Policies and Procedures

 

I.General
II. Definitions
III. Office for Grants Functions and Services
IV.  Authority
V.  Proposal Submission & Approval
VI.  Conflict of Interest
VII.  Cost Principles and Practices
VIII.  Cost Sharing and Matching Funds
IX.  Use of External Funds to Pay Salary
X.Use of NWACC Facilities
XI.Use of NWACC Equipment
XII. Equipment Procurement with External Funds
XIII. Materials and Supplies Procurement with External Funds
XIV.  Administrative and Clerical Support on External Grants
XV. Hiring Grant-Funded Employees
XVI.  Grant-Funded Travel Expenses
XVII. Institutional Approvals for Specific Types of Research
XVIII. Grant Processing
XIX.Reporting Requirements
XX.  Effort Reporting and Certification for Sponsored Activities
XXI.Project Director/PI Departure from the College
XXII.  Federal Guidelines, Regulations, and Compliance Requirements



I.  General
The College has included diversification of its funding base as one of its priorities.  State funding alone will not support a nationally recognized community college.  Therefore, NWACC faculty, staff and administration are highly encouraged to actively seek outside funding for activities and programs that are vital to the college.  Grant goals and objectives should support the NWACC mission.

II.  Definitions
The following definitions shall pertain to the terms contained within the Office for Grants Policies.  A full list of grant related definitions can be found in the glossary.

Award- Funds that have been obligated by a funding agency for a particular project.

External Agency- The external source of additional revenue.  Also known as Grantor or External Funding Agency.

Equipment- Tangible nonexpendable personal property, including exempt property, charged directly to the award and having a useful life of more than one year and an acquisition cost of $5,000 or more per unit.

Grant- A type of financial assistance awarded to an organization for the conduct of a program as specified in an approved proposal.  A grant is used whenever the Grantor anticipates programmatic involvement with the recipient during the performance of the activities.

Grant Proposer- Individual who begins the grant proposal application process and owns responsibility of the development and submission of the grant.  The grant proposer will likely become the PI once the grant is awarded and the project commences.

Grantor- Funding source that has agreed to provide financial support in the form of a grant.

Principal Investigator (PI)- A PI may be an employee, normally with an academic appointment who is or becomes eligible under this definition to submit a proposal for program support for projects in research, training, student and/or workforce development, public services, etc. to a significant degree, and who has primary responsibility for the scientific, technical and administrative conduct and reporting of the project.  May also be known as Project Director.

Sponsored Project/Program- The project, program or project related activities which are financially supported by grant funds.

Supplies- All personal property excluding equipment, intangible property, debt instruments, and inventions of an individual conceived or first actually reduced to practice in the performance of work under a grant; valued under $5,000.

 
BackToTop

III.  Office for Grants Functions and Services
The mission of the NWACC Office for Grants is to assist faculty, staff, and administrators seek, apply for, and receive external funding to promote innovation and meet the educational needs of students.  Located within the Division of Advancement, the Office for Grants works to advance the Mission, Vision and Strategic Outcomes (Ends) of the College, thus supporting the development of projects and programs that foster teaching and learning strategies designed to enhance student success.

The Office for Grants provides the following functions and services:

    • Develop and administer all policies and procedures of grants at NWACC;
    • Research funding opportunities;
    • Provide to NWACC faculty and staff members announcements of RFPs and other notifications of special grant opportunities;
    • Assist in the grant writing process;
    • Provide grant writing training;
    • Assist with project budget development and personnel requests;
    • Review all grant proposals prior to their submission to external agencies/organizations;
    • Manage the internal grant approval process;
    • Coordinate grant submissions;
    • Provide grant management training;
    • Grant administration;
    • Build and maintain relationships with funding agencies and organizations; and
    • Maintain records on all grant proposals and reports submitted by the College.

IV.  Authority
Grant agreements are typically made between external funding agencies and the College, not between such funding agencies and individual persons at NWACC.  Accordingly, individual faculty or staff members are not authorized to apply for or accept grants on behalf of the College unless given explicit authority by the Office for Grants to do so.  Faculty and staff members should contact the Office for Grants for assistance in securing the necessary authorized signature(s) to apply for and accept grants.

 
BackToTop

V.  Proposal Submission & Approval
NWACC faculty and staff considering applying for external funding must complete the Pre-Proposal Grant Request process before submitting an application or proposal to an external funding agency.  The Pre-Proposal Grant Request Form must be submitted a minimum of three weeks prior to the proposal deadline.  The AVP for Grants and Institutional Research will present the potential funding opportunity to the Cabinet for approval. 

Once a potential funding opportunity has received approval from the Cabinet, the grant proposer may begin developing the grant proposal/application process.  All final proposals/applications to be submitted for external funding MUST receive prior administrative approval by a number of NWACC officials and be submitted to the Office for Grants seven working days prior to the submission deadline. This includes proposals requesting faculty fellowships, sabbatical, or travel support. In addition, all pre-proposal correspondence, including any letters of intent, is to be routed through the Office for Grants for approval before submission.

Please review the full Grant Application and Management Procedures for the complete procedure regarding proposal submission and approval prior to seeking external funding.  No formal proposal may be submitted to any external agency without final administrative approval as outlined in the Grant Application and Management Procedures.  Any proposal submitted without this approval will be withdrawn. 

The Office for Grants reserves the right to require a greater amount of time than the prescribed three weeks for pre-proposal grant requests and/or the prescribed seven working days for final approval dependent upon the size and complexity of the proposal.

VI.  Conflict of Interest
As a part of the grant application process, the grant proposer must positively state on the Pre-Proposal Grant Request Form that there is an absence of a financial or other interest or affiliation held by them or a member of their immediate family in the funding agency or in companies from which goods and services will be obtained under the supported activity.  This statement must also cover any PIs, Co-PIs, co-grant proposers and other grant-supported staff at NWACC.

Should there be a conflict of interest the grant proposer must disclose that conflict by completing the Disclosure of Financial Interests Related to Sponsored Projects Form.   

For purposes of submitting an external grant application from NWACC to an external funding agency, the grant proposer must submit the Disclosure of Financial Interests Related to Sponsored Projects Form.  Conflict of interest exists if he or she (or any member of the immediate family) has a significant financial conflict of interest in the project, defined as $10,000 or 3% ownership or a $10,000 income per annum from the proposed external funding agency.  For additional guidance on the details of this requirement, contact the Office for Grants.

 
BackToTop

VII.  Cost Principles and Practices
The purpose of the Cost Principles and Practices policy is to ensure compliance with all applicable Federal, State, and NWACC rules and regulations.  Failure to adhere to these cost principles and practices may result in cost disallowance, penalties, and/or fines.  It is the responsibility of the PI, Department Chairs/Deans, and Administrators to understand and comply with this policy.

  1. Administration

It is the policy of NWACC that all sponsored program funding (e.g. grant funding, external funding) acquired under the name NWACC or the NWACC Foundation will be financially administered by the NWACC Finance Office.  All sponsored programs will adhere to Federal, State of Arkansas, and NWACC administrative policies along with any policies designated by the external funding agency.  Federal, State of Arkansas and NWACC administrative policies will have precedence over any and all external funding agency policies.

  1. Application 

These practices must be consistently applied in the like circumstances for all sponsored program funding and any other institutional activity affecting sponsored program funding.  While the PI has primary responsibility for overseeing the expenditure of project funds, all personnel involved in charging costs to sponsored programs must comply with this policy in order to meet federal costing standards and ensure that costs are allocated in a manner that accurately reflects the expenses incurred for the benefit of the project.

  1. Definitions

Direct Cost- Those costs that can be identified specifically with a particular project, an instructional activity, or any other institutional activity or that can be directly assigned to such activities relatively easily with a high degree of accuracy.

Indirect Cost- Those costs for expenses incurred when the College assumes responsibility for otherwise externally funded grants for projects and programs; costs not directly identified with a single activity, but identified with two or more final activities.  Also known as Facilities and Administrative Costs.

 
BackToTop

Examples of Direct and Indirect Costs

Direct Costs
Indirect Costs

Salaries, wages, fringe benefits for faculty, consultants, contractors, other technical and personnel who are necessary to meet the goals of the project

Scientific and technical equipment, computer costs, software

Long-distance phone, fax

Project-specific supplies and equipment

Project-specific services

Postage for project-specific use

Participants, subject costs

 

Travel, lodging, etc.
IndirectCosts
  1. Direct Costs

For expenditures to be considered allowable as a direct cost, they must be:

  • reasonable and necessary for the performance of the project;
  • allowable under the terms and conditions of the award document or agreement and by OMB Circular A-21; and
  • allocable and easily identifiable as having a direct benefit to the project or activity being performed.
  1. Indirect Costs

Included in the grant administration will be the budgeting and collection of indirect or administrative costs for all sponsored programs applied for under the name NWACC or NWACC Foundation.  It is required that the full amount of indirect or administrative costs as described in the grant solicitation or foundation policies be solicited in the submitted sponsored program proposal.  If no indirect or administrative cost rate is described in the solicitation but are available, an agreed upon rate that does not exceed the NWACC federal negotiated rate shall be requested.  This agreed upon rate will be approved by the Vice President for Finance, the Vice President for Advancement, and the Associate Vice President for Grants and Institutional Research in writing before the final budget is approved.  Any and all indirect and administrative costs will be divided between the following parties who provide support for sponsored programs at the prescribed percentages and placed in a designated fund and org.

NorthWest Arkansas Community College30%
NWACC Finance and Administration20%
Office for Grants30%
Applying Division or Department20%

 

 

Adjustment in percentages received by applying divisions or departments will be made for those PI/Project Directors who do not expend their awarded funds.

 
BackToTop

VIII.  Cost Sharing and Matching Funds
Cost sharing or matching funds is that portion of project costs not borne by the external funding agency. Some external funding agencies require cost sharing or matching for grants.  In cases where the grant application requires cost sharing or matching, explicit approval from the Office for Grants to proceed with the grant application must be received prior to commencing the external funding application process.

Direct Cost Sharing- involves actual dollars contributed by NWACC to the project as a part of the overall project budget.

In-Kind Cost Sharing- involves a determination of the value of services that NWACC agrees to contribute toward a project (e.g. space, supplies, etc.).

Matching Funds- typically used to indicate that a contribution of actual dollars is needed to match (at various ratios) an external funding agency's contribution.

IX.  Use of External Funds to Pay Salary
NWACC will not accept external grant funding which would require faculty effort exceeding a regular full-time load and would increase an employee's total compensation for the academic year beyond the agreed upon full time salary (not including stipends). In no case will federal and private funds be used to pay an employee more than 100% of his or her regular academic year compensation. Summer school is not considered part of the regular academic year. 

X.  Use of NWACC Facilities
Persons wishing to propose external grants involving the use of NWACC facilities as a part of the project must consider several important points as the project is developed and its proposed budget is formulated. Any use of any NWACC facilities must be approved in advance by the individual who has the authority to make a commitment for the use of the particular space in question.

NWACC facilities must be used in a manner consistent with the intended purpose of the space in question. Priority will be given to those activities related to the academic,  cultural, and community programs of the College, and requests to use NWACC spaces in connection with external grants must not interfere with the primary purposes for which the spaces are usually used (e.g. as a classroom, chemistry lab, meeting room for college-sponsored groups, and so forth). The facilities must be used in a safe, professional manner and in ways that will not endanger the College community or the general public.

To ensure accurate communication, the grant proposer should seek to have written confirmation that the necessary space(s) will be available at the times required for the proposed external grant.

In some cases, use of NWACC facilities may entail a charge for use of the space. Such costs, if applicable, should be added to the proposed budget for the project at a rate of $28 per square foot. Depending on the nature of the grant activity, use fees are variable. Before submitting a proposed grant for internal review prior to its submission to the external funding agency, the grant proposer should contact the relevant NWACC office and determine what charges, if any, will be required for use of NWACC space on the project.

XI.  Use of NWACC Equipment
If a proposed external grant will require the use of NWACC owned equipment as a part of the project, such use must be approved by the department head or program director of the area where the equipment resides and is normally used.

If applicable, the arrangement to use the equipment must include reimbursement of the cost of use of the equipment. Cost of use fees or supplies required to operate the equipment should be included as part of the direct costs of the proposed grant. Laboratory supplies (e.g. chemicals) and specialized shop or equipment costs may be treated as a direct cost so long as they are directly identifiable and clearly relevant to the intended research objective of the project being proposed.

The grant proposer must arrange to use the equipment on a schedule that will not create an interference or conflict with the ways that the equipment is normally used (such as in connection with teaching a laboratory course).

 

 
BackToTop

XII. Equipment Procurement with External Funds
In general, fixed and moveable equipment are considered fixed assets of NWACC and, as such, are owned by the College and not by a specific individual, department or operating unit. The College has sole ownership of all equipment acquired regardless of source of funding or method of acquisition. All purchases of equipment using grant funds must be requisitioned and purchased through the College's Purchasing Department.

In certain rare cases, there may be exceptions to this general policy. If the equipment was acquired through a sponsored project, and the federal government or other external funding agency explicitly retained title to it, that equipment would not be considered a fixed asset of NWACC. If the external funding agency furnished equipment merely for the duration of the project, such equipment would also not be a fixed asset of NWACC. Equipment acquired on short-term loan from another institution, or leased, is similarly not a fixed NWACC asset.

Should a faculty member choose to leave NWACC prior to the conclusion of a sponsored project, and seek to transfer this project and its equipment to a new institution, the faculty member must contact both the external funding agency and the Office for Grants in order to determine if such a transfer is possible, and under which conditions. Typically, the external funding agency will terminate the existing award and then issue an award to the new institution. Approval of a request to transfer equipment purchased through the grant will be dependent upon the nature of the ownership of the equipment (whether or not it became a NWACC fixed asset or title to the equipment was retained by the external funding agency).

XIII. Materials and Supplies Procurement with External Funds
Whenever grant funds are used to purchase any materials used on a sponsored project made with NWACC grant funds (such as software, books, DVDs, supplies and the like), those materials become the property of the College. They have been purchased with funds that have been conveyed to the College for use on a specific project and, as such, are not the personal property of the researcher but are the property of the College. These items are not to be retained by the researcher but are instead to be turned over to the College when the sponsored project is completed. Contact the Office for Grants  for instructions regarding the appropriate disposition of any items purchased with external grant funds that will have a useable life after the completion of the sponsored project.

All purchases of goods and services must follow Government and College regulations, such as using mandatory sources and observing bidding requirements. Contact Purchasing for an explanation of the proper procedures.  All purchases of materials and supplies using grant funds must be requisitioned and purchased through the College's Purchasing Department.

Should a faculty member choose to leave NWACC prior to the conclusion of a sponsored project, and seek to transfer this project and its materials to a new institution, the faculty member must contact both the external funding agency and the Office for Grants in order to determine if such a transfer is possible, and under which conditions. Typically, the external funding agency will terminate the existing award and then issue an award to the new institution. Approval of a request to transfer materials already purchased through the grant will be dependent upon the nature of the ownership of the item (whether or not it became a NWACC fixed asset or title to it was retained by the external funding agency).

XIV.  Administrative and Clerical Support on External Grants
As a general rule, it is normally not appropriate to include a request for secretarial or administrative support in the proposed budget for external funding. The federal government, for example, has determined that such an expense is an indirect cost that would be covered by the facilities and administrative (F & A) cost added to the proposed budget (See OMB Circular A-21, section F-6-B-2). In some cases, however, it might be appropriate to include administrative and secretarial costs as a separate budget item if the activities to be performed are significant and would amount to more than what would reasonably be expected to be performed as a part of normal administrative support. Another important factor is whether or not the guidelines provided by the external funding agency make explicit reference to how to handle secretarial support as a part of the budget request. Contact the Office for Grants for guidance if questions arise regarding how to accomplish the clerical program support that will be required as a part of a particular sponsored project.

 
BackToTop

XV.  Hiring Grant-Funded Employees
If an awarded external grant budget includes an amount for hiring employees, all hiring activities must be processed through the established procedures for hiring classified employees in a provisional position as set forth by the NWACC Office of Human Resources.  A grant-funded position is classified as provisional, meaning that the position will end when the external funding ends. 

The first step in this process is to contact the Office for Grants and submit a position request. Once the request has been approved, the next step is the Position Development, which will be handled by the requesting department and NWACC Office of Human Resources.  Before requesting that the position be developed, the grant proposer must have already established a grant fund number through the Finance Office. The existence of a grant fund number is essential in order to properly charge the grant for the costs associated with the employee being hired.

Current appropriation positions should not be used for new positions created with grant funding, since these are temporary positions hired for the duration of the grant.  If and when a grant-funded position becomes a permanent position, then a permanent appropriation act position should be used for that employee.

Provisional positions should be applied for and used for all new positions created by funding from an external source (e.g. grants, etc.) where the salaries and fringe benefits of the new position will be paid for using grant funds.  For further details regarding hiring grant-funded employees, please review the Grant Application and Management Procedures.

XVI.  Grant-Funded Travel Expenses
As a public institution of the State of Arkansas, NWACC administers and complies with the State of Arkansas Travel Regulations.  All employees of NWACC traveling on behalf of the College in relation to grant supported activities are required to comply with the travel policy and procedures outlined in the NorthWest Arkansas Community College Administrative Policies and Procedures. 

Unless otherwise set forth in the Terms and Conditions of the grant agreement, travel reimbursement is NOT a per diem and is to be claimed for actual expenses for meals and lodging not to exceed the maximum allowable rates as listed in the Federal Travel Directory  plus applicable Sales Tax.

XVII. Institutional Approvals for Specific Types of Research
All research projects submitted on behalf of the College and its faculty and staff must comply with all applicable federal, state, and institution policies and regulations before they are approved for submission.

It is the policy of the College that, prior to initiation, all research activities by faculty, students, or employees that involve the use of human subjects (i.e., individuals about whom data or information is obtained) be approved by the NWACC IRB or be certified exempt from review. Failure to gain committee approval prior to collecting data can result in a forfeiture of data or other penalties.

The NWACC IRB serves to ensure that participants in research are treated fairly and ethically. Research projects conducted by members of the NWACC community that involve human participants must be submitted to the NWACC IRB for approval unless it meets the criteria for exempt status. The review process must be completed before a grant proposal is approved for submission. To start the review process please download the application here (IRB APPLICATION) and submit to Lisa Anderson BH 3012, (479) 986-4025.

 
BackToTop

XVIII. Grant Processing
All acceptance of grant awards, of checks or other forms of payment, and the establishment of new funds for sponsored projects must be coordinated through the Office for Grants.

  1. Notification and Acceptance of an Award

All notifications of grant awards must be forwarded immediately to the Office for Grants.  The Office for Grants will forward copies of the award notification to the Executive Director of Accounting/Controller, the Director of Budgets, the Director of Human Resources, the Vice President for Finance, the Senior Vice President for Advancement, the Director of Public Relations, and others as appropriate.  The notification and acceptance of an award process can be reviewed in further detail in the Award Notification & Acceptance procedures.

  1. Acceptance of Grant Payments

The NWACC Finance Office will not accept grant payment checks forwarded directly by project directors. All grant checks must be forwarded to the Office for Grants. The College will coordinate acknowledgement of grant payments and will deposit grant payments into the project fund.  Faculty and staff who receive grant payments should not make any direct deposits into their project fund.

  1. Establishment of Fund

The Office for Grants will provide the Finance Office with information needed to establish a budget fund for the project.  Project directors will be notified when this information has been forwarded to the Finance Office. and funds are available. Before funds are made available, Projector Directors/PIs must meet with Restricted Accounts.

  1. Modifications to Grant

The PI, in cooperation with the Director for Grants and Institutional Research and the Controller, will handle all modifications, contract changes and/or negotiations with the external funding agency.

XIX.  Reporting Requirements
Project directors/PIs are solely responsible for the prompt submission of any operational, financial, progress, final and any other reports required by external funding agencies.  Copies of all progress and final reports must also be filed with the Office for Grants.  The PI should review the reporting procedures  for all required reports.

XX. Effort Reporting and Certification for Sponsored Activities
The purpose of the Time and Effort Reporting and Certification Procedure is to explain the process used at NWACC to carry out Time and Effort Reporting and Certification. Failure to comply with these procedures can result in serious adverse consequences to both NWACC and the employees. All employees who are subject to time and effort reporting requirements or who are responsible from implementing any part of the time and effort reporting system are therefore expected to review, understand and comply fully with the procedures in this section. Any questions concerning these procedures should be directed to NWACC Office of Restricted Accounts.
 
A.     Employees Requirements for Time and Effort Reports and Certification
Employees who meet either of the following criteria must complete a Time and Effort Report: 1) the employee’s salary is charged in whole or in part directly to a sponsored project, 2) the employee expends committed effort on a sponsored project, even though no part of the employee’s salary is charged to the project.
 
B.     Generating Time and Effort Reports
The following are the various types of effort reports: 1) monthly effort/activity reports for classified/non-classified employees, 2) time sheets for hourly employees (staff/students), and 3) end-of-semester effort reports for faculty and graduate students.  These reports are completed on a monthly basis and require original signatures from the employee and the employee’s immediate supervisor or the PI or the project director of the individual listed on the report. All time and effort reports should be retained in the office of the sponsored program.
 
C.      Certifying Time and Effort
Time and effort certification occurs quarterly. All time and effort certification forms must bear the ORIGINAL signature of the employee and the employee’s immediate supervisor or the principal investigator or the project director of the individual listed on the report and the employee’s AVP or VP. Completed time and effort certification forms are return, signed and dated to the Office of Restricted Accounts. The certification forms will be kept for at least three years after the grant or contract officially ends.
 

Time and effort is not based on a 40 hour work week. Time and effort must equal 100% regardless of the number of hours worked in a week. Non-grant related activity is restricted to a total of two hours per week in accordance with Education Department General Administrative Regulations (EDGAR) and OMB Circulars (A-21 and A-87) concerning time and effort reporting.

XXI.  Project Director/PI Departure from the College
Any faculty or staff member who is a PI, director or co-director of a sponsored project, and who believes he or she will depart the College before the project is completed, should contact the Office for Grants as soon as that realization is made.

  1. Grants are considered agreements between the University and external funding agencies.  The departure, due to transfer, termination, illness or death, or other causes, of a project director/PI will presume that a modification of the grant agreement is required.  Project continuance at the College will depend upon the terms of the modified grant agreement being established between the College and the external funding agency.
  1. In certain instances or project director/PI transfer to another academic (or possibly non-academic) institution, an external funding agency may wish to transfer the grant funds to the project director/PI's new institution.  In such cases, the College will generally make every effort to facilitate that process.
  1. Faculty and staff members who serve as sponsored project directors/PIs, and who know that their departure from the College appears possible or likely before the terms of their grant agreement with an external funding agency are fulfilled, should contact the Office for Grants immediately for guidance and assistance.
     
    BackToTop

XXII.  Federal Guidelines, Regulations, and Compliance Requirements
The following series of circulars from the Office of Management and Budget (OMB) are relevant to research administration of federally-awarded grants.  NWACC will submit external grant proposals that are in compliance with the guidelines and regulations outlined in the relevant circulars listed below.

  • A-21 -  Cost Principles for Educational Institutions
  • A-110 - Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations
  • A-133 - Audits of States, Local Governments, and Non-Profit Organizations
  • Federal Acquisition Regulations (FAR)
  • Most federal contracts incorporate a number of FAR clauses that must be reviewed by relevant NWACC officials and offices before accepting the agreement.
  • Code of Federal Regulations (CFR) A listing of the general, permanent rules published in the Federal Register by executive departments and agencies of the federal government.

 

For questions/comments on this content, please contact Shauna Sterling.