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Research Compliance

Establishing PI eligibility and meeting compliance requirements are the first steps for any faculty interested in submitting a sponsored research proposal. To get started in research each of the following four steps must be performed to establish a PI eligible profile in the UD PeopleSoft Grants Management System. The UD Research Office will not process a grant proposal until each of these requirements has been met. Each of these four items must be complete prior to submitting your proposal:
  1. Establish PI Eligibility (one time set-up)
  2. Define Keywords (one time set-up but may be modified)
  3. Conflict of Interest Form (to be completed annually)
  4. Watch a Mandatory Video titled: Basic Principles of Responsible Conduct in Research Training
Congratulations! You have won an award! There are additional compliance requirements for managing expenses on your research project.
  1. Effort Reporting is required for all faculty and staff with salary charged to a sponsored research project. The federal Office of Management and Budget (OMB) Circular A-21 dictates requirements for effort reporting which are outlined below.
  2. Food and travel are the most common red flags for unallowable expenses on a grant. Expenses must be allowable, allocable and reasonable under federal law and UD policies.
Tip: Planning your budget and budget justification carefully prior to submission can save a lot of PI heartburn managing expenses during the project!
UD’s Compliance Hotline is available for any person who is subjected to or witnesses inappropriate charging activity on a grant. The University of Delaware is committed to responsible conduct in research! For more information please contact: Linda C. Somers Business Officer Alfred Lerner College of Business and Economics Office of the Dean, Sponsored Program Services 303H Alfred Lerner Hall Newark, DE 19716 302-831-1602 lsomers@udel.edu

PI Eligibility

Principal Investigators and Co-Principal Investigators have primary institutional responsibility for providing scientific/technical leadership and administrative and financial management of sponsored projects. As such, the University has designated the following personnel as eligible to serve as Principal Investigator or Co-Principal Investigator on sponsored projects:
  • All full-time faculty regardless of academic rank
  • Visiting faculty/visiting scientists during the time they are on the University payroll
  • Full-time, academic non-administrative professionals in classified positions at or above Level 31E
  • Others as designated by the approval of the appropriate college dean using the PI eligibility form (Word doc).
* Principal Investigator/Co-Principal Investigator status may be rescinded for cause. Additional information on retired faculty or graduate students serving as a PI may be found on the Research Office website.  

Keywords

Keywords are submitted through the Employee Demographic Data (EDD) form prior to submitting a proposal. The Proposal Keyword(s) are used to track proposals by subject category (for example: disease, avian, solar) and to link multiple science codes to projects. These identifiers are important for reporting both internally and externally by science categories. Please see your department administrator for assistance with the EDD.

Conflict of Interest Form (Annual Requirement)

UD policy requires that a Conflict Of Interest (COI) be filed at the time of hire and the start of each calendar year. The UD Research Office will not process proposals unless the PI’s COI is current. It is the responsibility and obligation of all faculty and professional staff to disclose all significant financial and commitment interests that may affect, or appear as if they could affect, their professional responsibilities. A potential COI occurs when there is a divergence between an individual’s private interests and his or her professional obligations, such that an independent observer might reasonably question whether the individual’s professional judgment, commitment, actions or decisions could be influenced by considerations of personal gain, financial or otherwise. The conflict of interest form is available as a UD Web routing form. Please click on the link here, and login using your UD NetID and password. Look for “Conflict of Interest Disclosure Form” under the tab “Blanks”. The complete and official UD Research Policy can be found here: Section: Research Policy Number: 6-11 Policy Name: Conflict of Interest Policy and Procedures for Faculty and Professional Staff Revisions: March 1, 1996; February 18, 2002; January 18, 2008; August 11, 2008; August 23, 2012

Mandatory Video

Basic Principles of Responsible Conduct in Research Training Serving as a Principal Investigator (PI) at the University of Delaware brings significant rewards and confers concomitant responsibilities. PIs are responsible for the intellectual direction of research and scholarship and for the education and training of students. In carrying out these critical tasks, PIs are also responsible for compliance with laws and regulations that touch on all aspects of the research enterprise. To ensure compliance with applicable rules, regulations, and contract requirements, the University of Delaware requires all PIs to receive training in the financial management of sponsored projects. Developed for PIs already at the University, the University’s training program focuses on stewardship of funds, mandatory reporting requirements, and particularized training in the fundamentals of federal grant and contract accounting. PIs must complete mandatory training before the University will release project funding. Thank you for helping us to ensure that the research enterprise is not only competitive and productive, but also compliant with federal regulations. Video duration: 1 hour. Confirmation of viewing is required at the end of the video. This mandatory requirement is currently a one-time event. The PI’s confirmation will be kept on file at the Research Office. Please open the hyperlink here and login to Google Apps using your UDelNet ID and Password.

Effort Reporting

Certifications of Effort on sponsored awards are required for every University employee whose salary or wages are directly charged to a sponsored program account or whose salary or wages are used as cost sharing for a sponsored program. UD is mandated to comply with the federal Office of Management and Budget (OMB) Circular A-21 requirements for effort reporting. There are three effort reporting periods per year.
  • Period 1 includes effort provided during the fall semester of the academic year.
  • Period 2 includes effort provided during the spring semester.
  • Period 3 includes summer research activity performed June – August.
The following chart describes the three periods for academic faculty: Effort Periods for Faculty on Academic Contracts
Effort Periods Period 1 Period 2 Period 3
Semester Fall Semester Spring Semester Summer (Research Only)
Performance Period Sept- Jan. 15 Jan 16- May 31 June – August
Payments Made September – February March – August June – September (Later pay requires repush)
Payment Method JED JED S-Contracts
Accounts 121000, 121100, 121200, 121600 121000, 121100, 121200, 121600 *Excludes 121800 & 121900 121800, 121900
Release Date March September October
UD Effort Policy (6-5) Section: Research Policy Number: 6-5 Policy Name: Effort Certification Reporting Revisions: June 5, 1989; March 1, 1996; September 1, 2005; January 18, 2008; August 8, 2008, January 2009, July 2009; September, 2010; August 10, 2011; August 2012 Effort Training UD’s research enterprise depends on funding from federal and state agencies, private foundations, organizations, and industry. The University’s electronic Effort Certification Process (ECP) is the principal means of verifying that salaries and wages charged to or contributed to a sponsored project are fulfilled in a manner consistent with the award documentation and compliant with the federal regulations for which the University is held accountable. Policies and Overview Training Effort Certification Procedures Effort FAQs Dawn Yasik, Manager of Effort Certification, UD Central Research Office: effortcert@udel.edu or ext. 4956

Food, Alcohol and Travel

Every grant must be managed in strict compliance with applicable award terms.  It is the responsibility of the principal investigator and grant administrator to understand and adhere to the award terms.   Allowable, allocable and reasonable are terms defined by the federal Office of Management and Budget (OMB) Circular A-21 “Cost Principles for Educational Institutions” which establishes principles for determining costs applicable to grants, contracts and other agreements with educational institutions. Alcohol is NOT permitted as an expense on any research grant.  As a research institution which receives a significant amount of federal funding UD must remain compliant with the over-arching federal OMB Circular A-21. When it is deemed appropriate alcohol may be served at Lerner events.  The expense must be charged to a Lerner supplemental or discretionary account. Many sponsors prohibit both food and alcohol.  When submitting a grant proposal to a sponsor please carefully read the terms and conditions of the solicitation to establish if food is an allowable expense. Food may be an allowable expense on many non-federal grants.  Please carefully examine the terms and conditions of the solicitation for budget exclusions. The budget justification should clearly document the inclusion of food in the budget. Food on Federally funded grants is NOT allowed as a rule.  There are a few exceptions which include a request for funding a conference or workshops as part of the proposal.  In this case, food charges must be clearly defined as part of the conference or workshop in both the budget and budget justification. Foreign travel is often prohibited on grants.  Domestic travel may be allowed but with permission from the sponsor prior to taking the trip.  Please check on travel limitations before submitting your proposal. Unallowable expenses must be managed in accordance with the UD Cost Transfer Policy.

Compliance Hotline

The Compliance Hotline is designed to receive reports regarding ethical issues and other concerns related to accounting and financial controls, athletics, human resources, information technologies, research, and risk and safety matters.  Examples of reportable issues include fraud, misuse of UD resources or information, violation of safety rules and environmental laws, conflicts of interest, NCAA violations, unlawful discrimination or harassment, and research grant misconduct. EthicsPoint should not be used for immediate threats to life or property. If you require emergency assistance, please call 911 or 831-2222. How to File a Report: EthicsPoint is designed to maintain your confidentiality and anonymity.  Use any one of these channels of communication: University Web Go to UD’s Ethics Point portal and click on the appropriate Issue Category that best describes the incident. The system will walk you through the secure submission process. Toll-Free Phone Call the EthicsPoint toll-free hotline at: 1-888-366-6033. An intake specialist will assist in making your report.