The Director of Foundation Relations and Research Grants (DFRRG) is responsible for all grant applications submitted by Concordia College faculty and staff. The Vice President for Concordia Language Villages is responsible for all grants submitted on behalf of the Language Villages. The DFRRG reports to the Provost and Dean of the College. The Provost sets the grant strategy for the college, providing the vision and resources necessary to achieve success.
The office of Foundation Relations and Research Grants is staffed by a full-time director and part-time administrative assistant responsible for all pre and post award activities. The director provides guidance and advice to the Principal Investigator (PI) for research and programming grants, but does not have resources to develop the entire proposal. Institutional grants are targeted to institutional needs, priorities and special projects. A team of faculty and/or staff will work with the director to submit institutional grants.
A. Grant approval
The Board of Regents has authorized the following officials to submit grant proposals: President, Provost or a Vice President.
Individual faculty or program directors are not authorized to submit proposals on behalf of the college. Any funds that will be received by Concordia College must have a signed Grant Approval Form. The grant form and a final/draft of the proposal must be submitted within two weeks prior to the application deadline. If you are not able to meet this deadline, please contact the DFRRG as soon as possible to discuss your proposal. Faculty members may seek individual grants (awarded to them personally, not to the College) without completing a grant form, but must inform the DFRRG of your application and award. The director maintains a list of grant activity for the Provost.
B. Direct Costs - Budget Creation
There are four basic concepts related to direct costs: allowability, allocability, reasonableness and consistency. These concepts are applicable to all sponsored research proposals and required for all government funded proposals.
Allowability - An allowable cost meets all of the following:
- The cost must be allowable under provisions of OMB Circular A-21 AND under the terms of the sponsored project.
- The cost must be permissible according to Concordia College's policies and federal regulations.
- The cost must be reasonable and reflect what a "prudent person" would pay in a similar circumstance.
OMB Circular A-21 identified specific costs that may not be charged directly to federally sponsored awards, except under special conditions. Unless the special conditions apply, these unallowable costs must be paid from non-federal sources. PIs and others involved in the expenditure charges to sponsored projects must insure that charging these costs to non-federal projects is permissible in accordance with the policies of those sponsors. Unallowable costs for federal grants (based upon OMB A-21 definitions):
Public Relations Costs
Alumni Activity Costs
Local Civil Defense Project Costs not on Institution's Premises
Commencement and Convocation Costs
Institution Furnished Automobile Costs for Personal Use
Contingency Provision Costs
Defense and Prosecution of Criminal and Civil Proceedings, Claims, Appeals and Patent Infringement Costs
Depreciation Reserves Costs
Donations or Contributions
Entertainment Costs (includes amusement, diversion & social activities)
Executive Lobbying Costs
Fines and Penalties (including late fees)
Goods and Services for Personal Use
Housing and Personal Living Costs
Insurance Costs to Protect against Defects in Institution's Materials or Workmanship
Interest, Fund-Raising and Investment Management Costs
Losses on Other Sponsored Agreements
Membership Costs in Civic Clubs, Community Organizations, Country Clubs, Social or Dining Clubs or Organizations
Preagreement Costs Prior to Effective Date of Agreement
Selling and Marketing Costs of Products or Services of the Institution
Severance Costs in Excess of Institution's Normal Severance Pay
Specialized Service Facilities Charges in an amount More than Aggregate Costs of Service Over a Long-Term Period
Student Activity Costs
Airfare Travel Costs in Excess of Lowest Available Commercial Discount Airfare or Customary Standard Coach Airfare
Allocability - If possible, expenses should be individually charged to a specific sponsored agreement. An allocable cost is a cost that can be assigned to one or more sponsored project or other project in proportion to the relative benefits received.
A cost is allocable to a sponsored agreement if:
- It is incurred solely to advance the work under the sponsored agreement.
- It benefits both the sponsored agreement and other work of the institution, in proportions that can be approximated through use of reasonable methods.
- It is necessary to the overall operation of the institution and, in light of the principles provided in the Circular, is deemed to be assignable in part to sponsored projects.
The best approach to justify a cost on a specific sponsored agreement is that it is incurred solely to advance the work of the agreement. Some of these costs are easy to identify such as pieces of equipment, animal costs, or chemicals purchased solely for one project.
Other costs may clearly be allowable and reasonable but a question arises: how best to allocate among one or more sponsored agreements that benefit from that cost? The most typical example of this type of cost is general laboratory supplies. A-21 acknowledges that it is sometimes impossible to precisely identify or allocate such costs; governing regulations thus allow for the exercise of judgment: "A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a high degree of tolerance is appropriate." A-21, J8b(1)c.
Reasonableness - A cost is considered reasonable if the goods or services acquired, and the amount involved, reflect actions that a prudent person would take under the circumstances. Factors to consider in determining reasonableness are as follows:
- Is the cost necessary for the performance of the project?
- What laws and regulations should be considered, and what are the terms and conditions of the award?
- Did all individuals act with prudence and satisfy their responsibilities to both the institution and sponsor?
- Are the actions consistent with Concordia College policies and practices?
Consistency - All costs must be afforded consistent accounting treatment. A particular cost must always be treated in the same manner - as either a direct or indirect cost - under similar circumstances. The college's indirect rate covers administrative salaries and supplies related to the administration of federal grants. Costs for administrative salaries and supplies may not be directly charged to federally sponsored projects.
In addition, practices used in estimating costs in a proposal must be consistent with the college's regular practices for charging costs to projects and for reporting expenses on financial reports submitted to project sponsors.
Salaries and Wages on Grants
It is the policy of Concordia College that grant project personnel seek maximum allowable compensation from the grant for their work on the sponsored program. Full-time faculty members may apply for released time from their regular teaching load and will be compensated from the grant in direct proportion to the released time approved. Pursuant to the requirements of OMB Circular A-21, faculty paid under a sponsored agreement will be required to complete and sign a salary certification verifying the time expended and proportionate salary received. All grant compensation will be based on the individual faculty member's regular compensation for the continuous period which constitutes his/her Concordia College contract salary, and will be calculated at the base salary rate. If appropriate, a program investigator may be compensated as a percent of effort by filling out the Time and Effort Form, i.e., compensated in direct proportion to the percent of effort to be devoted to the grant funded program. For example if a principal investigator will be devoting 20% of his/her time working in the funded program their compensation will be calculated on the basis of 20% of their contract salary. Regardless of the basis of the compensation under no circumstances will charges to sponsored agreements exceed the proportionate share of the base salary for that period. Normally, compensation from grant funding may not be used to augment the total salary or salary rate of faculty members during the period covered by the term of the faculty appointment.
Under rare circumstances a faculty member may wish to apply for funding over and above his/her base contract salary. This will only be considered if (1) the request is consistent with the funder's guidelines, and (2) the activities within the funded program for which compensation is being sought are not part of the normal and expected contractual responsibilities, activities and obligations. In such a case the specific written approval of the program sponsor will be required prior to the compensation being allowed by the college.
Concerning summer salary, an individual seeking compensation for their work on a sponsored program during the summer months will be reimbursed at a monthly rate not in excess of the base salary divided by the number of months for which the base salary is paid, i.e., a faculty member be on a ten (10) month contract will receive compensation calculated on the basis of 1/9th of the contract salary for each of the months of June and July.
Each semester, employees receiving compensation from a sponsored program will be required to sign a Time and Effort Form verifying that the work was performed and also verifying the hours, time and effort expended under the program.
Course release to conduct research or for curriculum development may be a component of your grant project if allowed by the sponsor. All course releases must be documented on the internal grant form and have the permission of the Department Chair. Please consult the DFRRG to determine costs associated with a course release. Any requests for release time or leave without pay must receive prior approval by the Department Chair, Division Chair and Dean.
All principal directors must Include 10% for overhead/indirect college costs in your budget. If the funder does not allow indirect costs, please inform the DFRRG during the proposal process and note this on the grant form. All federal grant applications must include our negotiated rate of 39% on direct salaries and wages for faculty, administrative, student and staff positions. This rate does not apply to fringe benefits or other project costs. Indirect costs are distributed to an academic affairs/provost office account and are not tied to the proposed project.
Grant budgets that include salary and wages must also include fringe benefits. Student academic year wages are the exception to this policy as they are considered student aid and do not require fringe benefits. Student summer wages must include an additional 7.65% for the employer portion of the Federal Insurance Contributions Act. Academic year faculty and year-round employee wages must include an additional 30% for fringe benefits. Summer faculty and staff off-contract staff wages must include an additional 7.65% for the employer portion of FICA.
C. Special Review
Any proposal that involves research must follow the following guidelines:
- Proposals with human subjects must have Institutional Review Board (IRB) approval prior to submission. If the funder allows, approval may be requested and pending. Please see the IRB website for further information
- Proposals with involving animal research must be reviewed by the Institutional Animal Care and Use Committee (IACUC). Please contact the IACUC chair for more information.
- Proposals involving undergraduates or post-docs in research must follow Responsible Code of Research (RCR) guidelines. Please contact the Director of Undergraduate Research and Scholarship for more information.
National Science Foundation (NSF) proposals must meet the following requirements:
- Special Information and Supplementary Documentation (Chapter II.C.2.j, of proposal guide), contains a clarification of NSF's long standing data policy. All proposals must describe plans for data management and sharing of the products of research, or assert the absence of the need for such plans. Fastlane will not permit submission of a proposal that is missing a Data Management Plan. The Data Management Plan will be reviewed as part of the intellectual merit or broader impacts of the proposal or both.
- Cost Sharing (Chapter II.C.2.g[xi] of proposal guide), has been revised to implement the National Science Board's recommendations regarding cost sharing. Inclusion of voluntary committed cost sharing is prohibited. Awardees are informed, however, that they remain subject to the OMB A-21 Clarification memo regarding committing and tracking faculty effort. In order to assess the scope of the project, all organizational resources necessary for the project must be described in the Facilities, Equipment and Other Resources section (II.C.2.i). The description should be narrative in nature and must not include any quantifiable financial information. Mandatory cost sharing will only be required when explicitly authorized by the NSF Director.
D. Transmittal of the proposal
The PI/co-PIs are responsible for preparing the proposal. Under normal circumstances, the DFRRG is responsible for submitting the proposal to the funding agency.
The National Science Foundation (NSF) operates under an online submission process through Fastlane (www.fastlane.nsf.gov). NSF requires all PIs and co-PIs to be registered on their system. If you are not currently registered, please contact the DFRRG as she is the SRO (Sponsored Research Officer) for fastlane. The PI/co-PI complete the proposal and submit it via fastlane and submits the proposal. The SRO (DFRRG) reviews, approves and submits the proposal. Please contact the DFRRG if you have questions about your fastlane log in information.
Grants.gov is the online submission system for all federal programs. The DFRRG is an Authorized Organizational Representative (AOR) and will guide faculty/staff through the online submission process.