Introduction

  1. About the Policies
  2. Defining Sponsored Programs
  3. Sponsored Programs vs. Gifts

Policy Guide

  1. UNC General Administration (UNC-GA) Policies Related to Research Administration
    1. University Research — Appropriate, Proprietary, Classified
    2. Execute Grant Applications and Assurances of Compliance
    3. General Administration Regulation on Administering Sponsored Programs
    4. SPARC
  2. UNC-Chapel Hill University-Wide Policies and Procedures Related to Research Administration
    1. Responsible Conduct of Research
    2. Classified Research
  3. Federal Regulations Related to Research Administration
    1. Uniform Guidance
    2. Federal Acquisition Regulations (FAR)
    3. Federal Demonstration Partnership (FDP)
    4. Federal Register
  4. UNC-Chapel Hill Research Compliance Components
    1. Human Research Subjects Protection
    2. Humane Animal Care and Use
    3. Scientific Integrity
    4. Research Sponsorship
    5. Research Safety
    6. Conflict of Interest
    7. Health Insurance Portability and Accountability Act (HIPAA)
    8. Export Control

The Office of Sponsored Research (OSR) is the official “go-to” resource for the University of North Carolina at Chapel Hill (UNC-Chapel Hill, University) community involved in sponsored research projects — with helpful staff to inform, train and serve UNC-Chapel Hill investigators, researchers, and support staff. 

Introduction

The term “sponsored research” can be defined as University research that receives funding from an external source, or a “sponsor”. While that is a very simple definition, sponsored research encompasses much more, including considerations that may affect the University financially and legally. Therefore, OSR is not the only office concerned with elements of sponsored research and projects; however, it is considered the central, definitive resource.

The University has a system for managing the many concerns that accompany sponsored research, including accounting, compliance, and reporting. OSR is concerned with financial administration and compliance of sponsored research projects and serves faculty and staff by communicating with sponsoring agencies on behalf of the University.

The following overview describes Federal regulations, University guidelines and policies followed by OSR specific policies and procedures. 

I. About the Policies

In serving faculty and administrators at the University, these policies assist in preparing and submitting proposals for sponsored project funding and managing sponsored funds awarded to the University.

Their threefold purpose is to:

  1. In an organized and coherent fashion, present and explain existing policies and procedures affecting sponsored research funding at the University.
  2. Describe services available to faculty and staff through OSR and other offices involved in sponsored project management.
  3. Serve as a reference and a source for further information and assistance. 

II. Defining Sponsored Programs

The University abides by the criteria provided by the University of North Carolina Sponsored Programs and Research Council (SPARC) to identify “sponsored programs”. OSR is responsible for sponsored programs that encompass any scholarly, professional, or creative activity conducted by University personnel using support from external funding sources through grants, contracts, cooperative agreements, or other agreements. Such programs include but are not limited to organized research, instruction/training, other sponsored research activities, and research/support services. 

III. Sponsored Programs vs. Gifts

There are many distinctions between sponsored programs and gifts. Essentially, research contracts are signed research agreements, where a sponsor places contractual obligations on the research effort to gain something (referred to as a “deliverable”) in return for providing support.

Research grants and cooperative agreements differ slightly. Rather than a mutual agreement, research grants are awarded directly by the sponsoring agency to the University through a Notification of Grant Award (NoGA). Research grants are governed by policies and guidelines, rather than contractual obligations. All three – research contracts, grants and cooperative agreements require deliverables and thus, they are categorized together.

On the other hand, gifts are donations, given voluntarily without the imposition of restrictive contractual obligations by the donor. While gifts may include certain conditions (for example, a donation may go towards a specific type of research), when those conditions include deliverables, the transfer of intellectual property, or provision of data to the funder, it is no longer considered a “gift” but is classified as a “contract” or “grant”. OSR can help with questions about determining categorization of funding. In addition, OSR provides questions to ask in distinguishing between the two in an easy-to-follow procedure: Identifying Funding Opportunities: Gift or Grant?

The Office of University Development is responsible for the administration of gifts to the University.  


Policy Guide

Management of sponsored research is a combined effort of the University of North Carolina General Administration (UNC-GA), the University proper, the sponsors that provide their support to research efforts at the University, and the Principal Investigators (PIs) who spearhead the research itself. OSR considers the policies, regulations, and requirements issued by State, University and Federal offices in light of each and every sponsored research project. This is also the case with non-Federal sponsors. While there are many research policies that govern the University, the State-regulated policies summarized below govern research administration at all UNC constituent institutions, including UNC-Chapel Hill. 

I. UNC General Administration (UNC-GA) Policies Related to Research Administration

UNC-GA policies are established by the UNC Board of Governors, the legal body appointed by the North Carolina General Assembly. The Board is responsible for governing the collection of constituent institutions that compose the UNC multi-campus system. 

  1. UNCGA Policy 500.1 University Research Relations with Government Agencies and Private Entities, discusses three areas of concern regarding university research:
    1. Appropriateness in Research. Research collaborations must support teaching, research and public service while allowing faculty and students freedom to pursue and publish research and findings. Research must be conducted under conditions that ensure academic integrity.
    2. Proprietary Information. University researchers have the basic right to disseminate their research findings, except in cases where agreements must be made to protect shared proprietary information. Any agreement involving joint use of University facilities for proprietary purposes, or one that restricts publishing research findings, must be reported to the President of the UNC-System.
    3. Classified Research. In general, sponsored research must be conducted while maintaining openness in teaching and research. In exceptional cases (including those involving the United States government), where classifications impose limitations on dissemination of research findings, the Chancellor may waive the openness requirement in the greater interest of the University, State, or Nation.  
  2. UNC-GA Policy 500.3 Authorizing the President to Execute Grant Applications and Assurances of Compliance gives the North Carolina Office of the President the authorization to determine appropriateness and execute documents of compliance on behalf of the Board of Governors.  
  3. UNC-GA Policy 500.4[R] Regulations on Administering Sponsored Programs establishes general requirements and responsibilities of the University of North Carolina Office of the President and constituent institutions of the UNC system. This includes the establishment and role of SPARC and delegating policy-making authority to the Board of Governors. It also provides general criteria that must be followed in the development of sponsored programs, including the roles and responsibilities of the Office of the President, constituent institutions, and faculty and staff involved with sponsored research. 
  4. SPARC Guidelines Document #1.0 Defining Sponsored Programs ensures compliance with Federal and State laws, as well as UNC-GA regulations by providing both general and specific definitions of what is and what is not considered a sponsored program. In addition, the guideline presents clear procedures for submitting and processing externally sponsored program funds to maintain uniform administration throughout the constituent UNC institutions.  

II. UNC-Chapel Hill University-Wide Policies Related to Research Administration

In adherence to policies and regulations set by the Board of Governors and the State of North Carolina, the University has established policies and procedures tailored to the needs of faculty, staff and students at the University with regard to research. While there are many University research policies, the following form an essential foundation for conducting and administering sponsored research at the University.  

  1. Responsible Conduct of Research
    Faculty, research personnel, postdoctoral research associates and students are expected to follow the policies and procedures at the University that govern the conduct of research including the Research Ethics Resources.  
  2. UNC-Chapel Hill Policy on Classified Research

    In adherence to UNC-Chapel Hill’s longstanding commitment to academic freedom and service, the University does not usually participate in sponsored research that restricts or prevents investigators from publishing the results of their investigations. However, in rare instances, exceptions can be made only with the prior approval of the Chancellor or his designee, where certain considerations apply.  

III. Federal Regulations Related to Research Administration

The University is required to comply with Federal laws and regulations related to the administration of contracts, grants, and cooperative agreements when it receives Federal funding for sponsored research. These regulations are outlined below.  

  1. Uniform Guidance
    The Office of Management and Budget (OMB) establishes the regulations governing the management of Federally funded grants and cooperative agreements. Title 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly known as Uniform Guidance) houses these regulations.

    1. 2 CFR §200 Subpart D outlines uniform administrative requirements expected of recipient institutions covering topics such as property management, procurement, financial monitoring, and reporting, as well as other compliance issues.
    2. 2 CFR §200 Subpart E establishes cost principles applicable to expenses on Federally sponsored projects. This includes the differentiation between direct and indirect costs, allowability, and examples of selected items.
    3. 2 CFR §200 Subpart F identifies the auditing requirements for grant recipients as well as the responsibilities under the Single Audit Act Amendment of 1996.  
  2. Federal Acquisition Regulations (FAR)
    The Federal Acquisition Regulations System (FAR) establishes uniform policies and procedures for acquisitions of supplies and services by all executive agencies. The FAR is the principal document codified in Title 48 CFR Chapter 1 of the Federal Acquisition Regulations System that governs Federal contracts just as Uniform Guidance governs Federal grants and cooperative agreements.  
  3. Federal Demonstration Partnership (FDP)
    UNC-Chapel Hill is a member of Federal Demonstration Partnership (FDP), a cooperative initiative among select Federal agencies and institutions that receive Federal funds. It is an effort to reduce the layers of administrative work associated with research grants and cooperative agreements.

    1. General Terms and Conditions – General and sponsor-specific terms and conditions are established at the time the award is made and generally remain in effect for the life of that award.
    2. National Policy Requirements Matrix – A listing of statutory and regulatory requirements applicable to all FDP agencies.
    3. FDP Prior Approval and Other Requirements Matrix – A listing of prior approvals allowed by specific agencies.
    4. Subrecipient Monitoring Clearinghouse – A centralized repository for institutional information needed for Subrecipient Monitoring for all FDP entities.  
  4. Federal Register
    Published by the Office of the Federal Register, National Archives and Records Administration (NARA), the Federal Register is the official daily publication for rules, proposed rules, and notices of Federal agencies and organizations, as well as executive orders and other presidential documents.  

IV. UNC-Chapel Hill Research Compliance Components

The University is committed to performing sponsored research in accordance with all relevant ethical, legal and regulatory obligations. As an indication of its commitment and high level of accountability, UNC-Chapel Hill has structured several compliance programs to maintain effective monitoring, auditing, training, education and communication regarding compliance issues. In addition, the University Research Compliance Officer in the Research Compliance Program (RCP) oversees institutional research compliance issues. These proactive programs coordinate administrative and operational compliances by actively accessing and responding to compliance needs. Concerns related to any of the compliance components listed below can be reported anonymously through the University Compliance Line, via online submission, or by telephone (1.866.294.8688).

University programs responsible for various compliance proceedings are listed below.  

  1. Human Research Subjects Protection
    The University’s Office of Human Research Ethics (OHRE) manages the Human Subjects Protection Program, which provides assurance to the Federal government that the University upholds all ethical and regulatory requirements concerning research that involves human subjects. OHRE also supports and oversees the work of the Institutional Review Boards (IRBs).  
  2. Humane Animal Care and Use
    Three University offices work together to oversee compliance issues pertaining to animal welfare, care, and use of animals used for research. They include:

    1. Institutional Animal Care and Use Committee (IACUC) – Committee that assesses and approves animal use on campus. Responsible for adherence to Federal regulations related to humane care and use of animals.
    2. Office of Animal Care and Use (OACU) – Maintains assurance statement and accreditation for NIH OLAW approval and coordinates training and compliance of laboratory animal users.
    3. Division of Laboratory Animal Medicine (DLAM) – Responsible for the care of all vertebrate animals on campus and for providing veterinary care, technical assistance, and laboratory and pathology services for diagnostic and research purposes.  
  3. Scientific Integrity
    The entire University community is responsible for assuring that high standards of integrity and ethical behavior are practiced in all research endeavors. The University’s policy and procedures are outlined in the University Policy on Ethics in Research.  
  4. Research Sponsorship
    OSR and the Office of Clinical Trials (OCT) coordinate with IRB and Conflict of Interest Committees, University Counsel, and Auditing, to account for compliance regulations mandated from Federal granting agencies such as the National Institutes of Health (NIH), National Science Foundation (NSF), and the Food and Drug Administration (FDA).  
  5. Research Safety
    The Department of Environment, Health, and Safety (DEHS) is responsible for adhering to regulations for laboratory, chemical, and healthcare environment safety.  
  6. Conflict of Interest
    Both the (Office of University Counsel ) and campus Conflict of Interest Committees serve to ensure that research team members and their family members do not have conflicting financial interests with the research they undertake. 
  7. Health Insurance Portability and Accountability Act (HIPAA)
    Several University offices, including the Campus HIPAA Steering Committee work in unison to protect the research data that includes a person’s private Protected Health Information (PHI).  
  8. Export Control
    The Federal government’s export control regulations may prohibit the unlicensed export of specific technologies for reasons of national security or protection of trade. Such exports may require the University to obtain a license from the Department of State or the Department of Commerce before allowing foreign nationals without US citizenship or permanent resident status to participate in research. OSR works with the community to relay important information on export control as it relates to sponsored research at the University.

Last Edited: 06/16/2017