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LCSC Grant Policy & Federal
Compliance
The OGC is tasked with monitoring all grants awarded to
LCSC in accordance to LCSC policy and federal
regulations.
The LCSC policy for Grants &
Contracts has been revised and updated. Please be
sure to review it for guidance if you decide to pursue a
grant on behalf of LCSC.
1.111 Grant and Contract Applications (PDF)
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quick links
sub-award & sub-recipient
time & effort
conflict of interest
IRB
record retention
OMB circulars |
Sub-award &
Sub-recipient Management
When
LCSC is the recipient of a grant sub-award, the
participating LCSC P.I. is responsible for meeting all
terms outline by the primary recipient for the duration
of the grant’s life cycle. This means the P.I. will need
to be aware of the reporting requirements based on the
type of funding (i.e. state, federal, or stimulus), as
well as any other reporting requirements the primary
recipient may request. To facilitate those requirements,
the PI is responsible for establishing and maintaining a
relationship with the primary recipient’s administrative
contact, being aware of the reporting timeline and due
dates, and ensuring that any IRB requirements have been
addressed.
The OGC will go over
reporting requirements with a P.I. and help coordinate
reporting efforts with the Controller’s Office and
Budget Office. Because the OGC, in conjunction with the
Controller's Office and the Budget Office, helps the
institution monitor grant sub-awards to ensure work
scope and reporting requirements are addressed, the PI
needs to submit reports to the OGC for review before
final submission to the primary recipient.
[OMB Circular A-110, Section A5]
Time & Effort Reporting
LCSC and the Federal Office
of Management and Budget (OMB) require employees of
federally sponsored programs to regularly certify their
level of program effort. As per OMB A-21 Circular,
certification of effort requires the below information:
Employee staff classification and level of FTE
Program funding source and
account budget code
The obligated percentage of
employee activity and type of activity
The percentage of effort
expended monthly
Employee signature
Direct supervisor signature
Time and effort certification
should be done monthly for Classified and Irregular Help
personnel; Faculty and Professional staff should certify
at least once per each semester. A
Program Activity Report Form
(Excel) is available to utilize for this requirement. The percentage of overall
effort is totaled for each completed
monthly worksheet. As per OMB, in order to reconcile and
revise any significant exceptions to the level of effort
(10% or more), a quarterly review of the reports for
Classified and Irregular Help personnel (yearly for
Faculty and Professional staff) is required. If
the review determines that an adjustment needs to be
made, adjustments to salary charges should be made
before the next program activity report is completed.
Completed
Program Activity forms should be kept on file in your office. If
any quarterly review determines a need for adjustment,
the modification should be documented. If your sponsored
program has a Time and Effort reporting mechanism in
place that addresses all the above criteria, please feel
free to continue utilizing it.
Conflict of Interest
Any interest that is or
appears to be not in the interest of the institution.
The institution must write and enact policies to
prohibit waste, fraud, and abuse.
Per
LCSC policy (PDF): "A conflict of interest occurs
when a person's private interests compete with his or
her professional obligation to the College to a degree
that an independent observer might reasonably question
whether the person's professional actions or decisions
are materially affected by personal considerations,
including, but not limited to, personal gain, financial
or otherwise."
A disclosure of any and all
potential conflicts of interests should be written and
sent to the LCSC President. The OGC can assist you with
proper language if needed.
Institutional Review Board
The
charge of the
LCSC Institutional Review Board (IRB) is to protect
the rights and welfare of human subjects involved in
research by minimizing risk and ensuring that subjects
agree to participate voluntarily from an informed
perspective. This is mandated by federal regulations
governing research involving human subjects.
The
Social Sciences Division administers the IRB, to provide
a climate for research and scholarly activity that is
fertile and flexible insofar as possible while
protecting the well-being of human subjects.
Record Retention
The general rule for how long
to keep grant records is three years after closeout
date, however some funding agencies require grantees to
retain records for longer periods. Please refer to the
LCSC Records Retention Schedule (PDF) for more
information.
OMB
Circulars
The Office of Management and Budget (OMB) provides
instruction and information regulating all federal
grants. Please refer to 2 CFR Parts 215 and 220, Cost
Principles for Educational Institutions
[OMB Circulars A-21].
Purpose of Financial and Program Management
Pre-Award Policies
Grant Match
– Match can be in the form of cash or inkind. It is the
P.I. and/or Project Director’s responsibility to
document that the match requirement for the grant is
met.
Sub-awards
Data Rights & Intellectual Property
Conflict of Interest
Equipment
Closeout Procedures
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