Policies
Identification and Management of Sponsored Awards Policy
The purpose of this policy is to provide a framework to facilitate the appropriate classification of private support received by the University as either a gift or a sponsored award. This categorization is essential for ensuring that the appropriate office or department manages the funding in a manner consistent with such classification and for ensuring that it is treated correctly for tax and accounting purposes.
Review and Approval of Sponsored Project Documents
The purpose of this policy is to require a comprehensive pre-submission review of all sponsored project proposals to ensure that they are complete and accurate and to establish a process in order to:
- Ensure that the Principal Investigator, acting on behalf of the university, is compliant with (i) all relevant federal and state regulations, and (ii) all relevant university policies;
- Avoid over-commitment of the university resources and faculty and staff time;
- Ensure that proposals, when awarded, will not create unforeseen financial burdens for the university;
- Avoid situations where an award is declined because the university is unable to meet the commitments set forth in the proposal;
- Ensure that all proposals receive appropriate review and awards are accepted by the Authorized Organization Representative (AOR) who has the authority to sign on behalf of the university, etc.
Principal Investigator Eligibility and Assurances Policy
The purpose of this policy is to ensure that sponsored projects are led by qualified Principal Investigators who have the technical competence and administrative experience to assume responsibility for successful accomplishment of all aspects of the sponsored project. It is the policy of the university that only eligible personnel may serve as Principal Investigators since there must be direct accountability to the university, the Sponsor, and any governmental regulators.
Facilities and Administrative Cost Recovery and Distribution
The purpose of this policy is to ensure that Facilities and Administrative Costs (“F&A Costs”) are recovered to the maximum extent allowable and used per this policy to support and encourage research and other sponsored programs at the University.
Facilities and Administrative Negotiated Rate for Arcadia University (Effective 6/1/2024 to 5/31/2028)
Financial Conflict of Interest Policy
The purpose of this Policy is to promote objectivity in research by establishing guidelines for reporting and resolving financial conflicts of interest for research. This policy is intended to comply with regulations regarding financial conflicts of interest (“FCOI”) for Public Health Service (“PHS”) funded research, 42 C.F.R. Part 50, Subpart F and 45 C.F.R. Part 94 (the “Regulations”). This policy applies to all investigators working on a sponsored project.
To access the FCOI requirements and procedures please visit our Form, Templates, and Procedures page on MyArcadia.
Allowable Costs for Sponsored Research and Programs
This Policy is intended to ensure responsible stewardship of sponsored funding at Arcadia University. The Federal government’s Office of Management and Budget’s (OMB) Guidance for Grants and Agreements at Title 2 of the Code of Federal Regulations, Part 200, Subpart E, entitled “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Cost Principals”),” sets forth principles to be followed by federal funding agencies for the uniform administration of grants, cooperative agreements, and other funding instruments.
Subrecipient Determination and Monitoring on Sponsored Awards
This Policy is intended to ensure responsible stewardship of Sponsored Awards to the University. Prior to passing through funds to other entities, the University shall use its judgment in making case-by-case determinations of whether a party receiving funds will be in the role of a Subrecipient or a Contractor. As presented in the associated Federal Subaward Procedures and Subrecipient Monitoring Guidelines, prior to issuing a Subaward, the University shall evaluate each Subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions from the Pass Through Entity based upon a data-informed risk assessment questionnaire and apply a monitoring level appropriate to the degree of risk for the Subrecipient.
Institutional Policy on Research Misconduct
This is a University-wide policy which applies to the research proposed, conducted or reported at Arcadia University by all Arcadia related individuals including those with the appointment or official affiliation. Arcadia University believes that research misconduct has no place in the academic setting. Arcadia faculty, staff, and students are expected to conduct research in accordance with the highest ethical standards and all relevant regulations.
Effort Certification Policy
This policy describes the procedure for Arcadia University to comply with the requirements of the Federal Office of Management and Budget’s (OMB) 2 CFR §200.430 which covers compensation for personal services, including requirements for effort certification at educational institutions. The main purpose of effort certification is to verify that salaries and wages supported by sponsored funding were distributed in accordance with the actual level of effort provided. Effort certification is required for every University employee whose salary or wages are either directly charged to a sponsored account or whose salary or wages are allocated as cost-sharing for a sponsored account.
To access the Effort Certification procedure please visit our Form, Templates, and Procedures page on MyArcadia.
Export Control Policy
This Policy applies to all University Members whose activities, including but not limited to, research activities, grants, contracts and cooperative agreements, may trigger export controls. Export controls are designed to ensure that sensitive information, technology, software, biological and chemical agents, and equipment are not utilized for purposes other than their intended use. It is the responsibility of all University Members to be aware of and comply with these laws and the University’s policies and procedures. Violation of this Policy may have severe criminal, civil and administrative sanctions, including possible disciplinary action.
Davis-Bacon Act Compliance Policy
The purpose of this Policy is to ensure compliance with the Davis-Bacon Act (DBA) codified as 40 U.S.C. 3141-3148. Under the provisions of the DBA, contractors and subcontractors must pay their laborers and mechanics directly employed upon the site of the work no less than the locally prevailing wages and fringe benefits for corresponding work on similar projects in the area.
Cost Transfer Policy
The purpose of this Policy is to ensure that cost transfers to and from departmental budgets and sponsored accounts take place according to the specified guidelines set forth in this Policy. The University recognizes that cost transfers are sometimes necessary to correct a bookkeeping or clerical cost misclassification in the original charges, and to allocate closely related work that may support more than one Sponsored Project. Frequent, late, or inadequately explained cost transfers raise serious questions about the propriety of the transfers and call internal controls into question which may result in audit disallowances and monetary paybacks including penalties and fines.