. See VU’s guidance for the definition of off-campus/off-site research, plan requirements, plan template, etc.
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Sponsored Award Management Policies and Guidance |
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This Policy applies to all expenses that are paid for business travel needs using University funds. “University funds” include funds provided by contributions, endowments, grant funds, operating budgets, etc.
NOTE: When departments/colleges have further restrictions on travel spending, these must be applied to sponsored award spending within that department/college, as well. The owner of the local policy/process is responsible for ensuring local policies are consistently applied to all department/college spending.
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Process by which VU ensures that all terms and conditions of an award have been met, including all: financial, performance, and other reports have been submitted; deliverables have been met/submitted; expenses have posted; payments have been received; and the index has been closed in VU systems.
NOTE: Awards are not officially closed until sponsors close in their systems.
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All expenditures charged to sponsored awards must be 1) allowable, allocable, reasonable, and necessary; and 2) align with VU, sponsor, and federal regulations. If there is an error with any non-salary/wage expenses, the cost transfer (CT) is the process to correct that error. If there is an error with salary/wage expenses, see Labor Distributions in Sponsored Programs.
NOTE: All CTs to move a cost onto a sponsored award index must 1) be received by OG&C within 90 days from the original transaction date, 2) include the reason for the error, 3) provide the scientific/programmatic justification for why the cost should be charged to the award, and 4) include back-up documentation that shows that is where it should have been charged originally.
CTs to move unallowable costs OFF a sponsored award index can be submitted at any time.
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Expenses charged to sponsored awards must adhere to requirements set forth in Uniform Guidance 2 CFR 200 Subpart E, Cost Accounting Standards, and all VU policies. Some sponsors or awards may have additional restrictions that must be applied.
NOTE: Costs allowable by sponsor but unallowable per VU policy may never be charged to VU sponsored awards.
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The federal government requires an effort certification report when an individual is compensated by or has agreed to contribute time to a federally sponsored project. At VU, effort reporting applies to all faculty, staff, and students who worked on a sponsored project (including non-federal) and received compensation for that effort. Effort certification is the method of certifying to the granting agencies that the salary charged, or cost shared, in the context of each award has actually been expended.
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Guidelines and established procedures for the procurement of goods and services. All procurement activities conducted on behalf of VU must be in compliance with the standards outlined in federal, state, and local laws; VU policies; and Procurement Office procedures.
NOTE: All PIs and those assisting the PI in purchasing transactions involving federal funds are required to complete the ”Purchasing Involving Federal Funds” training offered by the Procurement Office. Link can be found in this policy document.
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Grant Summary Reports |
Monthly reports are issued to Lead PIs to allow for timely monitoring of spending on sponsored awards including links to transaction detail reports displaying both payroll and non-payroll transactions. PIs/Co-PIs hold primary responsibility for actively monitoring the accuracy of expenses charged to their sponsored awards and this report helps facilitate this timely review.
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Process by which the Research Accounting Office (RAO) invoices sponsors, submits financial reports, and processes letter of credit (LoC) drawdowns for sponsored awards.
NOTE: Before preparing any financial reports, discuss the process with OG&C and RAO.
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All expenditures charged to sponsored awards must be 1) allowable, allocable, reasonable, and necessary; and 2) align with VU, sponsor, and federal regulations. If there is an error with salary/wage expenses, the labor distribution (LD) is the process to correct that error. If there is an error with non-salary/wage expenses, See Cost Transfer in Sponsored Programs.
NOTE: All LDs to move a salary cost onto a sponsored award index must 1) be received by OG&C within 90 days from the original transaction date, 2) include the reason for the error, 3) provide the scientific/programmatic justification for why the cost should be charged to the award, and 4) include back-up documentation that shows that’s where it should have been charged originally. Additionally, no costs will be moved onto a sponsored index when 1) effort occurred during an effort certification period that is closed, or 2) effort occurred prior to the start/hire date of the individual.
LDs to move unallowable costs OFF a sponsored award index can be submitted at any time.
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Glossary of commonly used terms in sponsored programs
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