This module provides researchers with the ability to complete and submit researcher and staff financial interest disclosures electronically. It allows Research Compliance Services staff to track and manage conflicts of interest, establish management plans, and fulfill our policy requirements. The module interfaces with proposals and human subjects.

How To Materials

Listed below are various self-service handouts and instructional sheets with simple instructions on how to perform various functions within the UConn Storrs/Regional Campus InfoEd External Interests module which covers Financial Interest Disclosures. PLEASE DO NOT USE THESE MATERIALS FOR UCONN HEALTH, but instead refer to the financial interests [FCOI] system page on the UConn Health OVPR website.

• Quick Reference Guide New – for UConn Storrs and Regional Campuses only
• Create an Initial Financial Interest Disclosure New for UConn Storrs and Regional Campuses only
• Edit or Resubmit a Financial Interest Disclosure New for UConn Storrs and Regional Campuses only
• View, Print, Download or Save a Financial Interest Disclosure New for UConn Storrs and Regional Campuses only
• Turning Off Pop-up Blocking on Various Web Browsers Updated

For technical issues with InfoEd, please email eRA-support@uconn.edu or call 860.486.7944.

Reason For This Procedures Document

To communicate the purpose, distribution and duration of F&A (indirect costs) revenue returns that are provided annually to the Deans, Department Heads and Principal Investigators generated from sponsored research activities.

What Is F&A?

Facilities and Administrative (F&A) costs, also known as indirect costs, are costs associated with sponsored projects that are incurred by the University that cannot be readily identified nor specifically attributed to a particular project, but which support research endeavors. Each year the Office of the Vice President for Research (OVPR) distributes a portion of the indirect costs earned on sponsored research grants and contracts to Principal Investigators (PIs), Department Heads and Deans to invest in and support research programs and initiatives that exhibit the greatest potential to bolster the University of Connecticut’s rise among the nation’s top research Universities. Please note, for non-research Sponsored Program F&A 10% is distributed to Deans.

How Is F&A Distributed?

The return of F&A generally occurs in the winter of each year and is based upon the indirect costs collected from research grants and contracts during the preceding fiscal year (July 1‑June 30).

The indirect cost distribution formula is as follows:

The department and dean allocations are distributed according to the faculty’s academic home department regardless of where the grant is managed.

If there are any administrative changes in the grant, the Vice President for Research will make the appropriate determination as to the distribution of the F&A.

F&A returns are deposited into individuals’ unrestricted research accounts (Ledger 4) in Kuali and do not currently expire:

• Once the IDC account is created, it is up to the FO / School to manage the owners, balances, activity and status.
• PI over-expenditures are the responsibility of his/her academic department.
• Departmental over-expenditures are the responsibility of their Dean.

What Is Distribution of Credit?

For grants that include a signed Distribution of Credit at the time of proposal, the proportion of indirect costs is distributed to PIs and Co-PIs, their corresponding academic home department and school/college based on the percentage of distribution listed for each faculty member.

For example:

NIH Grant, KFS# 5151510, with total F&A Costs of $20,000 for FY20xx and the Distribution of Credit (DoC) form submitted as follows:

PI/Co-PI                  Name                   DoC          Academic Home Department

PI:                           John Smith           50%           Pharmacy Practice
Co-PI:                     Sue White             25%           Math
Co-PI:                     Deb Brown           25%           Animal Science

The F&A will be distributed as follows:

PI 10%                                   Department 10%                              Dean 10%

John Smith-$1,000            Pharmacy Practice-$1,000            School of Pharmacy-$1,000
Sue White-$500                  Math-$500                                       CLAS-$500
Deb Brown-$500                Animal Science-$500                     CAHNR-$500

How Can F&A Be Used?

In order for UConn to maximize its success in meeting its research goals, distributed F&A should be used to support UConn’s research enterprise in accordance with existing University policies and procedures. Common uses of these monies include the following:

• Funding for graduate student stipends, travel and other expenses incurred by graduate students while performing research;
• Funding for postdoctoral researchers;
• Research supply/equipment purchases;
• Bridge funding;
• Cost-share, required or voluntary;
• Travel to meet with program directors, present papers, give invited talks, etc.;
• Books, journals, papers and other similar expenses related to scholarship and research;
• Project development costs such as proposal writing, proposal workshops, etc.;
• General administrative and clerical costs (including office supplies) in support of research;
• Research related recruitment costs;
• Laboratory enhancements for research purposes; and
• Faculty start-up packages for research programs.

Contact

For additional information on this procedure, please email researchfinance@uconn.edu.

Revised 10/21/2021

This document is intended to provide principal investigators (PIs) with the IRB’s expectations about their role in mentoring student researchers who conduct research with human participants. This document is meant to compliment the “Responsibilities of Research Investigators” document given to researchers with every IRB approval and re-approval letter.

The Importance of Mentorship

• Helps students work within an often unfamiliar federal regulatory environment
• Contributes to the success of a student’s research experience
• Prepares students for future research endeavors
• Fosters professional development

PI Mentorship Responsibilities

• • Consider whether you have the time to mentor the student and oversee the research study.
    • Meet with the student prior to the development of a research project to discuss basic principles of ethical research design. Develop appropriate strategies for:
      • Recruitment/retention
      • Consent process
      • Data and safety monitoring plan
      • Writing scholarly papers and reports
    • Complete/renew required CITI human subjects training.
    • Ensure that the student researcher understands and abides by the ethical principles, professional standards and codes of conduct within the research discipline.
    • Assist the student in determining whether IRB review/approval is required. Contact IRB if unsure.
    • Assist the student in preparing the protocol application, consent document, recruitment material, etc. Student researchers should not complete the entire protocol submission solely on their own. The mentor is ultimately responsible for the integrity of the research.
    • Review and proofread the completed protocol application prior to IRB submission.
    • Guide students in the work habits necessary for success (planning, record keeping, disciplined work habits, procedures to protect participants’ privacy and confidentiality, etc.).
    • Be available. Provide supervision, guidance, and oversight for entire duration of study and at intervals described in the data safety monitoring section of the IRB-1. Hold regular meetings, if possible.
    • Ensure that the student researcher obtains proper approvals from all required organizations including those that are off-site.
    • Ensure that protocol deviations and adverse events are reported to the IRB as soon as possible.
    • Ensure that the protocol is re-approved according to the time-frame set forth in the approval letter.
    • Ensure that amendments are submitted before changes are made and that changes are not implemented before the changes are approved.
    • Ensure risks are minimized for research participants AND for the student researcher
      • Based upon the PI’s experience, is the research environment safe?
      • Has the student researcher been trained in how to address problems that may arise?
      • For field settings, particularly international research, are there travel advisories that may affect safety? PI and student researchers must be aware of university polices for foreign travel/research activities. PI must be sure that students are aware of local customs and regulations. Establish a communication plan with students. Develop effective plans for data security.
    • Ensure that the student researcher abides by the ethical principles of respect for persons, beneficence and justice, as outlined in the Belmont Report.
    • Ensure that the student researcher conducts the study in accordance with the approved protocol (including approved amendments).
    • Share responsibility with the student researcher for the conduct of the research.

As PI and as a mentor you MUST…

• Be available for the student
• Be involved in the research
• Be supportive
• Be knowledgeable about research rules, regulations, and policies
• Be aware of who to contact should an issue arise

Finally, the mentor is ultimately responsible for ensuring protection of human participants.

Back to Researcher’s Guide

On December 26, 2013, the Office of Management and Budget (OMB) issued the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (also known as the “Uniform Guidance” or 2 CFR 200). The Uniform Guidance consolidates, streamlines and supersedes the eight existing OMB Circulars including Circular A-21, A-110, and A-133. Included in this new guidance are definitions, uniform administrative requirements (preaward & postaward), cost principles and audit requirements. The new guidance, which will affect all federally funded grants and contracts, will take effect on December 26, 2014.

In response to this release the University of Connecticut has set up a University-wide Uniform Guidance Task Force spanning both the Storrs and Farmington campuses. The Task Force includes representatives from central administration and various UConn departments active in research to coordinate the implementation of the Uniform Guidance. Among the Task Force’s goals is to keep the UConn community informed about the changes that will affect PIs, researchers, department administrators and others involved with sponsored projects. This webpage will provide updated information specific to Uniform Guidance implementation and will post new material once it becomes available.

Navigating the Uniform Guidance

The Uniform Guidance is broken down into the following subparts:

Part I – Objectives
Part II – Major Policy Reforms
Subpart A (200.0 – 200.99) – Acronyms and Definitions
Subpart B (100.200 – 200.113) – General Provisions
Subpart C (200.200 – 200.211) – Preaward Requirements
Subpart D (200.300 – 200.345) – Postaward Requirements
Subpart E (200.400 – 200.475) – Cost Principles
Subpart F* (200.500 – 200.521) – Audit Requirements

*Subpart F will apply to university audits beginning the fiscal year starting after the Uniform Guidance takes effect on December 26, 2014 (July 1, 2015).

Revisions to the Uniform Guidance can be found at the Federal Register Guidance for Grants and Agreements-February 22, 2021

What is UConn Doing to Implement the Uniform Guidance?

In preparation for the December 26, 2014 implementation date, UConn (all campuses) have created a subcommittee to review and catalog changes that may be required due to the new Uniform Guidance.

The group is responsible for determining the impact of the new regulations to existing policy and process, creating new training materials and revising policies where needed, and ensuring broad and effective communication strategies.

Training Materials

• PowerPoint Slides
• Implementation Guide for Principal Investigators and Department Administrators and Coverletter
• Subaward Determination Guidance
• Federal Cost Principles Training

Uniform Guidance Timeline

Resources

• Council on Financial Assistance Reform (COFAR)
  • COFAR FAQS (July 2017)
• Federal Demonstration Partnership (FDP)
  • Meeting Presentations from May 2014
  • Meeting Presentations from September 2014
• Council on Governmental Relations (COGR)
  • COGR Version 1 response to Uniform Guidance (April 24, 2014)
  • COGR Version 2 Guide to OMB Uniform Guidance (September 17, 2014)
  • COGR Implementation and Readiness Guide for the OMB Uniform Guidance (December 12, 2014)
  • COGR Implementation and Readiness Guide for the OMB Uniform Guidance (November 17, 2020)
• Federal Register
  • Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
• National Science Foundation (NSF)
  • NSF Grant General Conditions (GC-1)
  • Financial & Administrative Terms and Conditions (CA-FATC)
• National Institute of Health (NIH)
  • NIH FAQs on the Uniform Guidance and NIH Interim Grant Conditions
  • NIH Interim Grant General Conditions
• Department of Education
  • Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
  • ED FAQs
  • Dept of Ed Webcast PowerPoint
• NCURA
  • NCURA Webcast – Uniform Guidance: The Challenges of Implementation – PowerPoint

Animal Per Diem Rates

Animal per diem rates are available on the Animal Care Services website.

Proposals submitted to Sponsored Program Services must use the appropriate indirect cost rate in accordance with the most recently negotiated rate agreement and University policy.

The University’s Indirect Cost Rate Agreement, negotiated with the Department of Health and Human Services and dated 9/27/24: Indirect Cost Rate Agreement.

• Proposals submitted to Sponsored Programs Services (SPS) on or before 1/1/25 may be submitted using the former Indirect Cost Rates
• Proposals submitted to SPS after 1/1/25 must be budgeted in accordance with the new rates, using the rate effective at the beginning of each proposed budget period
• UConn’s Modified Total Direct Cost (MTDC) base has been updated to raise the threshold for inclusion of subaward dollars from $25,000 to $50,000, effective 7/1/25. As a result, the first $50,000 of the total amount of each subaward budgeted for inclusion after 7/1/25 should be included in the base when calculating indirect costs using an MTDC base.
• Current awards will continue to utilize the IDC rate in effect at the time of the initial award
• New awards may continue to use the proposed rate (if lower), if allowed by the sponsor

Federal & Corporate Rates

*Indirect costs are calculated on Modified Total Direct Cost (MTDC) which is Direct Costs minus certain exclusions. Direct Costs include salary, fringe benefits, materials and supplies, travel, and the first $50,000 of each subcontract (after 7/1/25).

Exclusions include equipment over $5,000**, rent, fellowships, tuition, participant support costs and subcontract amounts beyond the first $50,000 for each subcontract (after 7/1/25).

**In order to be consistent with State classification standards, the dollar threshold for capitalization of equipment at UConn is $5,000.

Off Campus Rate

In accordance with our current Indirect Cost Rate Agreement:

For all activities performed in facilities not owned by the institution and to which rent is directly allocated to the project(s), the off campus rate will apply. Grants or contracts will not be subject to more than one indirect cost rate.  If more than 50% of a project is performed off campus, the off campus rate will apply to the entire project.

The off campus indirect cost rate can be budgeted as follows:

• If rent is directly charged to the project.
• If more than 50% of all program activities are performed off campus.   (We request written confirmation from the PI).
• If the sponsor specifically requires the off-campus rate per the solicitation.

The on-campus rate is normally applied whenever the University leases or pays for space costs that are not direct charged to a grant or contract.

If you have questions, please contact your SPS Grants/Contracts Specialist.

Sponsor-Stated Limits

When the University collects indirect costs at less than the full federally negotiated rates,  indirect costs are charged to Total Direct Costs (including equipment, participant support costs, subcontracts, etc.,)  unless otherwise stated in the sponsor guidelines.

Funding from Connecticut State agency appropriations and local municipalities are charged a current reduced rate of 20%.  Indirect costs should be charged to Total Direct Costs.  If the Originating Sponsor is non-State, the full rate allowable by the originating/prime sponsor should be applied.

Reduction of F&A on Projects Having a Total Cost of $50k or Less

To allow for more buying power on small sponsored projects and to help foster smaller awards which may lead to additional funding, indirect costs on new awards received after October 1, 2017 with total costs of $50,000 or less, will be reduced to 20% or the difference between the full indirect cost rate and 20% will be distributed to the investigators indirect cost account.  Indirect costs are charged to Total Direct Costs (TDC) or Modified Total Direct Costs (MTDC),  as required by the specific sponsor or solicitation.

Sponsored Program Services (SPS) has developed guidance and FAQs on how this program is implemented.

Types of Cost Sharing

Typical examples of cost sharing include the percentage of personnel effort to be expended on the project; associated employee benefits; Graduate Research Assistant Tuition and un-recovered indirect costs. Costs incurred prior to the award are not allowable matches. Program income earned under an award may not count as cost sharing unless authorized by the sponsor.

Cash contributions are sources of funds from either internal or external sources.  University cost sharing is considered cash, as it can be accounted for from the University’s records. In-Kind contributions are non-cash contributions typically provided from outside sources such as donations of equipment, sub-contractors of time or facilities, or volunteer services.

The SPS Cost Share Priority Grid provides additional information about potential and allowable sources of cost share.

For more information, see the University of Connecticut’s Cost Sharing Policy.

Fringe Benefits

• The University’s fringe benefit rates are negotiated with its cognizant agency (DHHS) and are part of UConn’s Colleges and Universities Rate Agreement.
• The FY25+ (Until Amended) rate should be used for all budget periods extending beyond 7/1/2024.
• Fringe benefits will be charged at the applicable rate at the time the cost is incurred.
• Sponsored Program Fringe Benefit Rates are to be used when developing all sponsor and cost-share budgets (mandatory and voluntary).
• The following language is required in all proposal budget justifications that include fringe benefit costs using rates listed on the rate agreement:
  “The fringe benefit rates used in the proposal budget are based on the rates approved by the Department of Health and Human Services (DHHS, 9/27/2024).”

Sponsored Program Fringe Benefit Rates and Projections (%)

* Employee rate category includes Faculty, Professional and Classified Staff, and Postdoctoral Associates
**Special Payroll Examples: Summer faculty, other state agency employees, state retirees, summer graduate students

• A 5% annual increase is recommended and should be applied to personnel salary projections for future budget years for all sponsors except NIH.
• A 3% annual increase is recommended and should be applied to personnel salary projections for future budget years for NIH.
•  Graduate assistant stipends below reflect annual increases for future budget years for all sponsors for August 2022 through May 2026. A 2% annual increase should be applied thereafter.

Graduate Assistants

A full time graduate assistant devotes one-half time to studies (approximately 20 hours per week) and one half-time to graduate assistant duties. During the summer, graduate assistants are put on special payroll and can work 40 hours per week.  Refer to the Graduate School website for additional information regarding graduate assistants.  If applying for an individual fellowship or training grant from NIH, refer to the NRSA requirements for stipend, tuition, and institutional allowance.

Graduate Assistant Stipends

In accordance with the Graduate Employee Union Contract, the following stipends represent the minimum stipends for graduate assistants.  Estimates are for proposal development only^†

Graduate Assistant Stipend Level Description:

• LEVEL I – Graduate assistants with at least the baccalaureate degree.
• LEVEL II – Experienced graduate assistants in a doctoral program with at least the master’s degree or its equivalent in the field of graduate study. Equivalency consists of 30 graduate level content course credits of appropriate course work beyond the baccalaureate degree completed at the University of Connecticut, together with admission to a doctoral program.
• LEVEL III – For students with experience as graduate assistants who have at least the master’s degree or its equivalent and who have passed the doctoral general examination.

Actual Semester Dates  (The months of June, July & August should be used for budgeting purposes for the summer period)

† Please refer to the Payroll website for updated stipend information.

Post Doctoral Fellow Stipends

• Below are the current National Research Service Award (NRSA) Post Doctoral Fellow stipend levels that should be taken into consideration when preparing your proposal budget. These stipend levels must be used when applying to the NRSA for support. Stipend levels can also be found on the NIH website / NOT-OD-24-104 (effective 4/23/2024).
• Use of the stipend level which is consistent with the intended postdoctoral years of experience is recommended for use with other support sources, however, in accordance with University policy, the stipend level must at least be equal to the minimum NRSA rate.
• For more information, visit the Graduate School Post Doc Policies.

Student Labor Pay Scale

Student Labor and Work-Study are paid based on an established pay scale determined by the Office of Student Employment. The rate of pay for a position is based on the skills and level of experience required for the position, regardless of whether earnings are paid through the work-study or student labor payrolls. The pay rate is determined by the hiring supervisor and is subject to approval by the student employment staff in the Office of Student Financial Aid Services.

DHHS Salary Cap

Effective January 1, 2024, the DHHS salary limitation for Executive Level II has been increased to $221,900. For additional information, please refer to NIH Notice NOT-OD-24-057. Note this salary cap applies to all DHHS agencies.

We would love to hear from you. Please use the following links to reach the most appropriate staff persons in the Research Integrity & Compliance areas:

• Institutional Review Board (IRB)
• Institutional Animal Care and Use Committee (IACUC)
• Institutional Biosafety Committee (IBC)
• Financial Conflict of Interest (FCOI)
• Export Control
• Stem Cell Research Oversight Committee (SCRO)
• Research IT eRA Help Desk

Reporting Research Concerns

All concerns related to human research, animal research, conflict of interest, research misconduct, research financial accounting, research safety or other research compliance matters should be reported by calling Research Integrity and Compliance Services at 860-679-2230, Office of University Compliance at 860-486-2530, or the specific area.

Concerns can also be reported anonymously through the REPORTLINE by calling a toll-free number at (888) 685-2637 or via the REPORTLINE website. The REPORTLINE is available 24 hours a day, 365 days a year operated by a private (non-UConn) company. You may contact the hotline to report a concern without giving your name. You will be able to re-contact the REPORTLINE to track your report to provide further information at a later date or to obtain general updates about the status of your concern.

The University welcomes and encourages good-faith reporting. As such, individuals who submit a report or participate in a compliance investigation in good faith are provided protection from retaliation per the University’s Non-Retaliation Policy.

Additional information on reporting concerns can be found at the Office of University Compliance website.

Award Management (Post-Award)

Effort Reporting

Subawards

General Contracts Email: spscontracts@uconn.edu

Incoming Contract Contact by Assigned Academic Unit

Email and Phone: preaward@uconn.edu / 860.486.3622

• Do you have a proposal-specific issue? Please contact your SPS assigned proposal reviewer (see below for portfolio assignments) for assistance via email or Teams call, since they will be most familiar with your proposal.
• Not sure who your assigned proposal reviewer is? For this or non-urgent matters, please email preaward@uconn.edu.
• For more urgent assistance, such as when you are unsure who is reviewing or you have been unable to reach your reviewer,
  please email spshelp@uconn.edu, or call 860.486.1023. Both are actively monitored during regular business hours.

Pre-Award Contact by Assigned Academic Unit