Rules and Regs

Article excerpt

To compete in the university research arena, one must know the rules of the game.

A university research agreement is fundamentally a work contract between a sponsor and a university. The researcher is the resident expert that the university identifies to carry out the proposed work. By submitting formal proposals, a researcher agrees to abide by the policies and procedures of the university and its sponsor. This means that a researcher must understand rules and regulations that affect university research. Conducting sponsored research with commercial entities usually involves institutionally driven and controlled terms and conditions. However, the major portion of university research is federally sponsored, and so is directly subject to federal regulations governing the conduct and financial accountability of the research. Many federal regulations "flow down" and are applicable to a researcher's project when the university is a subcontractor to a nonfederal entity that has a federally sponsored contract.

Relevant regulations take many forms. Following is a list of some types, with descriptions of important regulations in each category.

1. Administrative Regulations

The Office of Management and Budget (OMB) publishes regulations that specifically address university research, including: OMB Circular A-21, "Cost Principles for Educational Institutions." This defines allowable costs for project agreements made between the federal government and educational institutions. In addition to describing permissible budgetary items, it tells when written justifications for expenditures are required. Its infamous Section F.6.b specifies the circumstances under which researchers can charge secretarial time, supplies, and other administrative support to a project.

OMB Circular A-110, "Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Learning" Federal sponsors may not impose requirements in addition to or inconsistent with those delineated in this circular. Section C.23 is especially important because it provides definitions and criteria for allowable cost-sharing or matching.

OMB Cost Accounting Standards (CAS). In May 1996, four of these regulations became applicable to educational institutions, and two of these directly apply to researchers. …