The following documents should be routed through the Office of Contracts and Grants throughout the life of the project: Payroll reallocations, expenditure reallocations or corrections, and contracts for services. During the last six months of an award, all requests for equipment expenditures should be processed through the Office of Contracts and Grants. If the purchase of equipment has been approved, equipment purchases should be made at least six months prior to the expiration date of the award. This will assure receipt of equipment prior to the expiration date and avoid disallowances.

Overload

Overload is usually not allowed on sponsored project funds. Contact your Research Administrator for additional information.

Accrued Time

If either full-time personnel or part-time continuing, benefits eligible personnel are employed on a grant or contract, they accrue vacation and sick leave time. Therefore, the grant or contract on which they are paid is responsible for payment of the accrued vacation at the time of the employee's termination. If the grant or contract does not have sufficient funds to pay the accrued vacation, it is the responsibility of the employing department to provide the necessary funding. It is the responsibility of the Principal Investigator to ensure that these employees accurately report their vacation time prior to the project's expiration. Should death occur to either full-time personnel or part-time continuing, benefits eligible personnel while employed on a grant or contract, then the grant or contract on which they were paid is responsible for the payment of all death claim benefits. If the grant or contract does not have sufficient funds to pay the death claim benefits, then it is the responsibility of the employing department/college to provide the necessary funding.

Change in Scope

Changes in the scope/direction of the research project, in senior project personnel, or in the terms and conditions of the award itself require the approval of the awarding agency. These approval requests must be initiated by the Principal Investigator and countersigned by the Director of the Office of Contracts and Grants. The Research Administrator should be contacted as soon as the Principal Investigator is aware of a change in any of these categories.

Technical/Administrative Problems

Problems or questions of a technical nature may be addressed directly to your sponsor program officer. However, any requests of an administrative nature which require the sponsor's approval, such as requests for re-budgeting or date extensions (no-cost extension) must be countersigned by the Office of Contracts and Grants. This practice ensures that all agency requirements have been met.

Orders after Expiration

Orders placed for materials which are not received by the expiration of a grant or contract will be disallowed. In cases regarding outstanding orders and over expenditures at termination, the Principal Investigator(s) and Department Business Manager will be notified by the Research Division's fiscal reporting section regarding resolution. In order to be included as a billable cost to the agency, all encumbrances must be paid and liquidated within 30 calendar days following cost center expiration. If arrangements are not made within that period, then a department or college cost center must be provided to which to move the charges. Therefore, it is imperative that departments work closely with Accounts Payable concerning potential problems with outstanding purchase order encumbrances or with the appropriate on-campus service center for outstanding encumbrances in order to ensure both payment and liquidation within the 30 days’ time limitation.

Records Retention

Regulations require the University to maintain for audit purposes all project-related records, both financial and technical (including technical reports, lab notes, and all institutional committee approvals such as human subject, animal care, radiation, etc.) for a minimum of three years AFTER the acceptance of the final financial and/or audit report. Therefore, Principal Investigators, Project Directors and Business Managers should retain complete grant/contract files for a minimum of five years after project termination. After that date, check with the Office of Contracts and Grants to ascertain whether longer retention is necessary.

Biological Substances

Biological substances which are either viral (capable of causing epidemics) or toxic (capable of being refined for biological weapons) in nature, are defined as select agents and regulated by the Federal Government. A list of select agents is maintained by the Centers for Disease Control. If your research involves any of these select agents, contact your Research Administrator.

Export Controls

The export of certain technologies, software and hardware is regulated and controlled by Federal law for reasons of national security, foreign policy, prevention of the spread of weapons of mass destruction and for competitive trade reasons. The University and all its employees are required to comply with the laws and implementing regulations issued by the Department of State, through its International Traffic in Arms Regulations (ITAR), and the Department of Commerce, through its Export Administration Regulations (EAR). Before beginning work, PI must review the projected research to determine whether it is impacted by export control laws and regulations. The laws prohibit the unlicensed export (including the dissemination of information to foreign researchers or students in UH classrooms and laboratories) of certain materials or information. During the course of the project, PI must re-evaluate his or her determination when changing the scope or adding new staff to the project if such changes alter the initial determination. If the PI determines that export control laws and regulations impact the project, he or she must immediately contact the Office of Contracts and Grants before exporting any information, technology, software, hardware, or item. This will allow the University enough time to obtain the required export license.

Human Subjects and Animals

If your research involves the use of human subjects or animals, research may not begin until approval has been received from the appropriate university compliance officer.

Conflicts of Interest

An annual certification of compliance with the "Conflict of Interest Policy for Academic Staff" indicating the disclosure of actual or potential conflict of interest must be current and on file in the Division of Research prior to expending funds. Conflicts must be reported as they relate to significant financial interests which could affect the design, conduct, outcome, or reporting of research or educational activities funded by an external sponsor. See the policy and certification forms or your college dean for more information.

General Purpose Items

General purpose items are those items not limited to research, medical, scientific or other technical activities. Examples might include office equipment and furnishings, modular offices, telephone networks, information technology equipment and systems, air conditioning equipment, reproduction and printing equipment, and motor vehicles. Expenditures for general purpose items are generally not allowed on a federal grant. Contact your Research Administrator for additional information.

Consultants

Before a consultant may begin work, a consulting (service) contract signed by both UH and the consultant must be in place. The contract must include the following information: the services to be provided the period of performance and the consultants availability the qualifications of the consultant to perform the work the rate of pay. Payment for consultant services should be comparable to the normal or customary fees charged and received by the consultant for comparable services, especially on non-government contracts and grants. Consultants should be chosen using a competitive selection process; otherwise, sole source justifications should be clearly outlined. The consulting contract form is available on the Division of Research website.