Signature and Submission Authority for Sponsored Programs

Sponsored awards, grants, and contracts are legally binding agreements. When Earlham submits funding applications to government agencies and private foundations and then accepts resulting awards, the institution must certify that it meets extensive legal and fiscal requirements and that it assumes full responsibility for the funded projects. In light of the institutional commitment that these sponsored projects represent, the following policy applies.

Only the following employees are eligible to serve as project directors (PDs) or principal investigators (PIs) for sponsored projects:

• Teaching faculty members
  • Tenure-track faculty
  • Visiting faculty whose term of appointment extends beyond the notification date for the grant
  • Newly appointed faculty who have signed their contracts and whose term of appointment extends beyond the notification date for the grant
  • Emeritus faculty
• Administrative faculty
• Full-time staff

PDs/PIs assume responsibility for conduct of funded projects, fiscal oversight of funds, completion of reports, and compliance with the sponsors’ and Earlham’s requirements. Therefore, serving as a PD/PI requires supervisor approval (the appropriate Chief Academic Officer – College or School of Religion – serves in this capacity for their teaching faculty) in advance of submission of a sponsored project.

Some sponsors have their own requirements about who may serve as a PD/PI. In such cases, individuals are eligible only if they meet the eligibility criteria of both Earlham and the sponsor.

Students may not apply for grants that would be awarded to Earlham.

In some cases, sponsors will accept only one proposal from an institution per competition. In these scenarios, the Office of Grans and Sponsored Research (OGSR) will coordinate the process for determining who can submit. As needed, the institution will stage an internal competition (e.g., requesting a draft proposal and budget to make a determination on whose proposal to put forward based on weighing proposal fit, competitiveness, and benefit to the institution). Specifics for the competition will be communicated to the PIs by OGSR.

Cost sharing is any project cost that is not reimbursed by the sponsor to support the scope of work defined by the federal or non-federal sponsored award. Cost sharing, also known as matching, is funded by Earlham or a third-party. These resources may already exist at the institution or third-party (i.e., personnel, equipment, facilities) or may need to be purchased using organizational funds. “In-kind cost share” may also be allowable and includes contributions wherein the value can be readily determined, verified, documented, and justified but where no actual cash is transacted in securing the good or service comprising the contribution.

Cost share should only be committed when required and only to the extent required by the sponsor. Cost share sources must be identified by the PI, discussed with OGSR, and internally approved as part of the review process detailed in the Institutional Approval of Applications for External Funding section. All committed cost sharing must be tracked and may require reporting.

Cost sharing expenditures must adhere to the same accounting, financial, legal, and regulatory requirements as direct cost expenditures on sponsored projects and must comply with the following:

• Federal or non-federal sponsored award terms and conditions
• Sponsor regulations including federal restrictions for procurement and airfare
• Institutional guideline, including donor restrictions

For federally-funded sponsored awards, Uniform Guidance Section 200.306 requires that “cost sharing funds are a) verifiable from the University’s records b) not included as contributions for any other federal award c) necessary and reasonable for the accomplishment of the project or program objectives d) are allowable under Subpart E Cost Principles e) not paid from another federal award and f) included in the approved budget when required by the Federal awarding agency.”

No grants or sponsored projects will be accepted without a full internal administrative review conducted by OGSR. Internal review is conducted to check that proposals conform with institutional policies and objectives and that proposed contributions of resources are appropriate and accurate.

Before external submission to the sponsoring agency, the OGSR will coordinate administrative review and secure the necessary institutional approvals. To facilitate this process, PDs/PIs must provide all documents associated with the sponsored project submission (e.g. narrative, budget justification, CV, letters of support) and details regarding the funding opportunity to the OGSR with enough time to review before the grant deadline (preferably a week prior to the deadline).

The review OGSR coordinates includes the following, as needed:

• Sponsor’s expectations – OGRS
• Full application – OGSR
• Compliance – OGSR and relevant authorities (e.g. Biosafety)
• Budget narrative & justification – Accounting Office

Additionally, OSGR will ensure that all additional required institutional approvals have been obtained based upon the specifics of the proposed project (e.g. human subjects, animal research, cost share) and will obtain the requisite approval of an Authorized Organizational Representative (AOR).

Earlham reserves the right to withdraw applications, request revisions, and/or turn down an award for proposals that did not undergo the necessary administrative review before submission.

Earlham’s Authorized Organizational Representatives (AORs) are the only individuals with the authority to commit Earlham’s time and resources to sponsored projects. The President is the only individual with the authority to commit Earlham to sponsored projects of $1,000,000 and greater. The President may opt to delegate authority to other individuals (typically the Chief Financial Officer and the Chief Academic Officers) for approving commitments below this threshold. Such delegation of authority is completed through a signed presidential letter maintained within OGSR. (Please consult the OGSR regarding Earlham’s current AORs.)

With the permission from one of the AORs, the Head of OGSR may serve as an AOR for the purposes of submitting proposals on behalf of the institution. Rather than broadly delegated, this permission is granted through approval of the individual sponsored project.

Individual faculty and staff do not have the authority to sign sponsored project agreements on behalf of Earlham, including submitting proposals or accepting grants.

In the event that an external sponsor requires a PD/PI to directly submit a proposal via email, the administrative review detailed in the Institutional Approval of Applications for External Funding section is still requisite. Upon completion of review, OGSR will communicate institutional permission to submit the approved project to the PD/PI.

As the recipient of sponsored funding from federal and non-federal sources, Earlham is required to provide accurate, timely, and complete disclosure of financial information, as required by each sponsored award. The timely recording of financial transactions to sponsored awards is critically important, especially as an award’s end date approaches, since it is the basis for financial reporting, cash collection, and sponsor closeout requirements.

It is the responsibility of the PD/PI to submit narrative and financial reports, , including cost share documentation confirming commitments were met, to OGSR for review and approval before it is sent to the sponsoring agency. OGSR will coordinate with the Accounting Office to finalize financial reports and work with additional offices to secure any required institutional approvals.

Effective management of sponsored programs requires cooperation and diligence from multiple parties. The grid below outlines the various activities and the responsible individuals where the following abbreviations apply:

• PI: Principal Investigator or Project Director
• OGSR: Office of Grants and Sponsored Research
• Acct: Accounting Office
• VP: Vice President
• AOR: Authorized Organizational Representative