UNT Research and Innovation 2020 Annual Report by University of North Texas

research.unt.edu/2020report

Research & Innovation ANNUAL REPORT

2020

EXECUTIVE SUMMARY UNT’s Division of Research and Innovation has had an incredible past year filled with achievements despite the challenges presented by the global pandemic. More faculty than ever are engaged in funded research, and collaborations with national laboratories and industry are on the rise. FY 2020 was a record year for total research expenditures, which increased 6%, for a total of $83.5 million. For FY 2020, UNT’s new research awards reached a high of $34.5 million. This was an increase of 14% over new awards from the prior year. Additionally, a significant effort was made this year to increase the grantsmanship training to empower faculty to be more aggressive and successful in receiving grants from top funding agencies. As a result, during FY 2020 faculty submitted 616 new proposals for funding, representing a 15% increase in submissions.

Dedicated to expanding the research enterprise at the university by supporting and enabling faculty, the Division of Research and Innovation has undergone major restructuring efforts this year to include the creation of the Research Commercialization Agreements (RCA) unit and a revised Grants and Contracts Administration (GCA) unit. This Research Annual Report details these activities and successes of the Division of Research and Innovation from Sept. 1, 2019 through Aug. 31, 2020 (FY 2020). This report also includes an outline of the division’s mission, core values and key initiatives, as well as a By the Numbers section that highlights the significant progress faculty, staff and administrators have made this year, as well as the direction planned for the future.

TABLE OF CONTENTS

Division Overview

Strategic Planning and Implementation

Grow UNT’s Research Portfolio

Promote Integrity in Research

Expand Researchers’ Work with the Private Sector

By the Numbers

Unit Reports

Appendix: New and Revised Policies and Procedures for FY 2020

Texas NRUF Aspirations The University of North Texas aspires to achieve Texas National Research University Fund (NRUF) status. To reach this status, universities are required to meet a certain threshold among a series of metrics. Those metrics include reaching $45 million in restricted research expenditures. To accomplish this aspiration, the Division of Research and Innovation has implemented a plan with goals and strategies that are designed to significantly increase the university’s grantsmanship capability while maintaining the utmost integrity and efficiency.

DIVISION OVERVIEW The mission of the Division of Research and Innovation reflects a commitment to serve and support the faculty and staff at UNT with a primary purpose of collectively enhancing research. The core values outline the focus of the division’s employees as driven and committed team members. Mission The mission of the Division of Research and Innovation is to expand and promote sponsored research at UNT by supporting faculty and student researchers in attaining world-class status in their discipline, expanding the knowledge of their field and attracting resources to support innovation and discovery across the arts, humanities and STEM disciplines. Core Values Integrity — Committed to creating knowledge with a high degree of honesty and accuracy

Efficiency — Dedicated to the strategic and focused use of resources

Interdisciplinary Focus — Focused on the development of solutions requiring complex multidisciplinary approaches

Individual Growth — Focused individuals in and of themselves as part of multidisciplinary teams

Partnerships — Dedicated to building connections in teams focused on solutions to society’s biggest challenges

Diversity — Committed to empowered decision-making and the inclusion of talented individuals from a variety of different backgrounds

Innovation — Committed to identifying and supporting new and creative approaches

Mark R. McLellan Vice President for Research and Innovation

Victoria Smith

Katie Herring

Director for Budget and Operations

Executive Assistant

Pam Padilla

Charles Tarantino

Michael Rondelli

Vacant

Associate Vice President for Research and Innovation

Assistant Vice President for Grants and Contracts

Associate Vice President for Research Commercial Agreements

Naomi Wood

Emily Locey

Steven Tudor

Meagan Sabatino

Assistant Director for Research Development

Director for Pre-Award

Director for Licensing

Research Compliance Manager

Application Support Manager

Jamie Peno Director for Research Integrity and Compliance

VICE PRESIDENT FOR RESEARCH AND INNOVATION

MARK MCLELLAN

Mark McLellan, vice president for research and innovation, a 30-year veteran of university research leadership, joined UNT in 2019. McLellan came to UNT from Portland State University where he oversaw research across nine colleges and schools and implemented several initiatives that resulted in a significant increase in external research funding. McLellan also served seven years as vice president for research and dean of the School of Graduate Studies at Utah State University, where he led a major research expansion and achieved a record level of research funding. Prior to his service at USU, McLellan was a tenured professor and department chair at Cornell University; director of a multi-college research center at Texas A&M University; and dean for research at the University of Florida. McLellan’s service includes 10 years with the U.S. Food and Drug Administration, where he chaired the Science Advisory Board from

2016 to 2019. McLellan was selected in 2016 as the inaugural chair of the U.S. Department of Agriculture’s Science Advisory Council while serving on the USDA National Agricultural Research, Extension, Education, and Economics Advisory Board. He co-chaired the Association of Public and LandGrant Universities/Association of American Universities Task Force on Laboratory Safety, and he served as a member of the APLU/AAU Task Force on Public Access. McLellan is a distinguished and accomplished food scientist, focused on fruit and vegetable process technologies, with 46 peer journal publications, 10 book chapters, seven major technical reports for the federal government and five published software programs. McLellan earned his bachelor’s degree in food science from the University of Massachusetts Amherst and his Master of Science and Ph.D. in food science from Michigan State University.

ASSOCIATE VICE PRESIDENT FOR RESEARCH AND INNOVATION

PAMELA PADILLA

Pamela Padilla, professor of biological sciences and former associate dean of research and graduate studies in the College of Science, was named associate vice president for research and innovation at UNT in the fall of 2019. Padilla joined UNT in 2002, and in 2010, she earned the UNT Early Career Award for Research and Creativity. She was a Faculty Leadership Fellow from 2015 to 2016. Her research, which has been continually supported by either the National Institutes of Health or the National Science Foundation, focuses on how environmental and dietary stress affects living organisms at the cellular, genetic and molecular levels as a means to model human health issues including ischemia and diabetes. She has received numerous fellowships and grants including an NSF CAREER award.

In 2021, Padilla began her role as president for SACNAS, the Society for Advancement of Chicanos/Hispanics and Native Americans in Science, the largest STEM diversity organization in the country. She also was recognized as one of 100 most inspiring Hispanic/ Latinx scientists in America. She was a Howard Hughes Medical Institute and SACNAS Advanced Leadership Institute Fellow in 2017. Padilla received a Science magazine Prize for Inquiry-Based Instruction in 2012 and was a National Academy of Sciences Kavli Frontiers of Science Fellow in 2008. Padilla earned her Ph.D. in biology from the University of New Mexico and conducted her post-doctoral research at the Fred Hutchinson Cancer Research Center in Seattle.

CHAPTER 1

Strategic Planning and Implementation 8

STRATEGIC PLANNING The division’s three main goals focus on improving UNT’s research portfolio, ensuring a commitment to integrity and expanding the university’s partnership with private industry. These goals serve as the division’s overall effort to guide and achieve its mission. Each goal is supported by a set of critical strategies by each of the supporting units. Each strategy will move forward through a developed set of programs, including short-term initiatives and legacy efforts, as well as new initiatives.

GOAL 1

GOAL 2

GOAL 3

Grow UNT’s Research Portfolio

Promote Integrity in Research

Expand Researchers’ Work with the Private Sector

Strategies:

1. Increase the Quantity and Quality of UNT’s Proposals

1. Improve Workflow Efficiency for IRB and IACUC Protocols

2. Improve Research Support Infrastructure

2. Increase Trainings for Compliance Programs

Strategies: 1. Encourage Faculty to Disclose New Inventions

3. Support Strategic Research Needs

2. Market IP for Licensing and Corporate-Sponsored Research

4. Communicate Internally and Externally in Support of Research

3. Support/Operate an Effective and Efficient Research Contracting Process

GOAL 1

GROWING UNT’S RESEARCH PORTFOLIO One of the most important goals for the Division of Research and Innovation is growing and strengthening the university’s research portfolio. Strategy 1: Increase quantity and quality of UNT’s proposals • Grantsmanship Training — On Dec. 9, 2019, and Feb. 27, 2020, the division hosted the first grantsmanship workshops offered by ATG Inc. as part of a comprehensive commitment to improving grantsmanship skills among faculty. Attendance at the workshops were 90 and 80 faculty, respectively. Response and feedback among those attending the workshop were overwhelmingly positive, with many congratulating the division on creating a comprehensive opportunity to improve their likelihood of success in grantsmanship. • UNT Washington D.C. Research Faculty Fellows — On Feb. 9, the division took 20 faculty to Washington. This culminated an effort that included months of work preparing these faculty for face-to-face interactions with numerous program managers in federal agencies. The agencies visited included the National Science Foundation, National Institutes of Health, National Endowment for the Arts and many more. This training opportunity was focused primarily on pre-tenure faculty to jumpstart their programs. • Research BREAKS Training Program — On May 7, the division launched a new commitment to regular training and communication with faculty researchers. The program was created with the intent to focus on narrow subjects, spending 15 to 20 minutes going into great detail on them and then opening up the floor for a Q&A discussion. Research Building the Research Enterprise and Knowledge Series (BREAKS) sessions have been well-attended with an average of 35-45 faculty attendees. These topical discussions are scheduled approximately every two weeks. • In-College Grant Editors/Managers — To support faculty grant writing efforts, the division has entered into partnerships with colleges to share the cost of hiring in-college grant editors/managers. The agreement is designed so that 50% of the salary is covered by the division year one, dropping to 30% year two

and finally to 15% for year three and beyond. The first person hired in this program was Katherine Dreyer, grant proposal manager, in the G. Brint Ryan College of Business. • Year-Round Research Training — To support faculty efforts, the division has provided targeted informational sessions that focus on specific agency programs such as the NSF CAREER or the National Institutes of Health R15/ R01 grant opportunities. Furthermore, the wellattended Research BREAKS sessions are aligned with an increase in NSF CAREER grant and NIH grant awards. Strategy 2: Improve Research Support Infrastructure • Website Revision — After years of minimal change, the division strategically redesigned the website, research.unt.edu, to create a more functional and engaging resource for faculty and staff, as well as for external audiences. Updates as necessary will be an ongoing effort. Strategy3: Support Strategic Research Needs • Seed Grants Program — The division has offered for many years a seed grants program that utilizes the associate deans for research for each college as a decision body to help identify investments needed for seed funding. The intention and focus of this program is to create initial data that is needed for the submission of grant proposals. • Faculty Startup Investment Summary — Each year, the division supports the startup funding of new faculty hires across the university. Strategy 4: Communicate Internally and Externally in Support of Research • Principal Investigator Handbook — This year, the division rewrote the Principal Investigators Handbook and published it as an online version for easy access together with structured sections. The updated version is a valuable resource for investigators to understand the rules and/or methods associated with various functions regarding research and administration.

GOAL 1: GROW UNT’S RESEARCH PORTFOLIO Strategies

Before FY 2020

FY 2020

NIH Grantsmanship Training NSF CAREER Award Training UNT Washington D.C. Research Faculty Fellows

1. Increase Quantity and Quality of UNT’s Proposals

Research BREAKS Training Program In-College Grant Editors/ Managers Semester Grantsmanship Workshop Cayuse Proposal Submission System Huron Research Administration System

2. Improve Research Support Infrastructure

Restructured Contracts and IP Systems Reorganized GCA Operations

3. Support Strategic Research Needs

Seed Grants Program Completed HPC Talon Investment UNT Research Magazine

4. Communicate Internally and Externally in Support of Research

Research BREAKS Training Q&A Principal Investigator Handbook Revision Division Website Revision

GOAL 2

PROMOTE INTEGRITY IN RESEARCH UNT has an expanding portfolio of funding from major sponsors, including agencies of the federal government. Many of these sponsors have significant requirements to ensure the integrity of research that faculty conduct with their funding. The division is charged with ensuring that faculty conduct this work with the highest degree of ethics and integrity. Strategy 1: Improve Workflow Efficiency for IRB and IACUC Protocol • RedCap Server — This year, the division took a major step forward in moving sensitive survey needs to the university’s RedCap server. This required research and understanding of how to best use the RedCap server for the university’s needs and customize those survey needs to this database. The first application of the RedCap server was to manage the IACUC program’s medical questionnaires. Additionally, RedCap was utilized as the platform to manage international affiliation disclosures. • A Triage Approach to IRB Screening — This is the first step toward moving to a rapid screening of IRB protocols to more efficiently serve faculty. The division implemented a new triage approach whereby initial submissions of protocols by faculty were screened for complexity and risk. Although this approach is in the very early stages, the division is committed to making a difference in the throughput of protocols through the review process. Strategy 2: Increase Training for Compliance Programs • Toulouse Graduate School Training — The division is increasing specialized training for the Toulouse Graduate School to assist graduate students with compliance processes. This will be accomplished by holding specialized webinars and partnering with the graduate school to ensure the university provides the most supportive resources for graduate students.

GOAL 2: PROMOTE INTEGRITY IN RESEARCH Strategies 1. Improve Workflow Efficiency for IRB and IACUC Protocol

Before FY 2020

FY 2020

RedCap Server A Triage Approach to IRB Screening

Toulouse Graduate School Training 2. Increase Training for Compliance Programs

Research BREAKS Training Program

GOAL 3

EXPAND RESEARCHERS’ WORK WITH THE PRIVATE SECTOR Strategy 1: Encourage Faculty to Disclose New Inventions • Increased Contact with Faculty Researchers — Staff gave presentations on intellectual property at departmental meetings and reached out to individual principal investigators. Principal investigators served by the division were encouraged to spread the word about their experiences to their peers. • Relationships with University Advancement — The department built relationships with University Advancement to encourage partnerships for leveraging IP for donors, foundation funding and corporate licensing. • Increased Reporting — Monthly reporting to served PIs and deans keeps them up-to-date on activities of RCA and encourages more disclosures. Strategy 2: Market Intellectual Property for Licensing and Corporate-Sponsored Research • Targeting Industry Contacts — Staff worked with inventors to target collaborators in companies. Intern marketing reports were used to find potential licensees. Licensing consultants were used to target specific contacts at large potential licensees. Staff connected with potential licensees through LinkedIn. Data mining related patents for relevance to the RCA portfolio was also used to target potential licensing opportunities. • Spinout Companies — Staff discussed with inventors and their graduate students options for spinout companies based on their technology. • Industry Visibility and Networking — Staff spoke at or attended industry events to increase visibility and push specific technologies. As one of the founding members of Inspire Frisco, Research Commercial Agreements continued to be a leader in this network of qualified entrepreneurs for startup licenses. • Murphy Center for Entrepreneurship — Research Commercial Agreements worked with UNT’s Murphy Center for Entrepreneurship to target potential licensees.

Strategy 3: Support/Operate an Effective and Efficient Research Contracting Process • Research Commercial Agreements — The new unit was formed to merge the functions of managing research contracts and technology transfer — the protection and commercialization of intellectual property developed by UNT researchers. With the change in responsibilities, the team added two new members, growing to 4.5 full-time employees. • Guaranteed Turnaround for Contract Response — Research Commercial Agreements implemented 1-, 2-, 5- and 12-day guaranteed turnaround for contract response. Response time depends on the complexity and source of the contract. • Increased Communications — Monthly reporting was instituted to keep PIs and deans up-to-date on activities of Research Commercial Agreements and encourage more disclosures. Transparency and clear processes were developed by collaborating with college administrators, and bi-weekly meetings were conducted with University Advancement. • Improved Technology — Research Commercial Agreements implemented DocuSign and Adobe Sign for fast contract review and execution. The Research Commercial Agreements page on research.unt.edu was updated with content for both inventors and potential licensees so as to provide a higher level of customer service. An email box, researchcontracts@unt.edu, was launched as the triage email that manages all contractual issues and guarantees service tracking.

GOAL 3: EXPAND RESEARCHERS’ WORK WITH THE PRIVATE SECTOR Strategies 1. Encourage Faculty to Disclose New Inventions

Before FY 2020

FY 2020

Increase Content with Faculty Researchers Relationships with University Advancement Increased Reporting Targeting Industry Contacts

2. Market IP for Licensing and Corporatesponsored Research

3. Support/ Operate an Effective and Efficient Research Contracting Process

Spinout Companies Industry Visibility and Networking Murphy Center for Entrepreneurship Research Commercial Agreements Guaranteed Turnaround for Contract Response Increased Communications Improved Technology

CHAPTER 2

By the Numbers

UNT PROFILE UNT is a Carnegie-ranked Tier One research university, which is a very high research activity university, and is the flagship university in the UNT System, located in Denton, Texas. UNT has 14 colleges and schools: • • • • • • • • • • • • • •

G. Brint Ryan College of Business College of Education College of Engineering College of Health and Public Service College of Information College of Liberal Arts and Social Sciences College of Merchandising, Hospitality and Tourism College of Music College of Science College of Visual Arts and Design Frank W. and Sue Mayborn School of Journalism Honors College New College Toulouse Graduate School®

UNT Profile Table Tenure Tract Research Faculty Members (FY 2020)

836

Total Undergraduate Headcount Enrolled

32,790

Total Graduate Headcount Enrolled

8,006

Total Headcount Enrolled

40,796

Graduate Degrees Offered

130

Total # of UNT Sponsored Awards

222

Total UNT Sponsored Awards

$39,942,619

Total UNT Proposals Submitted

610

Total UNT Dollar Amount of Proposals

$213,689,508

UNT Sponsored Awards FY 2016 - FY 2020

FY 2019

FY 2020

Change From Last Year

College of Business

$229,479

$1,432,446

524%

College of Education

$1,814,991

$2,116,357

17%

College of Engineering

$10,257,733

$18,772,086

83%

College of Health and Public Service

$2,304,626

$2,544,214

10%

College of Information

$1,047,128

$665,082

-36%

College of Liberal Arts and Social Sciences

$1,356,893

$1,337,336

-1%

College of Merchandising, Hospitality and Tourism

$160,609

$148,128

-8%

College of Music

$40,000

-100%

$10,401,581

$9,034,804

-13%

$25,000

$106,018

324%

Other2

$2,554,714

$3,786,149

48%

Totals

$30,192,754

$39,942,620

32%

UNT College Sponsored Awards

College of Science College of Visual Arts and Design

Includes: Admissions, Distributed Learning Support, Enrollment Management and Equity and Diversity, Honors College, Office of the President, Office of the Provost and Vice President of Academic Affairs, Student Affairs-General, Student Engagement, Toulouse Graduate School®, University Libraries, UNTD, UNT Systems, Vice Provost for Academic Affairs, Vice President for Student Development 2

UNT Research Award by Source FY 2020

UNT Research Award by Sponsor FY 2020

UNT Research Gift Awards FY 2016 - FY 2020

Research Expenditures

Research Expenditures Total UNT Research Expenditures (HERD) Restricted UNT Research Expenditures (NRUF)

FY 2019

FY 2020

78,691,000 83,355,000 18,182,377

16,346,249

Change From Last Year 6% -10%

Comparative Pee Tenured Track Faculty

Research Expenditures

825

$78,415,097

2,639

$640,000,000

Georgia State University

878

$150,200,000

University of California – Santa Barbara

858

$176,311,000

University of Oklahoma

1,015

$167,680,175

George Mason University

1,570

$186,000,000

735

$53,000,000

University of Houston

1,078

$195,000,000

Texas Tech University

1,600

$191,640,000

597

$116,900,000

University of North Texas (FY 2019) Arizona State University – Tempe (FY 2019)

University of Wisconsin – Milwaukee

University of Texas at Arlington

er Metrics NSF Expenditure Ranking (2017)

Research Expenditures per Faculty

205

$96,049

48.5%

$242,516

54.5%

108

$171,071

55.5%

$205,491

53.5%

$165,202

55%

146

$118,471

57%

192

$72,109

52%

125

$180,891

53%

212

$119,775

49%

158

$195,812

51.5%

Carnegie F&A On-Campus Classification Research Rate

NOTABLE NEW GRANT AWARDS In any one year, UNT faculty are awarded many significant and important grants based on proposals for research submitted. We would love to share all of them, but due to space limitations, we have chosen a few notable award highlights.

PI Name

Dept./College

Project

Kevin Hawkins

University Libraries

Developing a Data Trust for Open Access Ebook Usage

Michael Stephen Bomba

Marketing, Logistics and Operations Management, G. Brint Ryan College of Business

Support for the Activities of the Border Trade Advisory Committee, Implementation of the Texas Border Strategic Transportation Blueprint, and Implementation of the Texas-Mexico Border Transportation Master Plan

Ana Paula Alonso

Biological Sciences, College of Science

Functional Analysis of Candidate Genes Involved in Oil Storage and Stability in Pennycress

U.S. De

Diana Berman

Materials Science and Engineering, College of Engineering

Materials for Internal Combustion Engines

Army R

Andrew

Federa Texas D (Federa

Sponsor

w W. Mellon Foundation

al Highway Administration; Department of Transportation al flow through)

epartment of Energy

Research Office

Amount

Co-PIs

$1,200,000

$1,580,000

David Nowicki, Marketing, Logistics and Operations Management and Engineering Technology

$1,600,000

Kent Chapman, Biological Sciences

$780,003

Andrey Voevodin, Materials Science and Engineering; Samir Aouadi, Materials Science and Engineering and Physics

New Faculty Startup Allocation from Division of Research and Innovation (All Funding Sources) College

FY 2019

FY 2020

G. Brint Ryan College of Business College of Education College of Engineering

$807,069

College of Health and Public Service

$76,225

$478,075

College of Information College of Liberal Arts and Social Sciences

$35,000

College of Merchandising, Hospitality and Tourism College of Music

$64,000

College of Science

$867,813

$554,841

$1,815,107

$1,067,916

College of Visual Arts and Design Total

FY 2020 F&A Table Revenue Distribution Colleges (PI, Dept., and College)

Fund 850000 (F&A) $1,584,888

VP Finance and Administration

$ 1,396,047

VP Research and Innovation

$1,743,436

Total

$4,724,371

Division of Research and Innovation, FY 2020 F&A Budget Division of Research and Innovation

Fund 850000 (F&A)

Total for FY 2020 Prior FY Balance Carried Forward

$1,958,770

FY 2020 New F&A Distribution

$1,743,436

Total Resources

$3,702,206

Allocation VP Research and Innovation Salaries/Fringe

$17,216

Materials and Office Supplies

$33,750

Dean and Associate Dean Meetings

$3,533

Travel

$12,310

Staff Professional Development

$2,707

COVID-19 Related Expenses

$5,968

Research Development

$34,160

Grants and Contracts Administration

$77,384

Research Integrity and Compliance

$25,461

Research Commercial Agreements

$109,410

Core University Shared Research Facilities

$419,250

Research Institutes and Centers

$387,709

Faculty Grantsmanship Training and DC Fellows

$64,921

Other UNT Research Program Support

$84,987

Direct College Support for Research

$31,723

New Faculty Startup

$414,002

Faculty Retention

$303,000

Faculty Research Seed Grants and Awards

$170,237

Sponsored Grant Award Cost Share

$20,000

EIS Budget Conversion Error Correction (one-time)

$185,487

Total Budget Allocation

$2,419,712

Expected Year Ending Net Balance

$1,282,494

CHAPTER 3

Office Reports

GRANTS AND CONTRACTS ADMINISTRATION

Charles Tarantino Assistant Vice President for Grants and Contracts

This has been a year of great change for Grants and Contracts Administration. New Hires: Organizationally, the unit restructured the pre-award area by upgrading two grants and contracts analyst positions to senior positions that oversee the day-to-day operations, allowing the pre-award director to focus on higher-level needs such as process reengineering and new regulatory requirements. Emiley Locey was promoted from a senior grants and contracts analyst to fill the vacant pre-award director position. The ability to promote talent from within speaks to the health of an organization. There also were changes in pre-award staffing. Loretta Neely and Laurel Holdegraver were hired to fill two vacant grants and contract analyst positions and have become great assets to the team. A third position remains vacant due to a university hiring freeze. Adapting to COVID-19: Pre-award has continued to work with faculty members during the onset of the 2020 pandemic and ended the fiscal year with increased proposal submissions as well as positive customer service remarks and gratitude

from faculty members. Michelle Hildebrand, grants and contracts specialist, leads the team’s efforts to implement a public access to research initiative and worked closely with the University Libraries on data and publication placement. The post-award team also has experienced significant changes this past year. They too have continued to work with faculty and administrators during the onset of the 2020 pandemic and ended the fiscal year with positive feedback from both groups. Post-award work processes were analyzed, and the set-up responsibility was transferred from one position to each individual grants and contracts accounting analyst. This will allow for more knowledge and expertise for each post-award individual, who will then be able to better support and advise faculty and staff about their awards. On a sadder note, two veteran post-award staffers, Marsha Corrigan and Sue Hursey, are retiring from UNT. Grant Work Center: The grant work center was finalized, providing faculty and staff with a dashboard with live data for all of their awards. They can actually drill down to the transaction level. The previous data available was from the prior business day. PeopleSoft Changes: Faculty requested a change in the PeopleSoft budget categories to more closely follow the federal sponsor budget categories on their proposals and awards. That change was successfully implemented in PeopleSoft this year. Content Updates: The suite of research administration policies has been updated, with six new policies being added to our portfolio of research policies. The PI Handbook was updated and made fully available online at the research website, research.unt.edu, and Grants and Contracts Administration updated its sections. Service Centers: A service center presentation, along with comprehensive procedures and a rate calculation template were finalized this year and made available to the university’s major service centers. Huron Software: The entire Grants and Contracts Administration unit, both preaward and post-award, are ending the year by beginning the implementation process for the Huron software. The unit looks forward to more organizationwide process improvements and a more effective operation as they implement the new suite of software products across the Division of Research and Innovation.

RESEARCH COMMERCIAL AGREEMENTS

Michael Rondelli Associate Vice President for Research Commercial Agreements

FY 2020 was punctuated with massive changes to Research Commercial Agreements, leading to the team’s success across multiple fields. They started the year with the execution of a series of agreements that is leading UNT into the forefront of industry engagement. LaCore Nutraceuticals Inc.: In a ground-breaking transaction with UNT through Chemistry Professor Guido Verbeck, LaCore Nutraceuticals Inc. executed a multiphase, long-term project that includes a $1 million gift to UNT (one of the largest single corporate gifts to UNT); a five year, $500,000 sponsored research contract; a five-year lease to labs in Inspire Park; over $60,000 of value in converting the labs into wet-lab space; internships for UNT students working as chemists in industry; and an option to license UNT intellectual property. This holistic package of interactions with a company demonstrates UNT’s ability to leverage research, advancement, facilities and both the university’s industry-renowned researchers and its students as a vehicle for engaging with industry. Dual Focus: Beginning in the first quarter, the unit changed from being technology transfer-focused to having a dual focus on both technology transfer — the protection and commercialization of intellectual property developed by UNT researchers — and managing all research contracts. With the change in responsibilities, the team added two new members, growing to 4.5 full-time employees. The unit surveyed faculty and deans about the issues they saw with contracts and then worked with Vice President McLellan to develop a service commitment that would exceed expectations. As a result, they launched with 1-, 2-, 5- and 12-day (depending on complexity and source of contract) guaranteed turn-around for all contracts received or notified about. The most difficult contracts generally take only two days for Research Commercial Agreements to turn around to the sponsor. New Hires: While absorbing contracts, the unit was able to hire two new members for the team. Janis Miller was a paralegal working part time in grants and contracts prior to Research Commercial Agreements being formed and joined the team triaging all incoming contracts. She has been the critical success factor in Research

Commercial Agreements succeeding with contracts; allowing the team to focus on each task and keeping ever-mindful of turn-around time. The unit also added Ali Yunus, senior contracts analyst, to the team focusing on licensing and related contracts to further the licensing mission. He has been instrumental in allowing Research Commercial Agreements to continue to grow licensing and has taken over the important role of managing disclosures of new technologies as faculty generate more and more intellectual property. Adapting to COVID-19: Beginning Friday, March 13, 2020, Research Commercial Agreements moved to working remotely because of the pandemic to experiment for the division should it be required to close down in-person operations. Within the first week, Research Commercial Agreements demonstrated that not only could the unit operate remotely, they did so with a higher level of service than previously provided. The team embraced technologies including Microsoft Teams and DocuSign to ensure that they could continue to serve UNT’s needs without adding people who would increase the pool of risk on campus. Additionally, they implemented daily office check-ins to ensure all team members knew what was needed, had the resources to succeed and continued to feel bonded to a work team even when working from home. The team continued to exceed expectations with completing contracts noticeably faster than previously and beyond peer institutions. Monthly Reporting: The leadership of Director for Licensing Steven Tudor in developing tools within the knowledge management system allowed Research Commercialization Agreements to communicate contract status to all PIs and deans with a monthly report, allowing transparency and confidence that contracts were being completed efficiently. Additionally, technology transfer activities again grew even during a global recession, with 12 licenses and options executed and 42 disclosures of new intellectual property. Finally, the unit has negotiated multiple licenses that will set FY 2021 up to exceed all prior years in license transactions while continuing to serve the contract management needs of faculty and administration.

RESEARCH INTEGRITY AND COMPLIANCE

Jamie Peno Director for Research Integrity and Compliance

Over the past year, the Research Integrity and Compliance team has been busy making substantial and innovative additions to compliance programs to ensure transparency, accessibility, timeliness, collaboration and consistency in research compliance operations. Addition of Team Members: The Research Integrity and Compliance team began 2020 with four members, and by July, had onboarded two new employees. The new additions to the team were trained and focused solely on the Institutional Review Board program, an area of critical need. In the first quarter, with four staff members, the team saw an average throughput of 76.5 days. By the end of the fourth quarter, after training the new team members, they had an average throughput of 6.8 days for IRB submissions. The team gave special considerations to COVID-19 studies, escalating them in the queue, and were consistent in support for faculty who were conducting COVID-19 research studies. The IRB program processed 440 initial protocols, 53 renewal protocols and 177 modifications over the past year, while making these substantial programmatic changes. Institutional Animal Care and Use Committee (IACUC) and Conflict of Interest (COI) Programs: The team also made fundamental changes to the process workflow for the Institutional Animal Care and Use Committee (IACUC) and Conflict of Interest (COI) programs to improve end-user support. They implemented eForms and utilized the RedCap platform to automate their workflow and reduce administrative burden on faculty. For the IACUC program, they processed 22 protocols throughout the year and managed animal research conducted in UNT’s vivarium. The Conflict of Interest program processed 408 conflict of interest disclosures and concluded the annual disclosure process on Dec. 1, 2020. International Affiliations Disclosure Form: In response to the U.S. government expressing serious concerns regarding foreign influence over research projects, the team developed and implemented an international affiliations disclosure form intended to capture any activities between UNT and foreign entities. The goal of the disclosure form was to ensure transparency and to implement an ongoing program

to provide guidance to UNT researchers about their compliance obligations with foreign entities. Responsible Conduct of Research (RCR) Training: The Responsible Conduct of Research (RCR) training, with the Toulouse Graduate School®, ensured that monthly trainings were provided to faculty, students and staff. They have plans to extend this program in the spring of 2021 to have a more comprehensive training program for UNT’s research community. Triage Approach: Finally, they made significant workflow changes within their unit, including the addition of the novel approach of adding a triage element to the protocol review process. The triage approach served as the first line of service for UNT’s research community to provide guidance to the compliance programs. Overall, the Research, Integrity and Compliance team had a very productive year and exceeded expectations by improving the IRB throughput and improving critical processes to ensure sustainable growth and future success.

RESEARCH AND DEVELOPMENT

Naomi Wood Assistant Director for Research Development

In an effort to provide better-than-ever support and training for faculty and staff, the Research and Development team launched several new initiatives in FY 2020. New Research Development Professionals: The G. Brint Ryan College of Business and the College of Science partnered with the Division of Research and Innovation in hiring proposal managers for their respective colleges and institutes therein. The hire in the G. Brint Ryan College of Business was successful, and the proposal manager began work in July 2020. A position in the College of Science has been posted, and the position is expected to be filled by the end of 2020. Currently there are two proposal managers on campus and one research analyst who fills a similar role in the College of Health and Public Service. The Research Development unit within the division is fledgling yet growing sustainably

with the associate vice president of research as the lead, an assistant director and two graduate student proposal editors. Grantsmanship Training: Distinguished grantsmanship training provided by the AtKisson group was brought to UNT in December 2019 and February 2020. Two additional trainings were planned for December 2020 and April 2021. The grantsmanship workshop in April will be geared toward arts and humanities faculty. Two hundred faculty attended the first two grantsmanship workshops. Research Development covered all of the costs associated with bringing the grantsmanship trainings to campus. BREAKS Knowledge Series: All UNT researchers were invited to participate in a new research education series held the first and third Thursday of the month. Each session was led by a topic expert in the field. From May to November, there were a total of 12 meetings with over 500 registered attendees. NSF CAREER Workshops: An NSF CAREER workshop was hosted by the Division of Research and Innovation in April in which 44 early investigator faculty attended. Nine faculty submitted NSF CAREER proposals in FY 2020. This year, four faculty researchers received NSF CAREER Awards, a record year for UNT. NSF Resubmission Series – Four-week Workshop on Proposal Resubmissions: In May, faculty who had previously proposed an NSF CAREER application but were not awarded were invited to attend a four-week series to revise and resubmit their applications. Six faculty attended these sessions in which faculty mentors advised the attendees on panel reviews, broader impacts and the education plan. Four out of the six attendees resubmitted their NSF CAREER proposals. Limited Submissions Competitions: When a sponsor limits the number of applications for which an institution can apply, there must be an internal competition to select the applicants to move forward. A total of six competitions were run through UNT’s Limited Submissions Competitions program, in which a committee of reviewers reviewed the highly competitive proposal applications. There were a total of 21 applicants across the six competitions. Out of the 21 applicants, 14 were selected to move forward with the full application to the sponsor. Research Seed Grants (RSGs): Every year, the Division of Research and Innovation provides funding to support scholarly and creative activities. The intent of Research seed grants (RSGs) is to enable research that seeds funding from extramural

sponsored programs. RSGs are provided to PI faculty members that hold the academic ranks of tenure-track assistant professors or tenured associate/full professors and be employed on a full-time bases in a permanent position. In FY 2020, the division received 17 applications and awarded funding to eight faculty at UNT, totaling $70,911.

NEW CENTERS At UNT, multidisciplinary meetings of the minds — both in-house and across industry and institutions — long have been an essential component of UNT’s scholarly culture. That interdisciplinary imprint continued to inform the university’s innovation mindset more than ever, with the continued development of the Center for Agile and Adaptive Additive Manufacturing (CAAAM) and the launching this year of the Center for Integrated Intelligent Mobility Systems (CIIMS) and Center for Racial and Ethnic Equity in Health and Society (CREEHS). Center for Agile and Adaptive Additive Manufacturing (CAAAM): UNT’s Center for Agile and Adaptive Additive Manufacturing (CAAAM) launched in 2019 following a $10 million appropriation by the 86th Texas Legislature. This center is on the cutting edge of additive manufacturing innovation for U.S. and global markets. Through support from partnerships and the State of Texas, CAAAM is positioned to build and support next-generation manufacturing prowess to lead U.S. global competitiveness and address acute shortages in manufacturing workforce training in additive manufacturing processes. The center is poised to forge innovative interdisciplinary collaborations across a multitude of fields, including cybersecurity, data and decision sciences, complex logistics and supply chain, and high-performance computing. CAAAM’s educational unit, the Institute for Transformative Education in Additive Manufacturing, focuses on developing a comprehensive and integrated education and training program in additive manufacturing Center for Integrated Intelligent Mobility Systems (CIIMS): Autonomous vehicle and aerial drone technology is progressing rapidly, but its future success will require an integrated approach to successfully deploy affordable, safe, accessible and resilient intelligent mobility systems in both rural and urban settings. UNT launched the Center for Integrated Intelligent Mobility Systems (CIIMS) to accelerate this deployment by collaborating with original equipment manufacturers (OEMs), transportation users and providers, area developers and policy makers. Faculty and student researchers are working collaboratively on integrated intelligent mobility systems, spanning disciplines including engineering, business, science, information, and health and public service.

Center for Racial and Ethnic Equity in Health and Society (CREEHS): UNT launched the Center for Racial and Ethnic Equity in Health and Society (CREEHS) this year to seek to uncover the impact of health care gaps and provide research for the development of best practices and policies for remedying these issues. A team of 25 UNT researchers from business, political science, education, health services, geography, rehabilitation and other social science areas is uniquely poised to develop partnerships with industry, municipalities and community organizations across the state. Core faculty members have received federal and state-funded grants to support their work on the educational, economic, environmental and social determinants of health and enhance the quality of life for underserved populations across Texas. Diversity, Equity and Inclusion: National events prompted higher education across the nation to fully examine their commitment to diversity, equity and inclusion (DEI). UNT is no exception to this national trend. Furthermore, UNT’s recent designation as a Hispanic Serving Institute (HSI) underscores the commitment to DEI within the DRI. The Research Development team has been engaged with faculty working on grants that serve our diverse student population and informing about funding opportunities for HSIs. Furthermore, the DRI provided financial support for faculty and students to attend and present at diversity-focused conferences. Padilla represents the division on the university-level HSI task force and APLU Aspire grant initiatives. Internally, all staff participated in conversations and trainings focused on DEI.

Appendix New and Revised Policies and Procedures for FY 2020

APPENDIX TABLE OF CONTENTS

13.002 Award Management and Financial Administration for Sponsored Projects

13.008 Sponsored Project Proposals

13.012 Sponsored Project Procurement and Property Management

13.013 Closeouts for Sponsored Projects

13.015 Effort Reporting

13.016 Sub-Awards and Sub-Award Monitoring

13.017 Cost Transfers for Sponsored Projects

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13.018 Cost Sharing for Sponsored Projects

13.002 AWARD MANAGEMENT AND FINANCIAL ADMINISTRATION FOR SPONSORED PROJECTS Policy Statement. This policy sets out requirements related to the award management of sponsored projects. Award management includes responsibility for financial management and oversight of grants and contracts. This policy addresses allowable/unallowable costs, the significant absence of a Principal Investigator, progress reporting to external sponsors, program income, and record-keeping related to a sponsored project. Although federal regulations are referenced, for consistency this policy will apply to all UNT sponsored projects. Application of Policy. This policy applies to all faculty and staff engaged in sponsored project activities. Definitions. 1. Allocable. “Allocable” means a cost incurred that advances the work of a sponsored project and is chargeable to a particular cost objective. 2. Allowable. “Allowable” means a cost incurred that is reasonable, allocable, consistent, and conforms to any limitations or exclusions of the sponsor. 3. Award. “Award” means a grant, contract, subcontract, sub grant, or cooperative agreement that provides funding from an external sponsor of a sponsored project and is entered into between the sponsor and UNT. 4. COGNOS Report. “COGNOS Report” means the official university record of the financial accounting of expenditures on sponsored projects. 5. Cost Sharing. “Cost Sharing” means the portion of a sponsored project cost that is not borne by the sponsor but is allocated to UNT or a third party. Cost sharing may involve cash and/or in‐kind contributions, and may consist of institutional funds or funds from outside sources. 6. Cost Transfer. “Cost transfer” means moving expenditures from one account to another. 7. Direct Costs. “Direct Cost” means costs that can be identified specifically with a particular final cost objective for a sponsored project, such as a federal award, or other internally or externally funded activity, or that can be directly assigned to such an activity for a particular sponsored project with a high degree of accuracy. 8. Effort Reporting. “Effort reporting” means an after-the-fact certification of the percentage of effort directly devoted to sponsored projects, including contributed effort; i.e. cost sharing. The certification also includes a

verification that PI/Co-PI’s and other sponsored project employees are not charging more than 100% of their time to sponsored projects. 9. Indirect Costs or Facilities and Administration Costs (F&A costs). “Indirect Costs”, “Facilities and Administration Costs” or “F&A Costs” means costs that are incurred for common or joint objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project. 10. Instruction Project. “Instruction Project” means any project involving teaching or training activities funded by an externally sponsored grant or contract, excluding research training activities, which are considered research projects. 11. OMB Circular A-21. “OMB Circular A-21” means United States Management and Budget (OMB) Circular A-21, “Cost Principles for Educational Institutions,” relocated to 2CFR, Part 220, as revised or superseded. 12. Principal Investigator. “Principal Investigator” (PI) means a single individual who, in the event of an award from an external funding agency, shall have the full and final responsibility for the conduct of the sponsored project as proposed and as set forth in the award. 13. Program income. “Program income” as defined by 2 CFR 200.80 means gross income earned by the non-federal entity that is directly generated by a supported activity or earned as a result of the Federal award during the period of performance. Program income includes but is not limited to income from fees for services performed, the use or rental of real or personal property acquired under federal awards, the sale of commodities or items fabricated under a Federal award, license fees and royalties on patents and copyrights, and principal and interest on loans made with federal award funds. 14. Progress Reporting. “Progress Reporting” means the technical report submitted by the PI to the sponsor as required by the sponsor guidelines. 15. Public Service Project. “Public Service Project” means any project involving activities other than instruction or research such as public health and community service projects. 16. Research Project. “Research Project” means a systematic study directed toward fuller scientific knowledge or understanding of the subject studied. It also involves the training of individuals in research techniques where such activities utilize the same facilities as other research activities. 17. Sponsored Project. “Sponsored Project” means a project funded by an

external sponsor through a grant or contract with UNT where one or more of the following obligations apply (examples of sponsored projects include but are not limited to instruction projects, public service projects, or research projects): a. Financial obligation – UNT is required to comply with conditions imposed when a sponsor awards funding for the performance of services or delivery of products described in a statement of work; b. Regulatory obligation – UNT is required to comply with sponsor regulations, which may include federal or state regulations; c. Reporting obligation – UNT is required to provide to the sponsor technical performance reports or regulatory or administrative reports; d. Performance Obligation – UNT is required to perform within a certain period and may be required to meet other specified requirements related to performance; e. Accounting obligation – UNT is required to establish a separate accounting record of project expenditures to demonstrate allowance of costs, to maintain financial accountability, to provide financial reports to the sponsor, and to preserve appropriate records for audit purposes. 18. Uniform Guidance. “Uniform Guidance” means OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 CFR Part 200, et al. The Office of Management and Budget (OMB) issued Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in the Federal Register. The Uniform Guidance replaces the administrative, accounting, and audit rules and principles promulgated in the OMB Circulars, including A-21, A-110, and A-133. Procedures and Responsibilities. 1. Oversight Responsibility Grants and Contract Administration is the administrative office responsible for overseeing award management and financial administration efforts of the Principal Investigator, department, and college; and addresses issues as necessary to ensure compliance with the prime award, federal and state laws and regulations, institutional policies, and UNT System Regents Rules. Responsible Party: Grants and Contract Administration 2. Cost Principles for Sponsored Projects For any costs to be charged directly to an award, the expense must be

allowable, allocable, reasonable, necessary, and consistently charged. The Principal Investigator, department, college, and Grants and Contract Administration will coordinate to exercise financial management and oversight of sponsored project grants and contracts to ensure that all charges comply with these cost principles. Charges must be charged consistently and categorized as either a direct cost or an indirect cost. Costs incurred for the same purpose in like circumstances must be treated consistently as either direct expenses or indirect costs. All federal awards issued after December 26, 2014 must comply with the Uniform Guidance award management and financial administration requirements. Awards issued prior to that date must comply with OMB Circular A-21 unless the agency has notified UNT to follow the Uniform Guidance requirements. In addition to the Uniform Guidance, UNT must comply with the Cost Accounting Standards (CAS) located in 48 CFR §9905.501, §9905.502, §9905.505, and §9905.506. The purpose of the CAS is to ensure consistency in: • Estimating, accumulating, and reporting costs (CAS 501) • Allocating costs incurred for the same purpose in like circumstances (CAS 502) • Accounting for unallowable costs (CAS 505) • Cost accounting periods (CAS 506) Responsible Party: Principal Investigator; Department; Grants and Contracts Administration 3. Monitoring Financial Activity The Principal Investigator is responsible for monitoring financial activity related to a sponsored project on a regular basis through PeopleSoft or COGNOS reports (at least monthly). All expenditures must comply with UNT Policy 13.012 Sponsored Project Procurement and Property Management. The Principal Investigator must address any discrepancies with the Grants and Contract Administration immediately. If a cost transfer is necessary in order to resolve a discrepancy, then the Principal Investigator shall submit a cost transfer form in accordance with UNT Policy 13.015 Cost Transfers for Sponsored Projects. Responsible Party: Principal Investigator 4. Financial Responsibility of Grants and Contracts Administration In the award management and financial administration of sponsored projects, the Grants and Contract Administration is responsible for: a. Preparing all billings and financial reports on sponsored projects.

b. Monitoring and administering account receivables for all sponsored projects. c. Receiving and depositing all payments made on sponsored project accounts. Responsible Party: Grants and Contracts Administration 5. Administrative and Clerical Salaries (2 CFR §200.413(c)) Principal Investigators are only allowed to charge administrative or clerical salaries to a sponsored project as set forth in this policy. Administrative and clerical personnel provide non-technical support services that benefit departmental, institute, center, or college activities. The services of these individuals could include: clerical support, financial management, procurement of materials and services, budget and planning, and personnel management. The salaries of administrative and clerical personnel are normally required to be treated as an indirect cost unless they meet certain Uniform Guidance criteria. As stipulated in the Uniform Guidance, direct charging of administrative salaries is allowable when all of the following conditions are met: • Administrative or clerical services are integral to a project or activity; • Individuals involved can be specifically identified with the project or activity; • Such expenses are explicitly included in the budget or have the prior written approval of the federal awarding agency; and • The costs are not also recovered as indirect costs. Administrative and clerical salaries charged improperly to federal awards result in unallowable costs, requiring reimbursement to the government and, depending on severity, additional penalties for UNT. Responsible Party: Principal Investigator 6. Travel and Related Expenses (2 CFR §200.474) Travel-related expenses are allowable as direct expenses when they provide a direct benefit to the sponsored award and meet certain requirements. Domestic and foreign travel charged to a sponsored project must comply with this policy as well as with other UNT travel guidelines and sponsor requirements, whichever imposes the greater restrictions. In order to charge a business meal on a federal award, an itemized receipt should be presented, regardless of cost. Federal regulations require travelers to incur the lowest possible expense to

the federal award; in most circumstances, this is a non-refundable (restricted) economy class airfare. Federal regulations require that airfare costs in excess of the lowest economy fare class are unallowable except when such accommodations would: i. Require circuitous routing; ii. Require travel during unreasonable hours; iii. Excessively prolong travel; iv. Result in additional costs that would offset the transportation savings; or v. Offer accommodations not reasonably adequate for the traveler’s medical needs. Once these criteria are met, the traveler must justify and document the exception for the use of business-class or upgraded economy airfare to be allowable on a federal award. Complementary (no-cost) upgrades are allowed. There may be circumstances where there is a high likelihood that the itinerary may change; in these situations, it is appropriate to purchase a refundable (unrestricted) ticket. When requesting a reimbursement, the reason for purchasing a refundable ticket must be explained. All air travel on federal awards must comply with the Fly America Act and use US Flag Carriers, even when a less costly foreign flag carrier is available, unless the flight meets the circumstances and exceptions. To determine if an authorized exception applies, the Principal Investigator must check with the Grants and Contract Administration or their College Research Officer. The Principal Investigator must retain documentation of the Fly America exceptions. The Open Skies Agreement is an exception to the Fly America Act requirement and it allows travelers to fly on airlines from the European Union, Australia, Switzerland, and Japan under certain circumstances. To determine if a flight meets the Open Skies Agreement criteria, the Principal Investigator must check with the Grants and Contract Administration or their College Research Officer. Responsible Party: Principal Investigator; Grants and Contract Administration 7. Prior Written Approval of Certain Costs in order to be Charged to Federal Grants For Items requiring prior approval, the Principal Investigator must request specifically and obtain approval for an item in the proposal budget or must request approval by the sponsor, in writing, before the expense is charged to the

award. In most cases, written approval from the program officer is not sufficient; instead, the Principal Investigator must refer to the terms and conditions of the award for information regarding who can authorize changes to the award budget. Only those costs that meet the criteria for direct expenses on a federal award, can be directly charged to an award under any circumstances. Per the Uniform Guidance, prior written approval from the sponsor is explicitly required for: • Change of key personnel (200.308 (c)(2)) • Change of scope (200.308 (c)(1)) • Cost sharing or matching (200.308 (c)(7)) • Effort reduction of key personnel greater than 25% or PI disengagement from project of greater than 3 months (200.308 (c)(3)) • Fixed amount sub-awards (200.332) • Participant support costs, any transfer of budget (200.308 (c)(5)) and (200.456) • Rearrangement and reconversion expenses (Renovations) (200.462) • Use of program income (200.307) • Entertainment costs (200.438) • Sub-awards, any changes or transfers (200.308) (c)(6)) The following also may require prior approval depending on the award: • Carry forward (200.308 (d)(3)) • No cost extension (200.308 (d)(2)) • Pre-award Expenses (200.458) The Grants and Contract Administration is responsible for requesting approval of an expense from the sponsor if required. Responsible Party: Principal Investigator; Grants and Contract Administration 8. Notification Requirements The Principal Investigators are responsible for notifying the Grants and Contract Administration when anticipating an absence from UNT that may negatively impact a sponsored project and/or would require relinquishing direction of the sponsored project. Notification is also required in the event of a significant change in effort (increase or decrease greater than 25 percent effort committed at the time of the award) or plans to transfer to another institution. The Grants and Contract Administration is responsible for notifying the sponsor of any significant absence of a Principal Investigator and negotiate a

replacement Principal Investigator for the applicable sponsored project award. The replacement Principal Investigator must be acceptable to the sponsor, the Grants and Contracts Administration, the Department Unit Administrator, and Dean. Responsible Party: Principal Investigator; Grants and Contract Administration 9. Progress Reporting The Principal Investigator is responsible for providing progress reports to the sponsor in compliance with the sponsor award guidelines. The Principal Investigator shall provide the Grants and Contract Administration with a copy of any progress report provided to the sponsor. Responsible Party: Principal Investigator 10. Record Keeping The Principal Investigator shall maintain and monitor accounting records of purchases and encumbrances in order to stay within the approved sponsored project budget. All expenditures on sponsored project accounts must be submitted to the Grants and Contract Administration or College Research Officer for approval in accordance with UNT Policy 13.012 Sponsored Project Procurement and Property Management. Responsible Party: Principal Investigator 11. Cost Allocation Methodologies to be Used for Sponsored Projects Whenever possible, Principal Investigators must charge specific expenses to a specific sponsored award. When it is not possible or efficient to determine how much of the cost is used for each award, allocation of the expenses is allowable. Allocation assigns a cost to one or more awards in reasonable and realistic proportion to the benefit provided to the sponsored projects. At UNT, allocation methodologies must meet the following criteria: • The allocation must provide a reasonable linkage between the cost incurred and the benefit to individual sponsored projects, • The allocation methodology must be identified for the allocation of expenses and documented in a way that a person unfamiliar with grants management would understand, • Each methodology should be applied consistently for similar costs that meet the criteria of the allocation methodology, and • Allocation methodology must be reviewed and approved by the Grants and Contracts Administration. Responsible Party: Principal Investigator; Grants and Contract Administration

References and Cross-references. UNT UNT UNT UNT UNT UNT

Policy Policy Policy Policy Policy Policy

13.007, Sponsored Projects 13.017, Cost Transfers for Sponsored Projects 13.018, Cost Sharing for Sponsored Projects 13.015, Effort Reporting 13.012, Sponsored Project Procurement and Property Management 13.013, Closeouts for Sponsored Projects

Forms and Tools. None Approved: 11/19/10 Effective: 11/19/10 Revised: 6/20/19; 06/03/20

13.008 SPONSORED PROJECT PROPOSALS Policy Statement. In submitting a sponsored project proposal, UNT is committing itself to fulfill the purposes and requirements of the proposed project through use of University personnel, resources and facilities. This policy sets out requirements related to the submission of sponsored project proposals to external sponsors, including all proposals for projects carried out in academic departments, laboratories, administrative units and clinics of UNT. In addition, this policy covers proposals for projects performed off campus, including but not limited to those performed at affiliated institutions. Application of Policy. Faculty and staff engaged in sponsored project activities. Definitions. 1. Award. “Award” means a grant, contract, subcontract, sub-grant or cooperative agreement that provides funding from an external sponsor of a sponsored project and is entered into between the sponsor and UNT. 2. Instruction Project. “Instruction Project” means any project involving teaching or training activities funded by an externally sponsored grant or contract, excluding research training activities, which are considered research projects.

3. Principal Investigator. “Principal Investigator” (PI) means a single individual who, in the event of an award from an external funding agency, shall have the full and final responsibility for the conduct of the sponsored project as proposed and as set forth in the award. 4. Public Service Project. “Public Service Project” means any project involving activities other than instruction or research such as public health and community service programs. 5. Research Project. “Research Project” means a systematic study directed toward fuller scientific knowledge or understanding of the subject studied. It also involves the training of individuals in research techniques where such activities utilize the same facilities as other research activities. 6. Sponsor. “Sponsor” means any external entity that provides funding to UNT for sponsored projects. Sponsors may be (i) governmental agencies (for example, federal, state, or local governments or their administrative organizations); (ii) nonprofit organizations (for example, universities, nonprofit corporations, foundations, or associations); (iii) for profit organizations (for example, corporations, partnerships, sole proprietorships, and other business entities); or (iv) individuals. Governmental, nonprofit, and for-profit sponsors are sometimes referred to by themselves and others as “agencies”. 7. Sponsored Project. “Sponsored Project” means a project funded by an external sponsor through an award with UNT, where one or more of the following obligations apply (examples of sponsored projects include but are not limited to instruction projects, public service projects, or research projects): a. Financial Obligation – UNT is required to comply with conditions imposed when a sponsor awards funding for the performance of services or delivery of products described in a statement of work; b. Regulatory Obligation – UNT is required to comply with sponsor regulations, which may include federal or state regulations; c. Reporting Obligation – UNT is required to provide to the sponsor technical performance reports or regulatory or administrative reports that require information beyond stewardship reporting; d. Performance Obligation – UNT is required to perform within a certain period and may be required to meet other specified requirements related to performance;

e. Accounting Obligation – UNT is required to establish a separate accounting record of project accountability, to provide financial reports to the sponsor, and to preserve appropriate records for audit purposes. Procedures and Responsibilities. A. Grants and Contracts Administration is the administrative office responsible for reviewing and submitting proposals to external sponsors on behalf of UNT. B. With the support of Grants and Contracts Administration, faculty and staff members interested in engaging in sponsored project activities are responsible for seeking out and identifying funding opportunities from external sponsors. Grants and Contracts Administration is responsible to assist in identifying federal, state, foundations, non-profit and other sponsored project opportunities that may be of interest to faculty and staff members engaged in sponsored project activities. Responsible Party: Faculty and staff members engaged in sponsored project activities, Grants and Contracts Administration C. At the outset of the proposal submission process, faculty or staff members interested in engaging in sponsored project activities must verify eligibility to serve as the PI in accordance with sponsor and UNT requirements and must comply with procedures for confirming PI eligibility in accordance with the Principal Investigator (PI) Handbook. Persons eligible to be PI shall hold the title of professors, associate professors, assistant professors, or be eligible as specified in the PI Handbook, unless an exception has been requested and granted in accordance with procedures in the PI Handbook. Responsible Party: Faculty and staff members engaged in sponsored project activities D. Faculty and staff members must notify Grants and Contracts Administration of their intent to pursue a funding opportunity. Responsible Party: Faculty and staff members engaged in sponsored project activities E. With the support of Grants and Contracts Administration, the PI is responsible for preparing the proposal. Proposals must be prepared in

accordance with sponsor guidelines and applicable proposal deadlines of the department, college and Grants and Contracts Administration. Grants and Contracts Administration shall provide support services and guidance regarding the development of a proposal submission. Responsible Party: Faculty and staff members engaged in sponsored project activities, Grants and Contracts Administration F. The PI must complete and certify a proposal record in Cayuse SP, or other UNT system of record for electronic proposal routing, and upload the budget form and any other proposal or administrative forms required by Grants and Contracts Administration. Examples of other forms that may be required are the pre-award cost-sharing form and sub-recipient forms. Responsible Party: Faculty and staff members engaged in sponsored project activities G. As an applicant organization, UNT has an institutional responsibility to review and approve a proposal before submission to an external sponsor. The PI, Department Head, Dean and Grants and Contracts Administration share responsibility for determining whether a proposed project and restrictions imposed on the University by the award are consistent with the University’s policies, its mission, its capabilities and capacity, and its commitment to free and open inquiry. In accordance with the Principal Investigator (PI) Handbook, responsibility is also shared for reviewing the proposal and related documents for accuracy, validity, and conformity with federal, state, system, institutional, and sponsor rules, regulations, policies and guidelines with respect to the administrative, fiscal, and scientific information included in the proposal, and for determining that UNT is able to comply with its obligations as set forth in the proposal. Conflicts of interest related to the proposal must be disclosed by the Principal Investigator and other project personnel in accordance with applicable institutional policies. Proposal related approvals and certifications attest to adherence to responsibilities for oversight. Responsible Party: Principal Investigators, Department Heads, Deans, Grants and Contracts Administration H. The Director of Grants and Contracts Administration or his/her designee shall submit the final proposal to the external sponsor and sign as the authorized organizational representative for UNT after approvals and certifications in accordance with the Principal Investigator (PI) Handbook have been

completed. In so doing, the Director or his/her designee on behalf of UNT is accepting the obligations and compliance requirements imposed by federal and state regulations and certifying that UNT will comply with all assurances, commitments, and certifications included as part of the proposal in the event of an award. Responsible Party: Principal Investigators, Department Heads, Deans, Director of Grants and Contracts Administration or designee References and Cross-references. UNT Policy 13.007, Sponsored Projects UNT Policy 13.002, Award Management of Sponsored Project UNT Policy 13.005, Conflict of Interest for Sponsored Projects UNT Policy 13.010, Export Controls Forms and Tools. Grants and Contracts Administration Website Grants and Contracts Administration Forms Principal Investigator (PI) Handbook Approved: 11/19/2010 Effective: 11/19/2010 Revised: 06/05/2019; 08/6/2020

13.012 SPONSORED PROJECT PROCUREMENT AND PROPERTY MANAGEMENT Policy Statement. The purpose of this policy is to establish the requirements for procurement of goods and services for sponsored projects. Further, this policy establishes procedures for safeguarding property funded by sponsored projects, and establishes related management and reporting requirements. Application of Policy. Faculty and staff engaged in sponsored project activities. This policy applies to all expenditures of monies paid from a sponsored project account.

Definitions. 1. Allocable. “Allocable” means a cost incurred that advances the work of a sponsored project and is chargeable to a particular cost objective. 2. Allowable. “Allowable” means a cost incurred that is reasonable, allocable, consistent, and conforms to any limitations or exclusions of the sponsor. 3. Award. “Award” means a grant, contract, subcontract, sub-grant, or cooperative agreement that provides funding from an external sponsor of a sponsored project and is entered into between the sponsor and UNT. 4. Contract. “Contract” means any written agreement or other document that creates a legally binding obligation, financial or otherwise, for UNT. Contracts related to sponsored project activity can include but are not limited to: documents with the title of contract, agreement, memoranda of understanding, affiliation agreement, cooperative agreement, interagency contract, professional services agreement, letter agreement, letter of intent, nondisclosure agreement, material transfer agreement, or a purchase order. 5. Contractor. “Contractor” means a consultant, vendor, or service provider who provides ancillary goods or services that UNT needs to conduct a sponsored project research activity. Examples include, but are not limited to, an entity or person who provides: a. Expert advice or consulting b. Non-University labor or services paid for as a “fee-for-service” c. Commercially available supplies and expendable materials d. Equipment or component parts for fabricated equipment or equipment which will be delivered to and used by the sponsor or an entity designated by the sponsor. 6. Funding. “Funding” means financial support for a sponsored project, including money, property, services, or anything of value in lieu of money. 7. OMB Circular A-21. “OMB Circular A-21” means United States Office of Management and Budget (OMB) Circular A-21, “Cost Principles for Educational Institutions,” relocated to 2CFR, Part 220, as revised or superseded. 8. OMB Circular A-110. “OMB Circular A-110” means United States Office of Management and Budget (OMB) Circular A-110, “Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher

Education, Hospitals, and Other Non-Profit Organizations,” relocated to 2 CFR, Part 215, as revised or superseded. 9. Pass Through Entity. “Pass through entity” (PTE) is a non-federal entity that provides an award to a sub recipient to carry out a program. 10. Principal Investigator. “Principal Investigator” (PI) means a single individual who, in the event of an award from an external funding agency, shall have the full and final responsibility for the conduct of the sponsored project as proposed and set forth in an award. 11. Sponsor. “Sponsor” means any external entity that provides funding to UNT for sponsored projects. Sponsors may be (i) governmental agencies (for example, federal, state, or local governments or their administrative organizations); (ii) nonprofit organizations (for example, universities, nonprofit corporations, foundations, or associations); (iii) for profit organizations (for example, corporations, partnerships, sole proprietorships, and other business entities); or (iv) individuals. Governmental, nonprofit, and for profit sponsors are sometimes referred to by themselves and others as “agencies”. 12. Sponsored Project. “Sponsored Project” means a project funded by an external sponsor through a grant or contract with UNT where one or more of the following obligations apply (examples of sponsored projects include but are not limited to instruction projects, public service projects, or research projects): a. Financial obligation – UNT is required to comply with conditions imposed when a sponsor awards funding for the performance of services or delivery of products described in a statement of work; b. Regulatory obligation – UNT is required to comply with sponsor regulations, which may include federal or state regulations; c. Reporting obligation – UNT is required to provide to the sponsor technical performance reports or regulatory or administrative reports; d. Performance obligation – UNT is required to perform within a certain period and may be required to meet other specified requirements related to performance; e. Accounting obligation – UNT is required to establish a separate accounting record of project expenditures to demonstrate allowance of costs, to maintain financial accountability, to provide financial reports to the sponsor, and to preserve appropriate records for audit purposes.

13. Sub-award. A “sub-award” (also referred to as sub-grant if the prime award is a grant, and sub-contract if the prime award is a contract or sub-agreement) means a secondary award provided by a pass-through entity (PTE) to a sub-recipient in order for the sub-recipient to carry out a portion of the sponsored effort required under the terms of the primary award between the sponsor and the PTE. The definition also includes sub-awards made by a subrecipient to a lower tier sub-recipient. Sub- awards differ from procurement contracts used to acquire goods or services from vendors. 14. Sub-recipient. A “sub-recipient” means the recipient of a sub-award from a PTE for the performance of a portion of the work statement or programmatic effort required by a prime award. The sub-recipient’s responsibility under a sub-award is also called “programmatic decision-making” under federal funding terminology. The sub- recipient is accountable to the PTE for the use of sub-award funding. The sub- recipient may be another educational institution, an independent laboratory, a foundation, a for-profit corporation, a non-profit corporation, or other organization, and may be a domestic or foreign entity. A sub-recipient may be referred to as a sub- awardee, subgrantee, or lower-tier institution. 15. Uniform Guidance. “Uniform Guidance” means OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 CFR Part 200, et al. The Office of Management and Budget (OMB) issued Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in the Federal Register. The Uniform Guidance replaces the administrative, accounting and audit rules and principles promulgated in the OMB Circulars, including A-21, A-110, and A-133. Procedures and Responsibilities. A. General Purchasing Requirements. When making purchases for a sponsored project, the principal investigator and Grants and Contracts Administration, in conjunction with the UNT System Procurement Services Department, are responsible for ensuring the following: 1. Procurement related to sponsored projects must be conducted in a lawful and ethical manner. Purchases must be consistent with the sponsored project budget and comply with UNT System and UNT purchasing policies and procedures as well as applicable award requirements and federal and state regulations, which includes but is not limited to the procurement regulations set forth in the Uniform Guidance.

2. All purchases must directly benefit the sponsored project(s) to which they are charged and must be allowable, allocable, and reasonable in accordance with applicable sponsor guidelines included in the award grant or contract. 3. The splitting of the cost of a purchase in order to avoid compliance with a requirement that relates to any purchase threshold is prohibited. Responsible Party: Principal Investigator; Department Administrator; Department Research Administrator; College Research Officer; Grants and Contracts Administration; B. Purchasing Requirements for Sub-Awards. When a sub-recipient uses federal grant funds for purchases related to a sponsored project, Grants and Contracts Administration shall ensure that the sub-recipient is contractually required in the sub-award to comply with §200.317 of the Uniform Guidance if the sub-recipient is a state entity or with §200.318-through §200.326 of the Uniform Guidance if the sub-recipient is not a state entity. Responsible Party: Grants and Contracts Administration C. Sole Source Purchases – the Uniform Guidance §200.320 limits the use of sole source purchases to four justifications: 1. Product/service is only available from a single source; 2. Public Emergency Procurement; 3. Federal Awarding Agency Authorization: the awarding agency specifically authorizes a non-competitive procurement after a written request (Principal Investigators must coordinate with Grants and Contracts Administration before making this type of request to a sponsor); and 4. Inadequate competition after solicitation of multiple sources. The Principal Investigator must provide a Proprietary/Sole Source Purchase Justification form to System Procurement when making a sole source purchase. The Principal Investigator, Department Research Administrator, College Research Officer, and Grants and Contracts Administration, in conjunction with the UNT System Procurement, are responsible for working together to ensure that the requirements of the Uniform Guidance are met prior to a sole source purchase being made using federal grant funds for purchases of goods or services related to sponsored projects.

Responsible Party: Principal Investigator; Department Research Administrator; College Research Officer; Grants and Contracts Administration; System Procurement D. Contract Provisions to be included in Purchase Orders or Contracts with Contractors. When using federal grant funds for purchases of goods and services related to sponsored projects, purchase orders and contracts must incorporate provisions as required by Appendix II of Part 200 of the Uniform Guidance. Responsible Party: Principal Investigator; Grants and Contracts Administration E. Procurement Records. In addition to following the standard UNT policies and procedures for procurement, the Principal Investigator, Department Research Administrator, College Research Officer and Grants and Contracts Administration, in conjunction with the UNT System Procurement Services Department, shall maintain procurement records for purchases related to sponsored projects. These records shall include the following: 1. Rationale for the method of procurement 2. Selection of contract type 3. Contractor selection or rejection 4. Justification for lack of competition when competitive bids are not obtained 5. Basis for award cost or price Responsible Party: Principal Investigator; Department Research Administrator; Department Research Administrator; College Research Officer; Grants and Contracts Administration; System Procurement F. Responsibilities When Receiving Purchases. Principal Investigators and/or Department Research Administrators, not Grants and Contracts Administration, are responsible to account for and document the receipt of goods and services and contractor performance related to grant expenditures in a complete, timely, and accurate manner and in accordance with the guidelines of the UNT System Procurement Services Department. The Principal Investigator must notify UNT System Procurement Services Department of the receipt of goods and services in order for payments to contractors to be made. Grants and Contracts Administration, in conjunction

with the UNT System Procurement Services Department, also must be notified if there is a problem with goods and services upon delivery. Upon Receipt of Goods, the Principal Investigator and Department Administrators are responsible for completing the following: 1. Inspect packaging and goods for signs of damage. Save packing materials. Insurers may want to inspect the materials if the goods are damaged. 2. Do not accept the shipment if the goods are damaged. Document damage directly on the receiving carrier’s forms as justification for nonacceptance. 3. Compare the merchandise received to the supplier-generated documentation (usually a packing slip or supplier invoice). The merchandise and documentation should match. Verify that the shipment is the correct quantity and price. 4. If the merchandise is incorrect, call supplier immediately to discuss the problem. If returning any merchandise, request a Returned Goods Authorization (RGA) number from the supplier. 5. Sign the receiving forms. Sign only for what was actually received. Verify the item belongs to the proper department. 6. Verify immediately that the product performs correctly. If the product is defective, call the supplier and arrange for the return of the product. Do not try to fix a defective product. This may violate the warranty or it may be construed as acceptance of an inferior product. Responsible Party: Principal Investigator; Department Research Administrator G. Property Management Records. The Principal Investigator, Department Designated Inventory Coordinator, and Office of Property Management are responsible for creating and maintaining property management records for all equipment purchased for sponsored projects. Property management records must include the following information: 1. description of equipment purchased 2. applicable sponsored project 3. serial number or other identification number 4. source of funding

5. who holds title 6. acquisition date 7. equipment cost 8. disposition or transfer information Responsible Party: Principal Investigator; Department Designated Inventory Coordinator; Office of Property Management H. Tagging and Tracking. In addition to complying with other tagging requirements as set forth in UNT policies, the principal investigator and the Office of Property Management are responsible for tagging and tracking equipment purchased for a sponsored project. Grants and Contracts Administration is responsible for noting when a sponsor has specific equipment disposition requirements, such as the project sponsor retaining ownership of UNT purchased equipment or when the project sponsor has furnished the equipment to UNT. Responsible Party: Principal Investigator; Department Administrator; Department Research Administrator; College Research Officer; Grants and Contracts Administration; Office of Property Management I. General Property Management. Principal Investigators and others participating in a sponsored project must manage, safeguard, inventory, and report property funded through an award in compliance with applicable UNT policies and with requirements established by the sponsor. The principal investigator is responsible for making reports of change of location of property, changes in need, annual and bi-annual inventories, and other property reports required by an award to Grants and Contracts Administration and the Office of Property Management. Responsible Party: Principal Investigator; Department Administrator; Department Research Administrator; College Research Officer; Office of Property Management J. Lost, Stolen, or Damaged Property and Equipment that was Purchased on Sponsored Projects. The principal investigator must promptly report all incidents resulting in equipment loss, damage, or destruction to their department, Grants and Contracts Administration, the Office of Property Management, and Risk Management.

Responsible Party: Principal Investigator; Department Research Administrator; Department Research Administrator; College Research Officer; Grants and Contracts Administration; Office of Property Management; Office of Risk Management K. Disposal or Transfer of Property. Equipment purchased using sponsored project funds cannot be disposed of or transferred without the approval of Grants and Contracts Administration in conjunction with the Office of Property Management. Sponsors reserve the right to assume title to capital equipment that is purchased with sponsor funds through final closeout of the award. 1. Exempt Property - Federal awarding agencies with statutory authority have the option to vest the title to property acquired with federal funds at UNT without further obligation to the federal government. This property is deemed “exempt property”. Generally, if exempt, this designation is made in the award. Property guidelines vary by awarding agency. Grants and Contracts Administration is responsible for maintaining all awarding agency guidelines and providing assistance in determining applicability to specific grants and contracts. Proceeds from the sale or trade-in of exempt property should be handled as follows: a. If the project(s) on which the item was purchased is still active, the proceeds or value from the sale/trade-in should be credited to the project(s). b. If the project in which the item was purchased has expired and the sponsor has accepted the final reports, the proceeds may be deposited into an appropriate departmental account/fund. Exempt property originally purchased with sponsored funds should not be sold to other departments/academic units within the University. Items that are no longer needed by the department should be donated to another department, if needed. Contact Grants and Contracts Administration for assistance with issues concerning the sale or tradein of exempt property. The Office of Property Management maintains a Surplus warehouse for redistribution of equipment for campus use or sale to the public. Exempt property is not subject to following the disposal guidelines for Government-funded and owned property. All Government funded

and owned property not specifically exempted are subject to the procedures included in this policy. 2. Federal government-funded property, where the federal government has retained ownership, acquired in whole or part with Federal grant funds requires special disposition procedures. Grants and Contracts Administration and the Office of Property Management are responsible for disposing of such property as allowed by the Uniform Guidance. 3. Procurement of Recovered Materials. When using federal grant funds for purchases related to sponsored projects, UNT must comply with §6002 of the Solid Waste Disposal Act when procuring items designated in the EPA guidelines of 40 CFR 247. 4. Transfer/Sale of Equipment. Transfer Out - A principal investigator transferring to another institution may wish to transfer equipment associated with a sponsored project to the new institution. To initiate this process, the principal investigator or their administrator should work with Grants and Contracts Administration to prepare a list of the items to be transferred. The list should be reviewed and signed by the principal investigator, the department Unit Administrator, the Vice President of Research and Innovation and the Vice President for Finance and Administration. After obtaining the required approvals, the list should be returned to Grants and Contracts Administration to provide institutional review and approval, as appropriate. The Office of Property Management also must be notified and must approve the transfer. The other university must be willing to accept responsibility for the equipment and pay for the shipping costs. If the grant has ended and ownership of the equipment vests with UNT, Grants and Contracts Administration and the Office of Property Management are required to obtain the current fair market value for each item and calculate the amount that UNT is entitled to be reimbursed by the receiving institution before the transfer is made. Assuming all parties agree to the transfer, UNT receives something of value for the transfer, there are no unusual restrictions in the original award document that might limit ability to transfer title, and the equipment is not being shipped outside the United States then the Office of Property Management will collect payment from the receiving university prior to shipment.

The receiving institution and/or principal investigator are responsible for the removal and safe delivery of the items to their new location as well as any costs associated with this process. 5. Transfer In - A principal investigator transferring from another institution to UNT may bring equipment with him/her that is associated with a sponsored project. The principal investigator should contact the Office of Property Management to facilitate the transfer process. The principal investigator is required to provide a list to the Office of Property Management who will provide copies to Grants and Contracts Administration of the transferred items that have a fair market value greater than $5,000. Grants and Contracts Administration and the Office of Property Management shall coordinate to create the appropriate equipment records for equipment that has been transferred into UNT. 6. Any equipment that has come in contact with hazardous materials that has been noted as hazardous in university records or in any way requires decontamination or removal of hazardous components during disposal or transfer requires notification to and approval by the Office of Risk Management prior to disposal or transfer. Responsible Party: Principal Investigator; Department Unit Administrator; Department Research Administrator; Department Research Administrator; College Research Officer; Risk Management; Grants and Contracts Administration; Office of Property Management; Vice President for Research and Innovation; Vice President for Finance and Administration L. Property Management during Sponsored Project Close-Out. To ensure proper inventory reporting and timeliness of disposition procedures, principal investigators are responsible for performing a physical property inventory prior to the close-out of a sponsored project. Adjustments or other property issues should be resolved at this time. Authorization and approval from federal awarding agencies should be requested for the transfer or disposition of federal government property. Grants and Contracts Administration may be required to review and report Government-funded, owned, and furnished equipment to determine appropriate execution of disposition procedures. Responsible Party: Principal Investigator; Department Administrator;

Department Research Administrator; College Research Officer; Grants and Contracts Administration M. Policy Non-Compliance. Non-compliance with this policy may result in a variety of adverse consequences for UNT and the principal investigator and/or school, department, center, or division, including but not limited to the following: 1. Sponsor agency temporarily withholding payments pending correction of a deficiency and/or disallowance of all or part of the cost of a purchase 2. Complete or partial suspension of a grant or contract 3. Suspension or debarment of UNT or the principal investigator from participation in sponsor funded programs 4. Research Misconduct allegation and investigation 5. Criminal prosecution for fraud or other legal action Failure to comply with this policy may result in disciplinary action, including termination of employment. In addition, violation of federal or state requirements may expose individuals to civil and criminal prosecution. Responsible Party: Principal Investigator; Department Administrator; Department Research Administrator; College Research Officer; any other faculty and staff engaged in sponsored project activities References and Cross-references. UNT System Regents Rule 03.900, Delegation of Authority for Contracts and Agreements UNT System Regents Rule 05.700, System Administration and Institution Ethics and Standards of Conduct UNT System Regents Rule 10.500 Disposal of Property UNT Policy 5.015 Ethics UNT Policy 10.003 Financial Reporting UNT Policy 10.043 Purchasing Services UNT Policy 10.048 Asset Management UNT Policy 13.005 Conflict of Interest for Sponsored Projects

UNT Policy 13.007 Sponsored Projects UNT Policy 13.006 Research Misconduct UNT Policy 13.016 Sub-Awards and Sub-Award Monitoring OMB Circular A-21 OMB Circular A-110 Federal Regulations regarding procurement are located in the Code of Federal Regulation, 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Procurement guidance is located in §§200.317-200.326 Forms and Tools. Principal Investigator Handbook Proprietary/Sole Source Purchase Justification Approved: 07/09/2020 Effective: 07/09/2020

13.013 CLOSEOUTS FOR SPONSORED PROJECTS Policy Statement. Sponsored projects must be closed out in a timely and accurate manner. Timeliness of reporting and closing out an award is crucial to sound award management in order to assure full compliance with sponsor requirements and regulations and to assure collection of all monetary reimbursement for costs. Application of Policy. This policy applies to all faculty and staff engaged in sponsored project activities and to all sponsored projects, regardless as to whether funded by a federal, state, or private sponsor. Definitions. 1. Award. “Award” means a grant, contract, subcontract, sub-grant, or cooperative agreement that provides funding from an external sponsor for a sponsored project and is entered into between the sponsor and UNT. 2. Closeout. “Closeout” means the process of documenting and assuring the fulfillment of the terms and conditions of the award, of certifying University

compliance with applicable regulations, and making final disposition of all award by-products, such as final vouchers, reports, patent disclosures, and property inventory. In addition, the closeout process includes the collection of outstanding accounts receivable and addressing deficit or residual balances. 3. Closeout End Date. “Closeout End Date” means the last day on which closeout reports need to be received by the sponsor. 4. Expenditure End Date. “Expenditure End Date” means the last day on which expenditures can be posted to the account. 5. Deficit Balances. “Deficit Balances” means cumulative expenses exceeding the amount awarded by the sponsor. 6. No Cost Extension. “No Cost Extension” means the extension of the sponsored project end date that usually requires advance notification to or approval from the sponsor. 7. Principal Investigator. “Principal Investigator” (PI) means a single individual who, in the event of an award from an external funding agency, shall have the full and final responsibility for the conduct of the sponsored project as proposed and set forth in an award. 8. Project End Date. “Project End Date” means the end date of the sponsored project as stated in the award, including extensions and modifications. 9. Residual Balances. “Residual Balances” means the cash or unobligated balances remaining after the Sponsored Project termination and after all appropriate expenditures have been charged against the sponsored project. 10. Significant Residual Balances. “Significant Residual Balances” means residual balances when the unexpended balance is 25% or greater than the total payments received for the sponsored project. 11. Sponsor. “Sponsor” means any external entity that provides funding to UNT for sponsored projects. Sponsors may be (i) governmental agencies (for example, federal, state, or local governments or their administrative organizations); (ii) nonprofit organizations (for example, universities, nonprofit corporations, foundations, or associations); (iii) for profit organizations (for example, corporations, partnerships, sole proprietorships, and other business entities); or (iv) individuals. Governmental, nonprofit, and for-profit sponsors are sometimes referred to by themselves and others as “agencies.” 12. Sponsored Project. “Sponsored Project” means a project funded by an external sponsor through a grant or contract with UNT where one or more

of the following obligations apply (examples of sponsored projects include but are not limited to instruction projects, public service projects, or research projects): a. Financial obligation – UNT is required to comply with conditions imposed when a sponsor awards funding for the performance of services or delivery of products described in a statement of work; b. Regulatory obligation – UNT is required to comply with sponsor regulations, which may include federal or state regulations; c. Reporting obligation – UNT is required to provide to the sponsor technical performance reports or regulatory or administrative reports; d. Performance Obligation – UNT is required to perform within a certain period and may be required to meet other specified requirements related to performance; e. Accounting obligation – UNT is required to establish a separate accounting record of project expenditures to demonstrate allowance of costs to maintain financial accountability, to provide financial reports to the sponsor, and to preserve appropriate records for audit purposes. Procedures and Responsibilities. I. Initiation of Closeout. It is the policy of UNT that the closeout of a sponsored project will occur in accordance with applicable, federal, state, and local government regulations, the terms of the award, and within the timeframe required by the sponsor. A. Project Termination Notice – 90, 60 and 30 days prior to the project end date, the Grants and Contracts Administration (GCA) will send a project termination notice to the Principal Investigator. The PI should review the items in the project termination notice and take action where needed. B. No Cost Extension - After receipt of the project termination notice, the Principal Investigator must notify the GCA of any intent to request a no-cost extension. The Office of Grants & Contracts Administration and the Principal Investigator shall coordinate to request an extension from the sponsor. Responsible Party: Principal Investigator; GCA

II. Closeout Timeline. All sponsored project grants and contracts have end dates that require a variety of closeout procedures. The Principal Investigator, GCA, and Grants and Contracts Specialist are responsible for coordinating in order to meet all sponsored projects close requirements for the expenditure end date and the closeout end date as required by the award. A. Federal – Federal regulations require all performance, financial, and other required reports to be submitted within 90 calendar days after completion of the award unless a sponsoring agency approves a longer period. B. Federal Pass-Through – Non-federal agencies that pass through federal funds to UNT are responsible for reporting to the federal agency within the federal timeline. Therefore, UNT is contractually obligated to complete closeout and final reporting to the non-federal agency in a shorter timeframe. The deadlines vary from agreement to agreement, but the standard is typically 60 days C. State – State of Texas agencies typically allow 90-days for award closeout. However, some agencies, specific awards, and awards from other states may require a shorter timeline. D. Private and Local Government – The closeout period for agreements issued by the private sector and local government entities varies by award. Responsible Party: Principal Investigator; GCA III. Principal Investigator Closeout Responsibilities. During the closeout process, the Principal Investigator is responsible for fulfilling the following in a timely manner to meet sponsor deadlines: A. All appropriate expenditures are charged against the sponsored project by the expenditure date. B. Review all uncertified effort charged to the sponsored project and submit any necessary corrections. The PI is responsible for certifying that effort during the normal effort certification cycle. C. Sub-recipient work and payments are complete. D. Necessary cost transfers (unallowable charges, overspent projects, etc.) have been completed.

E. Remaining encumbrances have been cleared. F. Cost share commitments have been met. G. Deficit balances have been cleared within the timeframe required by the award for the final expenditure report or invoice/voucher to be created and submitted. H. The PI should work with the GCA to provide any necessary information for completion of final reports. The PI is responsible for submitting any required technical reports. The GCA is responsible for submitting financial reports and any other sponsor required reports (for example, property report, report of inventions.) Responsible Party: Principal Investigator, GCA IV. Office of Grants and Contracts Administration Responsibilities. During the closeout process, the and Contracts Administration is responsible for fulfilling the following: A. Finalize sub-recipient monitoring procedures. B. Submit closeout forms, when applicable. C. Ensure applicable closeout reports are completed. D. Submit the final expenditure report and final invoice/voucher as required by the terms of the award. E. Return residual balances to the sponsor, when applicable. F. Transfer retained, residual balances, as appropriate. G. Deactivate the sponsored project in the UNT electronic accounting system to prevent post-closing expenditures from posting. Responsible Party: GCA V. Closeout Reports. Reports required at the close of a sponsored project vary by the type of sponsored project and by the sponsor. The exact nature of the reports required and the deadlines for their submission are typically outlined in the award. Most funding agency sponsors will require technical, financial, and invention reports. Most federal contracts also require a property report, contractor’s release form, and a contractor’s assignment of refunds, rebates,

and credits form. Types of reports that may be required include the following: A. Final Technical or Progress Report – This document describes the process, progress, and/or results of technical or scientific research, or the state of a technical or scientific research problem or project. The Principal Investigator is responsible for submitting the final technical or progress report to the sponsor by the date specified in the award, with a copy to the GCA. B. Final Invention and Patent Report – This document provides a list of inventions or new technology resulting from the project. The Office of Grants and Contracts Administration is responsible for preparing and submitting the final invention, patent or royalty report in coordination with the Office of Innovation and Commercialization to the sponsor by the date specified in the award. The Grants and Contracts Administration will coordinate with the Principal Investigator to obtain the information necessary to file the report. The Office of Innovation and Commercialization will verify any inventions or patents with the Principal Investigator prior to completing and submitting these reports. C. Final Financial Report – This document is the formal record of the financial activities related to the sponsored project, and provides details about the amount spent by the Principal Investigator and the amount received by the sponsor. The Office of Grants and Contracts Administration is responsible for preparing and submitting the final financial report to the sponsor by the date specified in the award. The Grants and Contracts Administration will coordinate with the Principal Investigator to obtain the information necessary to file the report. D. Final Invoice – This document is the claim for final payment that is due to meet expenditures. The Grants and Contracts Administration is responsible for preparing and submitting the final invoice to the sponsor by the date specified in the award. E. Final Inventory Report – The Grants and Contracts Administration in coordination with the Office of Property Management is responsible for maintaining inventory records to accurately account for capital equipment purchased with federal funds. The Office of Grants and Contracts Administration will prepare, certify, and submit final property reports to the sponsor by the date specified in the award. F. Other Reports – Most federal contracts also require a contractor’s

release and a contractor’s assignment of refunds, rebates, and credits form. The Grants and Contracts Administration is responsible for completing and submitting these forms. Responsible Party: Principal Investigator; GCA VI. Residual Balances. Periodically, a Principal Investigator will not utilize the full amount of funds awarded for a sponsored project. During close out of a sponsored project, the GCA is responsible for returning or retaining residual balances in accordance with the terms and type of award. Unless the sponsor stipulates in the award that UNT must return residual funds, unexpended funds may be retained by UNT, depending on the type of agreement. Some sponsors allow automatic carry over from year-to-year for certain projects. If a request for funds to be carried over is required, then the GCA is responsible for making the request in accordance with sponsor requirements. Some sponsors allow UNT to retain residual balances after the closeout of awards. Transfer of retained residual balances must be to designated funds, normally available for use by the Principal Investigator. If there is a significant residual balance, the disposition will be determined after justification by the Principal Investigator and approval by the Assistant Vice President of the Grants and Contracts Administration. Responsible Party: Principal Investigator; GCA References and Cross-references. None Forms and Tools. None Approved: 6/15/2020 Effective: 6/15/2020 Revised: 6/15/2020

13.015 EFFORT REPORTING Policy Statement. This policy sets forth the requirements to ensure compliance with Federal regulations regarding accounting for and documenting personnel cost charges to sponsored awards. The personnel charges to these awards must be based on records that accurately reflect the work performed. The Office of Management and Budget has issued “Uniform Guidance” (OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 CFR Part 200, et al) which replaces the administrative, accounting, and audit rules and principles that were promulgated in the OMB Circulars, including A-21, A-110, and A-133. The Uniform Guidance establishes the principles that colleges and universities must follow. These principles are used to determine the allowability of expenditures on federally sponsored program funds. The University of North Texas has chosen to require effort reporting for faculty, professional staff, and graduate students at least three times a year. Application of Policy. This policy applies to all faculty, staff, graduate and undergraduate students engaged in sponsored project activities. Effort reporting is required of all individuals who are paid from a sponsored project or who commit a percentage of their effort as mandatory or voluntary committed cost sharing to a sponsored project. Definitions. 1. Certification. “Certification of Effort” means that a confirmation of the work that has been performed. Each activity (e.g., sponsored project) is attributed a percentage of the effort during the reporting period that is reasonable in relation to 100% of total effort for all activities for which the individual is paid by UNT during the period and that the charge to each award is appropriate in relation to the work performed. 2. Cost Sharing. “Cost Sharing” means the portion of sponsored project cost that is not borne by the sponsor but is allocated to UNT. Cost sharing may involve cash and/or in-kind contributions, and may consist of institutional funds or funds from outside sources. 3. Departmental Research. “Departmental Research”, as defined in OMB

Circular A- 21, Paragraph B.1.a.(2) as relocated to the Uniform Guidance, 2 CFR, Part 200, as revised or superseded means research, development and scholarly activities that are not organized research and, consequently, are not separately budgeted and accounted for. 4. Effort. An individual’s effort is defined as the total amount of time that they spend on any activity for which they are compensated by the University of North Texas. Effort is expressed as a percentage of an employee’s total time spent on University activities. Effort typically include time spent on sponsored projects (whether directly charged or contributed as cost sharing), teaching and instruction, service, or other duties for UNT. 5. Effort Report. “Effort Report” means the after-the-fact activity report that documents and confirms the percentage of effort an employee has spent on each specific activity for which UNT compensates the employee. 6. Institutional Base Salary (IBS). “IBS” is defined as the annual compensation paid by the University based upon that individual’s appointment, whether that individual’s time is spent on research, instruction, administration, or other related activities. IBS does not include: a. Bonuses, Task Payments, and incentive compensation b. Summer supplemental pay for faculty with 9-month appointments c. Supplemental compensation (e.g., augmentation) that may be issued for temporarily performing duties that fall outside of the duties and responsibilities associated with the current appointment d. Overload teaching e. Reimbursed expenditures f. Any income earned by an employee outside of their UNT employment 7. OMB Circular A-21. “OBM Circular A-21” means United States Office of Management and Budget (OMB) Circular A-21, “Cost Principles for Educational Institutions,” relocated to 2CFR, Part 200, as revised or superseded. 8. Principal Investigator (PI). “Principal Investigator” or “PI” means a single individual who, in the event of an award from an external funding agency, shall have the full and final responsibility for the conduct of the project as proposed and as set forth in the award.

Activities Included In Total University Effort

Activities Excluded From Total University Effort

Instruction/university supported academic effort — includes all teaching and training activities whether offered for credit or non-credit, student mentoring and advisement

External consulting, and paid service on external boards and for other types of professional organizations when paid by someone other than UNT

Sponsored project activities — includes activities such as research, research training, and public service. Also includes activities contributing and integrally related to work under a sponsored project award. Refer to the Expending Effort and Charging Effort to Sponsored Projects Section below, for specific activities that can be included as sponsored project activities.

Volunteering as an individual for community or public service

Departmental research — includes unfunded research effort, peer review of manuscripts and proposal preparation for competitive awards

Special activities for which a one-time, extra payment is received

Organized research — includes all research and development activities of an institution that are separately budgeted and accounted for: 1) Sponsored research — all research and development activities that are sponsored by Federal and non-Federal agencies and organizations. This term includes activities involving the training of Activities over and above an employee’s job individuals in research techniques (commonly called requirements, such as overtime or faculty research training) where such activities utilize the overload same facilities as other research and development activities and where such activities are not included in the instruction function. 2) University research — all research and development activities that are separately budgeted and accounted for by the institution under an internal application of institutional funds. Administrative or university service — administrative assignments such as department Unit Administrator, institutional committees, advisory boards, other departmental or university activities

Incidental activities — non-routine, nonrecurring activities that are not a routine part of an individual’s employment

Public service on behalf of UNT, including institutional community service

Other activities unrelated to an employee’s primary job with UNT

Unpaid service to professional organizations or societies related to one’s field of work

9. Significant Difference. “Significant Difference” is a variance of 5% or more above or below an employee’s effort given to a particular sponsored project or institutional activity. A significant variance requires that the effort report be revised to reflect the significant change in effort. 10. Sponsor. “Sponsor” means any external entity that provides funding to UNT for sponsored projects. Sponsors may be (i) governmental agencies (for example, federal, state, or local governments or their administrative organizations); (ii) nonprofit organizations (for example, universities, nonprofit corporations, foundations, or associations); (iii) for profit organizations (for example, corporations, partnerships, sole proprietorships, and other business entities); or (iv) individuals. Governmental, nonprofit, and for profit sponsors are sometimes referred to by themselves and others as “agencies”. 11. Summer Salary. “Summer Salary” is compensation to faculty for effort performed beyond their period of 9-month appointment. The basis for calculation of an individual faculty member’s summer salary that can be charged to a sponsored project is the regular compensation received during the period of appointment. As an example, for faculty on a 9-month (academic year) appointment, each month of summer compensation will be limited to and calculated at the rate of 1/9th of the salary for the academic year preceding the summer effort. The summer effort reporting period should only include effort provided during the summer effort reporting period from June 1st thru August 31st. A manual effort report is the appropriate mechanism to make a correction that needs to be retroactively applied for the academic year. A faculty member with any academic, administrative, or other non-sponsored responsibilities during the summer, should not normally contribute more than 95% of their effort to sponsored projects. 12. Total University Effort. “Total University Effort” means all activity for which UNT compensates an individual with institutional base salary. Total university effort is not synonymous with full time employment (FTE). Total university effort is the cumulative number of hours spent each day to accomplish tasks associated with an individual’s appointment or job assignment for which the individual receives IBS. For example, a full-time regular work week of 40 hours may be represented by 100% FTE in the payroll system. However, effort is reported as a percentage of the total number of hours worked and total university effort represents the total number of hours actually worked that week. They could be more or less than the official 40 hours designated on the payroll system.

Procedures and Responsibilities. A. General Procedures: 1. All individuals including, PI’s, College Research Officers (CRO’s), research administrators, colleges and departmental administrators who are involved in the entering and approving of personnel/payroll transactions on sponsored projects should review and be familiar with the policy and procedures related to effort reporting. All researchers and others who are authorized to certify effort are required to complete the annual online effort training course prior to performing an effort certification. B. Proposal Process: 2. The Principal Investigator (PI) is responsible for determining the appropriate effort committed on a sponsored project. They provide an initial estimate of the effort required to perform the scope of work in their proposal. The effort must reflect a reasonable estimate of the time that will be required to conduct the project. During the life of the project changes in the percentage of effort are made based upon the actual effort contributed during the current effort reporting period. Modifications to effort are processed through the payroll system and are also reflected on the effort report for that reporting period. 3. The PI should consider the minimal commitment appropriate for their level of effort along with other key personnel during the project. In accordance with this policy, effort can be increased during the academic year, the summer, or both. The minimum requirement does not apply to equipment grants and awards with a specific purpose such as travel or conference awards. C. During the Life of the Project: 4. The PI is required to use the PeopleSoft effort certification process to certify the effort of all persons working on their sponsored projects, the PI is ultimately responsible for the accuracy of the certification. The certification is normally performed by the PI within the PeopleSoft certification process. 5. The effort expended on total institutional activities must not exceed 100%. Generally, most PI’s and Co-PI’s have responsibilities for teaching, committee work or public service that would preclude them from devoting 100% of their time to sponsored activities; exceptions to this include

key research staff who do not have other responsibilities. The University normally requires that a faculty member commit not more than 95% effort on sponsored projects. In all cases, the faculty’s 9-month salary rate cannot exceed his/her institutional base salary (IBS) rate on sponsored projects. 6. In situations where the effort of the faculty will either be charged or contributed (cost sharing) to sponsored activities and exceeds the approved amount of the college, the PI must gain approval of the Unit Administrator and/or dean to ensure that the total institutional activities do not exceed 100%. 7. Fulfillment of effort commitment for a sponsored project is measured over an entire budget period for a sponsored project, typically one year. During that period, an individual’s level of devoted effort may vary. Variation is acceptable, as long as the individual fulfills the effort commitment for a sponsored project over the entire budget period. A one-year project budget period spans multiple effort expenditure periods and the individual is obligated to charge salary to the project and to certify devoted effort consistent with actual effort within each effort expenditure period. For example, an individual who has committed 30% effort to a federalfunded project during a calendar year budget period could fulfill that commitment by expending 40% effort during the first six months of the year and 20% during the second six months. Consequently, each effort report would show something other than 30% effort. It is not permissible to allocate salary at a constant 30% rate for the entire budget period, when actual effort is substantially greater during the first half of the budget period than the second half. The principal investigator is responsible for being aware of variations of effort within each effort expenditure period in order to ensure that effort commitment is met over an entire sponsor project budget period. 8. Each university department has oversight responsibility to ensure that the faculty commitments are being reviewed and that faculty are advised to ensure that effort commitments are being met over the budget period. 9. Departmental administrators should assist the faculty in reviewing effort (e.g., in the approved budget and ePARs), salary and labor charges, as recorded in the accounting and payroll systems, on a regular basis and submitting documents to make changes or corrections if they are needed. 10. The PI is required to complete the effort certification within the 30 days certification period.

D. Summer Salary: 11. The number of months during the summer that a researcher can claim salary on a sponsored project may be limited by summer teaching assignments and also by individual funding agencies. The number of summer months charged should reflect the period the faculty member is actively contributing effort to a project. 12. Commitment of summer effort for all sponsored activities may be up to, but not more than, 95% assuming that the faculty member does not teach during the summer. Some agencies do not allow payment of salary for all three months during the summer (e.g., NSF). Faculty should check the sponsoring agency guidelines or contact their research administrator or GCA for assistance. E. NIH Salary Cap: 13. For NIH awards, the salary rate charged to NIH awards cannot exceed the annual salary rate mandated by the annual NIH salary cap. The annualized salary rate of a faculty member is calculated by adding their Academic Year salary with three months of summer salary. The NIH salary cap is revised every calendar year and is available at https://grants.nih.gov/ grants/policy/salcap_summary.htm. F. Recertification of Effort: 14. Once certification of an effort report has been completed, recertification is not normally allowed except in rare circumstances with the approval of the Vice President of Research and Innovation or the Assistant Vice President of the Office of Grants and Contracts Administration or their designee. If it is necessary to adjust salary charges for a previously certified effort period, documentation to reallocate must provide a detailed explanation of the need for salary adjustment and subsequent recertification and any cost transfer must be in accordance with UNT policies and procedures regarding cost transfers for sponsored projects. The PI is responsible for completing a recertification promptly after receiving notice that certification has been re-opened. Responsibilities. 1. Vice President of Research and Innovation in coordination with the Senior Vice President of Finance and Administration a. Establishing and updating UNT’s effort reporting policy.

Responsible Party: Vice President of Research and Innovation and the Senior Vice President of Finance and Administration 2. Deans, Associate Deans and Department Unit Administrators a. Understanding and ensuring compliance with the University of North Texas effort reporting policy and procedures. b. Providing oversight, effective processes, controls, and problem resolution. Responsible Party: Deans; Associate Deans; and Department Unit Administrators 3. Grants and Contracts Administration (GCA) a. Preparing, reviewing, and distributing effort confirmation reports three times a year for faculty, staff, and graduate students. Note: Undergraduate student effort is reflected on their hourly timesheet which is processed by Payroll and is not included in this process. b. Providing online training on effort policies and procedures and for overseeing the effort reporting process. c. Coordinating audits of Effort Reporting and/or providing supporting information to auditors or agencies as requested. Responsible Party: Grants and Contracts Administration (GCA) 4. College Research Officers (CRO’s) or Departmental Administrators a. Each university department has oversight responsibility to ensure that the faculty commitments are being reviewed and that faculty are advised to ensure that effort commitments are being met over the budget period. b. Reviewing effort (e.g., in the approved budget and ePARs), salary and labor charges, as recorded in the accounting and payroll systems, on a regular basis and submitting documents to make changes or corrections if they are needed. c. Each university department is also responsible for ensuring that the effort confirmations are reviewed, certified, and completed timely. Responsible Party: College Research Officers (CRO’s); Departmental Research Administrators (DRA’s); or Departmental Administrators 5. Principal Investigators a. Ensuring compliance with this policy for his or her awards, including those awards where the Co-PI has a separate project ID set up for their part of the award or in other situations where the Co-PI has effort reporting responsibility.

b. Meeting with their CRO/DRA or departmental administrator to review the project plan and the PI and Co-PI effort commitments. The labor/ stipend charges in the ledgers should be reviewed and compared to the effort report. Any significant differences from actual effort require a labor distribution change to reflect the actual effort incurred during the period. c. Certifying his or her effort report in a timely fashion. The PI should ordinarily approve the effort reports for each person paid from or contributing effort to sponsored projects, including staff, graduate students, post-doctoral fellows, and undergraduates (hourly timesheets serve as an effort certification). If the PI is not able to approve the report online, a manual report may be created for the PI or in rare circumstances, a designated employee (such as a lab manager) who has a suitable means of verification that the work was performed, may approve the effort certification. Responsible Party: Principal Investigator Failure to Comply. Since failure to follow federal effort reporting rules could result in audit findings which include expenditure disallowances and penalties or fines levied against the University of North Texas, the University will take corrective action in the event that this policy and associated procedures are not followed, including, but not limited to, disciplinary action. In situations where a falsified Effort Report is certified, criminal charges may be brought. To ensure compliance with effort reporting policy and procedures, UNT may suspend grant submissions from the involved individuals until the delinquent PI or Co-PI effort reports are properly completed and certified, unless an exception for extenuating circumstances is approved by the Vice President for Research and Innovation. Reports that are not certified by the scheduled effort reporting certification deadline will be considered overdue. Reports will be considered delinquent if not properly completed and certified within 30 business days from the date of the scheduled effort reporting certification deadline. During this 30-day period, GCA will endeavor to notify department Unit Administrators, deans, associate deans, and PIs about issues with effort reports that have not been timely or properly completed, certified, and returned to GCA within the reporting deadline.

Forms and Tools. The tables below display the effort reporting periods and the timeline for certifying effort. UNT Effort Reporting Procedures Guide References and Cross-references. UNT Policy 13.007 Sponsored Projects UNT Policy 13.002, Award Management and Financial Administration of Sponsored Projects UNT Policy 13.017 Cost Transfers for Sponsored Projects UNT Policy 13.018 Cost Sharing for Sponsored Projects CFR 200.430 Compensation-Personal Services (Formerly OMB Circular A-21, Cost Principles for Educational Institutions, Section J.10, Compensation for Personal Services) Revision History. Policy Contact: Chuck Tarantino Approved Date: 09/07/2020 Effective Date: 09/07/2020 Last Revision:

Time Frame for Certifying (90 days)

Responsible Areas and Individuals

Configuration — 30 days

Grants and Contracts Administration (GCA) has 30 days after the effort reporting period to work with ITSS to bring payroll data into the effort reporting system and configure effort reports. GCA is addressing the system functions during this period. GCA is also responsible for auditing reports that are subject to salary caps and other salary limitations during this time period.

Pre-Review Certification — 30 days

The CRO/DRA/Dept Admin has 30 days to review the effort reports in relation to the ledgers and the PI project plan in conjunction with the certifiers. GCA will send out an email notification to the CRO/DRA or Departmental Administrator when the forms are ready for pre-review. During this period, the PI should use this time to verify effort and update cost share contributions to projects.

Certification — 30 days

The PIs have this last 30 days to certify the effort reports after which they will be considered delinquent.

Recertification

In rare circumstances, an effort report may be recertified after the initial certification with the appropriate approvals and sufficient back up documentation for the payroll reallocation justifying the recertification.

Effort Reporting Period

Timeline

Fall

Sept. 1 — Dec. 31

Spring

Jan. 1 — May 31

Summer

June 1 — Aug. 31

13.016 SUB-AWARDS AND SUB-AWARD MONITORING Policy Statement. In accepting a sponsored project award, the University of North Texas (UNT) has legally committed itself to fulfill the purposes and requirements of the sponsored project through use of university personnel, resources, and facilities. When UNT makes a sub-award to assign responsibility for conducting a portion of the work required to a sub-recipient, UNT remains responsible to the sponsor for management of the funding and meeting performance requirements. This policy establishes guidelines for: (i) stewardship of funds used to pay sub- recipients; (ii) confirming that UNT and its sponsors receive value for funds expended; and (iii) promoting appropriate responsibility and accountability in university/sub-recipient relationships. Additionally, this policy promotes compliance with federal and state legal requirements related to sub-recipient monitoring. Application of Policy. Faculty and staff engaged in sponsored project activities. Definitions. 1. Award. “Award” means a grant, contract, subcontract, sub-grant, or cooperative agreement that provides funding from an external sponsor of a sponsored project and is entered into between the sponsor and UNT. 2. Contract. “Contract” means any written agreement or other document that creates a legally binding obligation, financial or otherwise, for UNT. Contracts related to sponsored project activity can include but are not limited to: documents with the title of contract, agreement, memoranda of understanding, affiliation agreement, cooperative agreement, interagency contract, professional services agreement, letter agreement, letter of intent, nondisclosure agreement, material transfer agreement, or a purchase order. 3. Contractor. “Contractor” means a consultant, vendor, or service provider who provides ancillary goods or services that UNT needs to conduct a sponsored project research activity. Examples include, but are not limited to, an entity or person who provides: a. Expert advice or consulting b. Non-University labor or services paid for as a “fee for service” c. Commercially available supplies and expendable materials

d. Equipment or component parts for fabricated equipment or equipment which will be delivered to and used by the sponsor or an entity designated by the sponsor 4. OMB Circular A-21. “OMB Circular A-21” means United States Office of Management and Budget (OMB) Circular A-21, “Cost Principles for Educational Institutions,” relocated to 2CFR, Part 220, as revised or superseded. 5. OMB Circular A-110. “OMB Circular A-110” means United States Office of Management and Budget (OMB) Circular A-110, “Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations,” relocated to 2 CFR, Part 215, as revised or superseded. 6. OMB Circular A-133. “OMB Circular A-133” means United States Office of Management and Budget (OMB) Circular A-133, “Audits of States, Local Governments, and Non-Profit Organizations” and August 2017 Compliance Supplement, as revised or superseded. 7. Pass-through Entity. A “pass-through entity”, “PTE”, or “prime recipient” means the direct recipient of funding from a sponsor who passes award funding to a sub- recipient through a sub-award to carry out a portion of the sponsored project. The PTE assumes responsibility for negotiation, issuance, oversight, and management of a sub-award. The PTE also assumes many of the responsibilities typically assigned to a sponsor in issuance and oversight of an award, including verification of the financial viability, adequacy of compliance controls, and audit status of its sub-recipients as well as oversight and verification of a sub-recipient’s fulfillment of its portion of the sponsored project. 8. Principal Investigator. “Principal Investigator” (PI) means a single individual who, in the event of an award from an external funding agency, shall have the full and final responsibility for the conduct of the sponsored project as proposed and as set forth in the award. 9. Sponsor. “Sponsor” means any external entity that provides funding to UNT for Sponsored Projects. Sponsors may be (i) governmental agencies (for example: federal, state, or local governments or their administrative organizations); (ii) nonprofit organizations (for example: universities, nonprofit corporations, foundations, or associations); (iii) for-profit organizations (for example: corporations, partnerships, sole proprietorships, and other business entities); or (iv) individuals. Governmental, nonprofit, and

for-profit sponsors are sometimes referred to by themselves and others as “agencies.” 10. Single Audit. “Single Audit” means the organization-wide audit or examination of an entity prescribed in Subpart F of the Uniform Guidance. 11. Sponsored Project. “Sponsored Project” means a project funded by an external sponsor through a grant or contract with UNT where one or more of the following obligations apply (examples of sponsored projects include but are not limited to instruction projects, public service projects, or research projects): a. Financial obligation – UNT is required to comply with conditions imposed when a sponsor awards funding for the performance of services or delivery of products described in a statement of work; b. Regulatory obligation – UNT is required to comply with sponsor regulations, which may include federal or state regulations; c. Reporting obligation – UNT is required to provide to the sponsor technical performance reports or regulatory or administrative reports; d. Performance obligation – UNT is required to perform within a certain period and may be required to meet other specified requirements related to performance; e. Accounting obligation – UNT is required to establish a separate accounting record of project expenditures to demonstrate allowance of costs, to maintain financial accountability, to provide financial reports to the sponsor, and to preserve appropriate records for audit purposes. 12. Sub-award. A “sub-award” (also referred to as sub-grant if the prime award is a grant, and sub-contract if the prime award is a contract or sub-agreement) means a secondary award provided by a PTE to a sub-recipient in order for the sub-recipient to carry out a portion of the sponsored effort required under the terms of the primary award between the sponsor and the PTE. The definition also includes sub-awards made by a sub-recipient to a lower tier sub-recipient. Sub-awards differ from procurement contracts used to acquire goods or services from vendors. 13. Sub-recipient. A “sub-recipient” means the recipient of a sub-award from a PTE for the performance of a portion of the work statement or programmatic effort required by a prime award. The sub-recipient’s responsibility under a sub-award is also called “programmatic decision-making” under federal

funding terminology. The sub-recipient is accountable to the PTE for the use of sub-award funding. The sub- recipient may be another educational institution, an independent laboratory, a foundation, a for-profit corporation, a non-profit corporation or other organization, and may be a domestic or foreign entity. A sub-recipient may be referred to as a sub-awardee, subgrantee, or lower-tier institution. 14. Sub-recipient Monitoring. “Sub-recipient Monitoring” means a compliance requirement obligating a prime recipient of an award to monitor activities of sub- recipients. This requirement is in accordance with the terms of the prime award grant or contract, as well as applicable federal and state regulations, to assure that awarded funds are used for authorized purposes and to ensure that performance obligations are achieved. 15. Uniform Guidance. “Uniform Guidance” means OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 CFR Part 200, et al. The Office of Management and Budget (OMB) issued Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in the Federal Register. The Uniform Guidance replaces the administrative, accounting, and audit rules and cost principles promulgated in the OMB Circulars, including A-21, A-110, and A-133. The Uniform Guidance took effect on December 26, 2014. Procedures and Responsibilities. I. Grants and Contracts Administration (GCA) is the administrative office responsible for reviewing, negotiating, and submitting grants. Research Commercial Agreements (RCA) negotiates those sub awards and sub contracts related to sponsored projects or contracts, and is responsible for obtaining signature by the sub-recipient and the appropriate representative for UNT. In performing these responsibilities GCA and RCA shall ensure compliance with the prime award, federal and state laws and regulations, institutional policies, and UNT System Regents Rules. Responsible Party: GCA and RCA II. The Principal Investigator (PI) is responsible for determining the need for a sub- award and providing notice and justification for selection of the sub-recipient to GCA. The PI’s original proposal must include a separate statement of work and line-item budget for each proposed sub-award. GCA is responsible for reviewing award proposals prior to submission to ensure that sub-awards are allowable and appropriately budgeted for in the prime

award. RCA shall issue a sub-award only after receiving a fully executed prime award from a sponsor. Responsible Party: Principal Investigators, GCA and RCA III. Before entering into a relationship with another entity in which the entity will provide goods or services or substantive, programmatic work to UNT that relates to an award, GCA must determine the nature of the legal relationship between UNT and the other entity. The classification of contractor versus sub-recipient will determine the type of legal agreement required to document the relationship. Properly classifying the relationship is essential because it determines the allocation of responsibilities as well as influences the appropriate application of indirect cost rates, proper accounting for costs, and other compliance requirements. In making the determination regarding classification, GCA shall follow the Uniform Guidance requirements set forth in 2 CFR §200.330. Responsible Party: GCA IV. Risk Assessment and Scoring. Prior to issuing a sub-award, a prospective sub-recipient shall be required to (1) complete and return to RCA a UNT Sub-Recipient Monitoring Form; and (2) provide a copy of their most recent Single Audit to RCA. Alternatively, RCA may obtain the most recent Single Audit from the Federal Demonstration Partnership Expanded Clearinghouse (FDP Clearinghouse) if the prospective sub-recipient is a member. If a prospective sub-recipient does not receive a Single Audit, the prospective sub-recipient must complete and return a UNT Risk Assessment Questionnaire to RCA. RCA will assess and document the sub-recipient’s risk of non-compliance considering the following factors and any other factors determined to be relevant: a. Research focus of the sub-recipient and familiarity with U.S. regulations governing the conduct of research; b. The maturity of the prospective sub-recipient organization; c. Type of award making up the original funding source (Federal or State grants, federal or state cooperative agreements or grants with special conditions, subcontracts, or industry contracts); d. Sub-award amount and total percentage of the Prime Award flowing to the sub-recipient;

e. Ability of sub-recipient’s established accounting system to manage federal funds in accordance with federal regulations; f. Ability of sub-recipient’s established procurement systems to comply with OMB procurement guidelines; g. Whether the sub-recipient has a negotiated indirect cost rate agreement; h. Sub-recipient’s previous Single Audit results; i. Inclusion of export-controlled elements in sub-recipient’s scope of work; j. Inclusion of animal or human subjects in sub-recipient’s scope of work; k. Audit restrictions and transparency of sub-recipient; l. Adequacy of established sub-recipient facilities to perform the work; m. Potential for conflict of interest due to relationship between UNT PI and sub-recipient; n. Significance and complexity of the sub-recipient’s cost-share commitment; o. Complexity of sub-recipient’s statement of work RCA will establish a “risk score” for each sub-award using the UNT Risk Assessment Matrix, a weighted scoring tool used to evaluate the total risk based on the compilation of the above-listed factors. For UNT, there are three risk scores: low, medium and high. Low-risk sub-awards do not require an individualized risk mitigation plan, but RCA may require additional riskmitigating terms for such sub-award. Medium-risk sub-awards undergo an individual assessment by RCA along with GCA to determine whether a Risk Mitigation Plan is needed. High-risk sub-awards require an individualized Risk Mitigation Plan, prepared by RCA in coordination with the Assistant Vice President of GCA. Risk Mitigation Plans will be provided to the PI and must be acknowledged by PI signature prior to issuance of a sub-award. Responsible Party: RCA and GCA V. Sub-awards shall be set forth in a written document negotiated by RCA and executed by an appropriate representative for UNT. The terms and conditions of the sub-award shall be consistent with the sub-recipient’s risk rating. A

sub-award shall include the following information and must document the terms of the sub-recipient’s responsibilities regarding: a. Federal award identification elements, if applicable (CFDA name and number, FAIN, award date, agency name, agency contact information, R&D indicator, FFATA information, etc.); b. Flow-down provisions from the prime agreement; c. Additional terms set forth in the Risk Mitigation Plan; d. Certification that the Sub-Awardee is not debarred or suspended; e. Performance obligations; f. Period of performance; g. Appropriate indirect cost rate; h. Sub-award budget and any revision restrictions; i. Cost accounting systems; j. Property management, when applicable; k. Invoicing; l. Financial and performance reporting requirements and other reporting as necessary; m. Audit requirements; n. Procedures and timeline for award closeout; and o. Remedies for noncompliance. RCA shall ensure that sub-agreements executed with sub-recipients are accurate, complete, and compliant with the prime award. Responsible Party: RCA VI. When the Principal Investigator has an interest in or a relationship with the sub-recipient entity, it will be managed as required by UNT Policy 13.005, Conflict of Interest for Sponsored Projects. Responsible Party: Principal Investigator, RCA, ORIC and GCA VII. Sub-awards related to federally-sponsored prime awards issued prior to December 26, 2014 are subject to OMB Circular A-21, OMB Circular A-110, and

OMB Circular A133. Sub-awards related to federally sponsored prime awards issued December 26, 2014 or later are subject to the Uniform Guidance. A federal sponsor may require adoption of the Uniform Guidance on awards made prior to December 26, 2014, in which case the Uniform Guidance shall apply. Responsible Party: Principal Investigators; GCA; RCA; faculty and staff engaged in sponsored project activities VIII. In accordance with Regents Rule 03.900, Delegation of Authority for Contracts and Agreements, and UNT Policy 10.4, Contracts and Agreements, RCA shall obtain authorized signatures on the final sub-award grant or contract from the appropriate representative for UNT and the sub-recipient. RCA shall supply such fully executed sub-award grant to GCA who shall provide a copy of the fully executed sub-award grant or contract to the PI. Responsible Party: GCA and RCA IX. Sub-recipient Monitoring. As a recipient of federal funding, UNT is required under Uniform Guidance to monitor the activities of sub-recipients to ensure that sub-award funding shall be used for an authorized purpose and in compliance with laws, regulations, and terms of the prime award. GCA, College Research Officers (CROs) and the PI shall be responsible for verifying and documenting, with appropriate evidence, a sub-recipient’s compliance with the requirements of this policy and the terms and conditions of the sub-award when sub-awards are executed, prior to payment of each invoice, and at the closeout of all sub-awards. For prospective sub-recipients who are participants in the Federal Demonstration Partnership Expanded Clearinghouse (FDP Clearinghouse), RCA shall review the most recent Single Audit and other financial information from the FDP Clearinghouse prior to issuance of a sub-award. If a prospective sub-recipient is not a participant in the FDP Clearinghouse, RCA shall obtain a completed Sub-recipient Monitoring Form from a prospective sub-recipient prior to the issuance of a sub-award. Thereafter, on an annual basis, GCA shall obtain updated information from the FDP Clearinghouse. If a new Subrecipient Monitoring Form is required from a sub-recipient because they are not included in the FDP clearinghouse, RCA will contact the sub awardee as a part of the negotiation process to obtain the form. If an active sub-recipient’s Single Audit reports any findings of noncompliance, significant deficiencies, or material weaknesses, RCA will

coordinate with GCA to assess the risk and, if necessary, establish a Risk Mitigation Plan for the sub-recipient. The Risk Mitigation Plan will be signed by the AVP of RCA and the PI. For sub-recipients that report material weaknesses specifically related to sponsored project activities contained in the pending sub-agreement or do not provide the completed Sub-recipient Monitoring Form in a timely manner, GCA shall develop and implement a plan of corrective action. The PI holds final approval rights for all technical components of the subaward. The PI shall be responsible for reviewing sub-recipient invoices and providing payment approval to the College Research Officers or GCA Post Award by email. By approving the invoice, the PI is attesting that the stipulated sponsored project scope of work is being or has been completed according to specifications and schedules in the statement of work. This action also enables the PI to monitor the rate of expenditure to determine if costs are reasonable, confirm that the work is progressing as planned and in accordance with spending, and determine if there will be sufficient funds for the duration of the project. The PI is responsible for monitoring all work in progress. At a minimum, this shall entail regular, informal contact with the sub-recipient (although monthly or quarterly technical reports should be required in the sub-award agreement if the PI or GCA deems necessary). If required, the PI shall ensure the receipt of reports on a timely basis. The PI shall maintain documentation of any communication with the sub-recipient during the performance period of the sub-award. The PI must follow GCA procedures for monitoring sub-recipient compliance during the period of performance of the sub-award and during closeout of the sub-award. Sub-award invoices presented to the CRO’s or GCA Post Award for payment must have the PI approval documented. The CRO or GCA Post Award shall perform a secondary review of all approved invoices to ensure they meet budgetary restrictions. When necessary, additional documentation or clarification may be requested from the sub-recipient to ensure unallowable costs do not exist. Such documentation or clarification may include, but is not limited to, the following: a. Clarification of invoiced charges that appear unusual, excessive, or questionable; b. Detailed documentation to verify the allowability of a cost; c. Payroll records;

d. Copies of paid invoices; e. Descriptions of services performed; and f. Travel documentation. Responsible Party: CRO’s, GCA Post Award, Principal Investigator X. In the event of noncompliance, nonperformance, or inadequate performance by the sub-recipient, the PI should immediately contact GCA to discuss possible courses of action, which may include withholding payment, suspending work, or terminating the sub-award. Decisions regarding such actions can only be made by and issued by GCA; the PI should not discuss such possibilities with the sub-recipient without first speaking with GCA because of potential legal implications. Responsible Party: GCA, Principal Investigator XI. Sub-Award Closeout. The PI, Departmental Administrators, CROs and GCA Post Award,must begin sub-award closeout actions immediately following conclusion of the sub-award period of performance and/or when final technical deliverables are received and financial matters are concluded. Sub-award closeout requirements must include, but are not limited to, the following: a. Receipt of final invoice; b. Collection of all required deliverables (technical/progress reports, patent/invention documentation, equipment reports, patent reports, financial reports, audit documentation, etc.) to be provided by the sub-recipient and final verification of technical completion by the PI, indicated by the PI’s approval of the final invoice. c. Completion of any necessary final review of costs charged to the UNT by the sub-recipient and final closeout of all commitments, accrued costs, or payables. The PI is responsible for seeing that an acceptable final report and all deliverables are received from the sub-recipient. GCA Post Award shall be responsible for overseeing financial aspects of the closeout and GCA Pre Award shall be responsible for overseeing the non-financial aspects of the closeout. If there is a problem obtaining a final report from a sub-recipient, the PI should promptly notify GCA Pre Award. The PI must review and approve the final invoice for authorization of the final payment to the sub-

recipient. Final payment to a sub-recipient shall not be approved until all closeout documents and deliverables have been received and approved by the CRO or GCA. During the closeout process for a sub-award, the PI, CROs, and GCA, shall ensure adherence with the closeout requirements of the prime award to which the sub-award is related. Responsible Party: Principal Investigator, CROs and GCA XII. GCA shall maintain official files of each sub-award in accordance with the terms of the prime award, UNT Policy 4.008 Record Management and Retention, and applicable federal and state regulations; and GCA shall continue to do so until conclusion of the sponsor audit (or audit vulnerability period) and the conclusion of the record retention period set out in UNT Policy 4.008 Records Management and Retention. During this period, GCA Post Award shall maintain the accounting records and documentation of expenditures for sub-awards. Responsible Party: GCA References and Cross-references. UNT System Regents Rule 03.900, Delegation of Authority for Contracts and Agreements UNT Policy 10.4, Contracts and Agreements UNT Policy 04.008, Record Management and Retention UNT Policy 13.007, Sponsored Projects UNT Policy 13.005, Conflicts of Interest for Sponsored Projects Forms and Tools. Principal Investigator Handbook Risk Assessment Matrix Risk Mitigation Plan Template Sub-recipient Risk Assessment Questionnaire Sub-recipient Monitoring Form Approved: 06/18/2020 Effective: 06/18/2020 Revised: 06/2020

13.017 COST TRANSFERS FOR SPONSORED PROJECTS Policy Statement. The University of North Texas strives to ensure that those involved in sponsored project activities appropriately charge costs associated with a sponsored project to the correct account from the outset. However, UNT recognizes that cost transfers are sometimes necessary to correct keypunch or clerical errors, allocate costs of closely related work that may support more than one project or to clear a cost overrun or disallowed cost. It may also be necessary to reimburse costs paid from departmental or discretionary resources prior to receipt of a fully executed award if those costs were incurred within the period of performance set in the award. When cost transfers occur, they are required to be handled and accounted for in a manner that is in accordance with best practices, is well documented and that is in compliance with the cost allowable and allocable requirements of OMB Circular A-21, as relocated to the Uniform Guidance, 2 CFR, Part 200. This policy establishes requirements and responsibilities for all cost transfers related to sponsored projects at UNT. Application of Policy. This policy applies to all faculty and staff engaged in sponsored project activities and applies to all sponsored project funding, regardless as to whether received from a federal, state, private or other sponsor. Definitions. 1. Allocable. “Allocable” means a cost incurred that advances the work of a sponsored project and is chargeable to a particular cost objective. 2. Allowable. “Allowable” means a cost incurred that is reasonable, allocable, consistent, and conforms to any limitations or exclusions of the sponsor. 3. Award. “Award” means a grant, contract, sub-contract, sub-grant, or cooperative agreement that provides funding from an external sponsor of a sponsored project and is entered into between the sponsor and UNT. 4. Committed Effort or Effort Commitment. “Committed Effort” or “Effort Commitment” means the amount of effort identified in a sponsored project award agreement or in a sponsored project proposal that is submitted and accepted by the sponsor for funding regardless of whether or not salary support is requested in support of that effort.

5. Cost. “Cost” means an expense that has been incurred by UNT and recorded to the financial accounting system of UNT. 6. Cost Transfer. “Cost Transfer” means the reassignment of a cost to a sponsored project account after the cost was initially charged to another sponsored project account or to a non-sponsored project account in the financial accounting system or official records of UNT. Cost transfers include reassignments of salary, wages, and other direct costs. Reassignment of salaries and wages affecting a sponsored project are covered by Policy 13.015, Time and Effort Reporting. 7. Effort. “Effort” means the amount of time spent on any activity for which an Individual is compensated by UNT. Effort is expressed as a percentage of the Individual’s total institutional activities, which typically includes work on sponsored projects, teaching and instruction, service, or other duties for UNT. 8. OMB Circular A-21. “OMB Circular A-21” means United States Office of Management and Budget (OMB) Circular A-21, “Cost Principles for Educational Institutions,” relocated to 2CFR, Part 220, as revised or superseded. 9. Principal Investigator (PI). “Principal Investigator” or “PI” means a single individual who, in the event of an award from an external funding agency, shall have the full and final responsibility for the conduct of the project as proposed and as set forth in the award. 10. Sponsor. “Sponsor” means any external entity that provides funding to UNT for sponsored projects. Sponsors may be (i) governmental agencies (for example, federal, state, or local governments or their administrative organizations); (ii) nonprofit organizations (for example, universities, nonprofit corporations, foundations, or associations); (iii) for profit organizations (for example, corporations, partnerships, sole proprietorships, and other business entities); or (iv) individuals. Governmental, nonprofit, and for profit sponsors are sometimes referred to by themselves and others as “agencies”. 11. Sponsored Project. “Sponsored Project” means a project funded by an external sponsor through an award with UNT, where one or more of the following obligations apply (examples of sponsored projects include but are not limited to instruction projects, public service projects, or research projects): a. Financial Obligation – UNT is required to comply with conditions imposed when a sponsor awards funding for the performance of

services or delivery of products described in a statement of work; b. Regulatory Obligation – UNT is required to comply with sponsor regulations, which may include federal or state regulations; c. Reporting Obligation – UNT is required to provide to the sponsor technical performance reports or regulatory or administrative reports; d. Performance Obligation – UNT is required to perform within a certain period and may be required to meet other specified requirements related to performance; e. Accounting Obligation – UNT is required to establish a separate accounting record of project accountability, to provide financial reports to the sponsor, and to preserve appropriate records for audit purposes. 12. Total Institutional Activities. All activities for which an Individual is compensated by UNT as a result of his or her employment, including but not limited to, service on UNT committees, teaching, performing duties associated with committee-work or teaching, public service, continuous administrative duties (Unit Administrator, dean, etc.), and research (which may or may not be pursuant to a sponsored project). 13. Uniform Guidance. “Uniform Guidance” means OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 CFR Part 200, et al. The Office of Management and Budget (OMB) issued Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in the Federal Register. The Uniform Guidance replaces the administrative, accounting, and audit rules and principles promulgated in the OMB Circulars, including A-21, A-110, and A-133. Procedures and Responsibilities. 1. Grants and Contracts Administration is responsible for overseeing and approving all cost transfers related to sponsored projects. Responsible Party: Grants and Contracts Administration 2. Frequent, late and/or inadequately explained cost transfers, especially those made near or after the end of the performance period and relating to sponsored projects with cost overruns or unexpended balances, raise serious questions about the propriety of the cost transfers and internal fiduciary controls.

Sponsors and auditors regard suspicious cost transfers with the following characteristics: • Frequent cost transfers; • Costs transferred long after the original charges were recorded; • Cost transfers supported by inadequate documentation or justification; • Cost transfers made at the end of a sponsored project that relieve overruns or that spends a sponsored project balance. It is the policy of UNT that a cost must be applied to the account associated with the sponsored project that has benefited from the cost incurred and that this application must be posted into official records found in the financial accounting system of UNT. After the initial posting of a cost, Grants and Contracts Administration will only approve and post a cost transfer if allowable and allocable under the Uniform Guidance and if the cost transfer is in accordance with best practices as determined by Grants and Contracts Administration through this policy. Responsible Party: Principal Investigators; Grants and Contracts Administration 3. The Principal Investigator is responsible for monitoring sponsored project expenditures on a regular and timely basis to ensure that all costs are reasonable and have been reported and applied correctly and that costs are allowable and allocable and comply with federal, state, and UNT System and UNT rules, regulations, policies and procedures. In addition, the Principal Investigator should check to ensure that salary costs comport with effort commitment. In the event it is necessary to request a cost transfer, the Principal Investigator will complete a Cost Transfer Request Form and submit it to Grants and Contracts Administration with supporting documentation. The principal investigator, and department administrators shall ensure completeness, accuracy, and timeliness of requested cost transfers. The request for a transfer must be initiated promptly (within 90 days of the end of the month of the original transaction date or within 30 days of the sponsored project end date, whichever is earlier). After this period, cost transfers will only be permitted under extenuating circumstances, and will require an additional written justification and detailed documentation of the reason for the transfer, and the Cost Transfer Request Form will require signature by the Principal Investigator, and by the appropriate Unit Administrator or Dean in the case of a Unit Administrator submitting the

transfer. When a correction will benefit a sponsor, then a cost transfer must be initiated to correct errors regardless of the timeframe, unless the sponsor deems the dollar amount to be immaterial. Responsible Party: Principal Investigator; Unit Administrators and Deans 4. Grants and Contracts Administration provides fiscally sound management of sponsored project costs and ensures that cost transfers to or from sponsored projects are made promptly and in accordance with this policy, the Uniform Guidance and applicable law. Grants and Contracts Administration is responsible for the following: a. Reviewing Cost Transfer Request Forms and approving or denying all cost transfers, ensuring the requested cost adjustments or changes comply with appropriate policies, rules and regulations; b. For cost transfers related to effort and effort commitment, notifying and obtaining the approval of the Provost and Vice President for Academic Affairs or his or her designee prior to making any cost adjustments; c. Posting cost transfers associated with sponsored projects in the official records of the financial accounting system for UNT; and d. Maintaining official records related to cost transfers made to sponsored projects, in accordance with the terms of the grant or contract, UNT Policy 4.008 Records Management and Retention, and applicable federal and state regulations; and continuing to do so until conclusion of the sponsor audit or audit vulnerability period and the conclusion of the record retention period also set out in UNT Policy 4.008 Records Management and Retention. Responsible Party: Grants and Contracts Administration; Vice President for Research and Innovation 5. Under no circumstances will Grants and Contracts Administration allow costs that benefit one sponsored project to be charged temporarily to another sponsored project (equivalent to a loan). This results in improper financial reporting and inappropriate reimbursement from the sponsor(s). Typically, a cost transfer for salaries that is related to changes in effort is not permitted after effort certification statements are completed and signed by the faculty or staff member or after the sponsored project closeout date unless it benefits the sponsor (i.e., a salary transaction is removed from a sponsored project account). In rare circumstances if it is necessary to adjust salary

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charges for a previously certified effort period, documentation must provide a detailed explanation of the need for salary adjustment, be approved by the Unit Administrator, and/or Dean and Assistant Vice President of GCA along with subsequent recertification. Responsible Party: Principal Investigators; College Research Officers, Departmental Research Administrators, Departmental Administrators and Grants and Contracts Administration 6. If Grants and Contracts Administration becomes aware of an inappropriate charge to a sponsored project or a disallowance is required for a charge to a sponsored project, the principal investigator, and the department and/ or school will be notified to initiate a transfer to a non-sponsored project account. If this transfer is not initiated within five (5) working days from the date of notification, then Grants and Contracts Administration may transfer the charge to an appropriate departmental or school account, with appropriate documentation. Responsible Party: Principal Investigators; Departments and Schools; Grants and Contracts Administration 7. Abuse of cost transfers may result in disallowances and/or subsequent reduction in funding by the sponsor. Abuse may also result in more severe sanctions, fines, penalties and audit criticisms applied against UNT and/or the individuals involved. Violation of this policy can lead to disciplinary action and limitations in the ability to participate in research activities at UNT. Responsible Party: Principal Investigators; Grants and Contracts Administration References and Cross-references. UNT Policy 13.007, Sponsored Projects UNT Policy 13.015, Effort Reporting OMB Circular A-21 relocated to 2 CFR 200 Forms and Tools. Cost Transfer Request Form Principal Investigator Handbook Approved: 6/15/2020 Effective: 6/15/2020 Revised:

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13.018 COST SHARING FOR SPONSORED PROJECTS Policy Statement. As a condition of receiving an award from a sponsor, the University of North Texas is sometimes held responsible for a portion of the cost of the sponsored project. When this occurs, UNT must ensure that the administration of cost sharing is in a consistent and reasonable manner, and that the fulfillment of cost sharing commitments is documented and verified. This policy establishes requirements and responsibilities for monitoring, tracking, reporting, and documenting cost sharing for sponsored projects at UNT. Application of Policy. This policy applies to all faculty and staff engaged in sponsored project activities and applies to all sponsored projects, regardless of how they are funded (eg. federal, state, local, or private sponsor). Definitions. 1. Allocable. “Allocable” means a cost incurred that advances the work of a sponsored project and is chargeable to a particular cost objective. 2. Allowable. “Allowable” means a cost incurred that is reasonable, allocable, consistent, and conforms to any limitations or exclusions of the sponsor. 3. Award. “Award” means a grant, contract, subcontract, subgrant, or cooperative agreement that provides funding from an external sponsor of a sponsored project and is entered into between the sponsor and UNT. 4. Committed Costing Sharing/Matching. “Committed Cost Sharing” or “Committed Matching” means a binding commitment by UNT to provide resources to a sponsored project, which UNT must agree to as part of the terms of an award. All committed cost sharing must be tracked and may require reporting to the sponsor. 5. Cost Sharing. “Cost Sharing” means the portion of a sponsored project cost that is not borne by the sponsor but is allocated to UNT or a third party. Cost sharing may involve cash and/or in-kind contributions, and may consist of institutional funds or funds from outside sources 6. Cost. “Cost” means an expense that has been incurred by UNT and recorded to the financial accounting system of UNT. 7. Effort. “Effort” means the amount of time spent on any activity for which

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an individual is compensated by UNT. Effort is expressed as a percentage of the individual’s total institutional activities, which typically includes work on sponsored projects, teaching and instruction, service, or other duties for UNT. 8. F&A Cost. “F&A cost” means facilities and administrative costs. F&A cost is referred to as “indirect cost.” 9. In-Kind Contributions. “In-Kind Contributions” are a type of non-cash cost sharing where the value can be readily determined, verified, documented, and justified but where no actual cash is allocated in securing the good or service comprising the contribution. When applicable, an estimated value of the in-kind contributions should be determined and documented based on the fair market value at the time of acceptance of the award. In-kind contributions that are used for cost sharing must be tracked manually by the Principal Investigator. 10. Mandatory Committed Cost Sharing. “Mandatory Committed Cost Sharing” means cost sharing required as a condition of an award and included in the terms of the award grant or contract. Mandatory Committed Cost Sharing must be documented and tracked and may require reporting. 11. Matching. “Matching” means a specific type of cost sharing, typically used when a sponsor requires the grantee to “match” the sponsor funding according to a specified ratio. In practice, the “cost sharing” and “matching” are often used interchangeably. 12. OMB Circular A-21. “OMB Circular A-21” means the United States Office of Management and Budget (OMB) Circular A-21, “Cost Principles for Educational Institutions,” relocated to 2CFR, Part 220, as revised or superseded. 13. Over-the-Cap Salary. The portion of a faculty or staff member’s salary and associated fringe benefits that exceed the regulatory maximum imposed by the sponsor (e.g., National Institutes of Health and Department of Defense salary cap). 14. Principal Investigator (PI). “Principal Investigator” or “PI” means a single individual who, in the event of an award from an external funding agency, shall have the full and final responsibility for the conduct of the project as proposed and as set forth in the award. 15. Sponsor. “Sponsor” means any external entity that provides funding to UNT for sponsored projects. Sponsors may be (i) governmental agencies (for example: federal, state, or local governments or their administrative

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organizations); (ii) nonprofit organizations (for example: universities, nonprofit corporations, foundations, or associations); (iii) for-profit organizations (for example: corporations, partnerships, sole proprietorships, and other business entities); or (iv) individuals. Governmental, nonprofit, and for-profit sponsors are sometimes referred to by themselves and others as “agencies”. 16. Sponsored Project. “Sponsored Project” means a project funded by an external sponsor through an award with UNT, where one or more of the following obligations apply (examples of sponsored projects include but are not limited to instruction projects, public service projects, or research projects): a. Financial Obligation – UNT is required to comply with conditions imposed when a sponsor awards funding for the performance of services or delivery of products described in a statement of work; b. Regulatory Obligation – UNT is required to comply with sponsor regulations, which may include federal or state regulations; c. Reporting Obligation – UNT is required to provide to the sponsor technical performance reports or regulatory or administrative reports; d. Performance Obligation – UNT is required to perform within a certain period and may be required to meet other specified requirements related to performance; e. Accounting Obligation – UNT is required to establish a separate accounting record of project accountability, to provide financial reports to the sponsor, and to preserve appropriate records for audit purposes. 17. Total Institutional Activities. All activities for which an individual is compensated by UNT as a result of his or her employment, including but not limited to, service on UNT committees, teaching, performing duties associated with committee-work or teaching, public service, continuous administrative duties (Unit Administrator, dean, etc.), and research (which may or may not be pursuant to a sponsored project). 18. Uniform Guidance. “Uniform Guidance” means OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 CFR Part 200, et al. The Office of Management and Budget (OMB) issued Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in the Federal Register. This regulation provides a government-wide framework for grants management for the

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Federal Agencies who in turn implement these regulations at the agency level (as a part of their Agency Code of Federal Regulations (CFR)) for the grantees. The Uniform Guidance replaces the administrative, accounting, and audit rules and cost principles promulgated in the OMB Circulars, including A-21, A-110, and A-133. 19. Unit Administrator. “Unit Administrator” means an individual with unity supervisory responsibilities. Unit administrators include, but are not limited to directors, chairs, associate deans, and deans. 20. Voluntary Committed Cost Sharing. “Voluntary Committed Cost Sharing” means cost sharing that is included in a sponsored project proposal by UNT on a voluntary basis, quantified in either the proposal budget and/or narrative, and is included as a term in the award grant or contract so that it becomes mandatory and must be tracked and documented. Voluntary committed cost sharing also may require reporting to the sponsor. 21. Voluntary Uncommitted Cost Sharing. “Voluntary Uncommitted Cost Sharing” means cost sharing and effort that are not included as part of the submitted proposal or in the award grant or contract. This type of cost sharing does not need to be tracked or reported. Procedures and Responsibilities. A. Cost sharing activities require the support and coordination of all research community including Principal Investigator, Institutes, Centers, College Research Officer (CRO), Dean, Department Unit Administrator, Grants and Contracts Administration (GCA) and VPRI office. Responsible Party: PI, CRO, Unit Administrator, Grants and Contracts Administration and the Vice President of Research and Innovation B. The GCA is responsible for overseeing and approving all cost sharing related to sponsored projects. The GCA Pre Award and Post Award are responsible for reviewing the cost share form and proposal to ensure that the cost sharing is allocable, allowable, and reasonable in accordance with sponsor requirements, federal and state law and regulations, and UNT policy. The Vice President of Research and Innovation or designee must approve the proposed waiver of any portion of F&A cost recovery. Responsible Party: GCA Post Award C. The Principal Investigator is responsible for identifying resources for cost sharing and obtaining approval of cost sharing from the dean of the school

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and/or college, department Unit Administrator, or director of a center or division that will be providing resources for the cost sharing prior to the submission of a cost share form and the proposal to the GCA. Requests for cost sharing must be completed in a timely manner. Responsible Party: PI D. It is the policy of UNT that only the minimum amount of cost sharing necessary to meet a sponsor’s requirements will be committed to a sponsored project. Therefore, voluntary committed cost sharing is strongly discouraged and is usually not allowable. Cost sharing may be in the form of direct costs (personnel or non-personnel) or F&A costs, subject to the sponsor’s restrictions. Responsible Party: PI, CROs, Unit Administrator, Director Grants and Contracts Administration E. The following funds or expenses cannot be used to achieve cost sharing commitments: 1. Expenses not considered allowable in a federal grant or contract, including but not limited to entertainment type expenses, expenses for general equipment, or proposal-writing activities. 2. Expressly unallowable costs as set forth in the Uniform Guidance, Subpart E – Cost Provisions, General Provisions for Selected Items of Cost. 3. Expenses categorized as unallowable in the sponsored project grant or contract. 4. Over-the-cap salary. 5. Effort commitments used as cost sharing for more than one sponsored project. In order to be allowable, effort commitments must be expended directly in support of the scope of work of a single sponsored project and must coincide with the award’s period of performance. 6. Cost sharing that includes indirect cost differential (the difference between sponsor-approved and University-negotiated rates) unless approved by the Federal, State or Private awarding agency. 7. Valuation for in-kind contributions and services used for cost sharing that is not in accordance with applicable federal regulations. 8. Federal funds, except as authorized by law.

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Responsible Party: PI, CROs; Grants and Contracts Administration F. During the term of an award, the Principal Investigator is responsible for monitoring sponsored project expenditures on a regular and timely basis (at least monthly) to ensure the following: 1. Cost sharing expenses are associated with only one sponsored project; 2. Cost sharing commitments are being met using appropriate resources as specified in the cost sharing form and the award grant or contract; 3. Cost sharing associated with a sponsored project is reasonable, allowable, allocable, and necessary, and costs incurred during the effective dates of the award are timely and accurately charged to the appropriate accounts and sponsored projects; 4. Appropriate creation and maintenance of documentation of cost sharing contributions; 5. Report cost sharing activity to GCA Post Award at the required intervals as necessary under the award grant or contract, but no less often than annually; 6. If the amount of cost sharing has changed or if the cost sharing can no longer be met, contacting GCA Post Award and working with them to address the change in commitment; 7. Upon closeout, providing cost share information and confirming the cost sharing commitment has been met, and coordinating with GCA Post Award to resolve any cost sharing discrepancies. Responsible Party: PI G. Deans, Department Unit Administrators, and Directors are responsible for the following: 1. Providing direction, resources, and oversight to the principal investigator to help ensure that all cost sharing obligations and expenditures are met in accordance with law, federal regulations, the sponsored project grant or contract, UNT policies and procedures, and sponsor policies and procedures; 2. Documenting in a timely manner the allocation of college, department, center, or institute committed cost sharing; 3. Providing resources for cost sharing as committed by the school, college, department, division, institute or center; and

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4. Assuming any financial loss if cost sharing commitments are not met and the sponsor does not approve of a reduction of cost sharing commitment. Responsible Party: Department Unit Administrators H. GCA Pre Award is responsible for the following: 1. Ensuring that cost sharing commitments are appropriately included (or not included) in proposals in accordance with law, federal regulations, UNT policies and procedures, and sponsor policies and procedures; 2. Ensuring that resources for cost sharing are approved and documented in writing prior to proposal submission; 3. Identifying situations where an award is significantly less than requested, and work with the principal investigator and sponsor to determine whether any related cost sharing should be appropriately reduced; and 4. Advising the Principal Investigator, applicable administrative offices, and the appropriate department Unit Administrator, Dean, or Director of the existence and form of cost sharing associated with an accepted award. Responsible Party: GCA Pre-Award I. GCA Post Award is responsible for the following: 1. Providing financial system set-up to accommodate cost sharing as evidenced in the budget and the sponsored project grant or contract; 2. Documenting the cost share expenses that are incurred; 3. Screening sponsored project costs to ensure that costs are allowable and are categorized by the proper account code; 4. Reviewing recorded cost sharing for compliance with UNT commitments; and 5. Reporting cost sharing to sponsors according to sponsor requirements and the terms and conditions of awards. Responsible Party: GCA Post Award

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References and Cross-References. OMB Circular A-21 relocated to 2 CFR 200 Federal regulations regarding Cost Sharing are located in the Code of Federal Regulation, 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. (§200.306 Cost sharing or matching). Forms and Tools. Cost Share Form Principal Investigator Handbook Approved: 6/3/2020 Effective: 6/3/2020 Revised: 6/2020

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