The University of Connecticut and UConn Health are committed to the highest standards of integrity in fulfilling its mission to expand human knowledge and benefit society through research. All research activities undertaken by faculty, staff, and students at UConn will be conducted in accordance with strict ethical principles and in compliance with federal, state, and institutional regulations and policies. Research Integrity & Compliance (RIC) reports to the Vice President for Research, Innovation and Entrepreneurship. RIC is responsible for providing support and training to faculty, students and staff in order to meet these requirements and maintain a robust research compliance program at UConn Health.
RIC works with the faculty oversight committees to promote the ethical and responsible conduct of research and to ensure compliance with regulatory requirements relating to research including:
Mission
Environmental Health and Safety is a group of highly-skilled specialists dedicated to promoting a healthy and safe work environment, for the UConn Health community. We are dedicated to the health, safety and welfare of our research, medical, dental and support communities in the fields of environmental, biological, chemical and radiation safety. Our directive includes but is not limited to; fostering a safety culture, compliance alignment strategies strengthened by audits, providing comprehensive trainings in a variety of disciplines, risk reduction techniques, environmental stewardship, workplace evaluations, proper waste disposal oversite, injury and accident mitigation efforts. Environmental Health and Safety’s dedicated team of professionals is uniquely positioned to provide comprehensive EH&S services to the aforementioned, in support of UConn Health’s mission of excellence in research, teaching, service, and community outreach.
Vision
To promote and maintain a safe and healthful environment by ensuring the highest level of environmental health and safety services, achieved via departmental partnerships, leadership support and collaboration with faculty, staff, students, and visitors at UConn Health.
Goals
- EH&S develops and administers comprehensive programs and services with the goal of establishing sustainable and effective safety compliance.
- Ensuring all written guidance documents, procedures, and training materials are created and appropriately aligned to applicable regulatory standards; are current and disseminated accordingly.
- Providing high quality and efficient services in support of biological, chemical, environmental and radiological safety.
In addition to being UConn Health’s authorized representative for grants, contracts and other agreements from government agencies, private industry, and non-profit foundations and the central point of coordination for sponsored projects, Sponsored Program Services administers grants and contracts on behalf of UConn Health.
Activities include establishing new awards and budgets in the UConn Health’s accounting system (Banner) and assisting with pre-award coding requests, approving and processing re-budgets of expenditures, cost transfers, no-cost extensions and preparation of final financial reports.Awards Management also provides guidance and consultation on issues such as applicable regulations, allowable costs, cost share and match requirements as well as monitoring account activity for adherence to terms and conditions of awards and applicable policies and regulations.All grant management policies at UConn Health are derived from Federal, State and University policies and regulations such as Office of Management and Budget Uniform Grant Guidance.
The Research Subaward Agreement (RSA) is used to issue a subaward to a collaborating institution on a grant or contract. It is the responsibility of the Principal Investigator (PI) to prepare the required documents for the RSA.
During the life of the subaward, the PI monitors technical progress, compliance with all applicable laws and regulations, and reporting requirements.
The PI reviews subrecipient’s invoices before payment and submits all invoices, including the final invoice, to SPS for review and to ensure that all costs are allowable and that cost share has been met.
» Subaward/Project Agreement Request Form.
When SPS has set up a new award and consulting services are anticipated, the Department will initiate the contract request by submitting a requisition in HuskyBuy.
Submiting a requisition in HuskyBuy for consultant services.
a. If the vendor (consultant) is not available in HuskyBuy, obtain a Form W-9 from the vendor and create the new vendor request through the requisition in HuskyBuy.
b. Complete the Contract Request Form (CRF), using Account Code 78510 (Grant contract consultant) and attach to HuskyBuy requisition
Amendments and Multi-year Agreements:
For new multi-year Agreements, enter the full project period in Banner, but only enter committed funds for Year 1.
When SPS has set up a new award that has a subaward component, the Department will receive an email with the fund number. The Department will then:
1. Submit a requisition in HuskyBuy.
- If the vendor (Subrecipient) is not available in HuskyBuy, obtain a completed and signed Form W-9 from the vendor and create the new vendor through HuskyBuy.
- Proper account codes to use on the requisition
- 78501 – Grants Federal Subcontracts under $25,000
- 78502 – Grants Federal Subcontracts over $25,000
- 78503 – Grants Subcontracts with indirect costs (IDC)
- 78504 – Grants Subcontracts with no indirect copsts (IDC)
2. Attach the following documents:
- FDP Agreement Request Form
- Information and Compliance form for Subrecipients
- Subrecipient SOW, budget and budget justification
- Subrecipient Compliance approvals, if applicable
3. SPS will confirm receipt and send the Department a final draft to review before sending the Subaward Agreement out for Subrecipient signature.
Amendments
Amendments will be used to make any necessary changes to the Agreement. Amendment requests are submitted in HuskyBuy by the PI or designee. SPS will draft and send the Amendment to the Subrecipient and encumber the funds in HuskyBuy by approving the PO.
Grant-funded research collaborations usually involve issuing a Subaward to the collaborating institution. Subaward Agreements are used to issue grant funds to Subrecipients. A Consultant PSA should be used to contract for consulting services. All grant-funded Subawards are managed through SPS before they are sent to and signed by the Subrecipient. Consultant PSAs are handled through HuskyBuy by SPS and Procurement and Contracts.
Subaward versus Consultant
A recipient of a Subaward (Subrecipient) is usually an institution that collaborates with the UConn Health Principal Investigator (PI). The Subrecipient performs, and has responsibility for, part of a sponsored project. Its services are of a specialized and specific nature and cannot be performed by UConn Health. A Subrecipient is normally reimbursed for expenses in accordance with a budget. UConn Health has the responsibility to monitor Subrecipient performance.
A Consultant may be an individual or an organization. The Consultant assists the UConn Health PI. Consulting services are primarily advisory in nature and address a clearly delineated problem or provide a fee-for-service function. A Consultant is normally paid based on an hourly or daily rate or on a fixed price for deliverables.
Consultant versus Employee
A Consultant PSA should not to be used in place of hiring regular full-time, part-time, or temporary employees. Furthermore, a Consultant PSA is not appropriate for the hiring of individuals to teach classes or to perform work that has been recognized as belonging to one of the collective bargaining units within the State System. Retired members of the State Employee Retirement System cannot be placed on PSAs. Instead, they are to be placed on Special Payroll in 120-day positions. If an employer/employee relationship exists and the contractor is acting as an employee, the Department needs to contact the Department of Human Resources for information and assistance.
Assistance
Subawards and Consultant PSAs should be submitted through HuskyBuy.
- Issuance, Review and Execution of the Project Agreement: Because UConn Storrs and UConn Health are separate fiscal entities, a project agreement needs to be executed before funds can be transferred between the two campuses. After the lead organization has received its award, a project agreement is prepared by UConn Storrs SPS unit or UConn Health’s SPS unit. This agreement is emailed to the subawardee’s corresponding unit for review and execution.
Note: The project agreement must be signed by authorized signatories of both parties. Pls are not authorized to sign.
- Award/Fund Setup: Separate project funds are set up at the lead and sub’s campuses. Prior to fund set-up, all compliance-related approvals should have been obtained, e.g., Institutional Review Board (IRB)/Stem Cell Research Oversight (SCRO)/Institutional Animal Care and Use Committee (IACUC)/Institutional Biosafety Committee (IBC).
- Invoicing: Before invoices can be paid, they must be approved by the lead campus’s principal investigator.
- Amendments: Competitive project periods often span multiple budget years. If the sponsoring agency awards funds on a budget year basis, issuance and execution of amendments will be necessary to next year’s funding after it has been released to the lead organization by the sponsor.
- Carryover of Funding and No-Cost Extensions: Carryover of funds and no-cost extensions (NCE) are not authorized without the lead’s written approval. If needed, at least sixty (60) days prior to the end date of the current budget period the PI(s) should seek approval for any carryover or NCE requests.
- Award Closeout: So that awards may be closed out in accordance with sponsor requirements, final invoices will normally be required no later than 45 days following the termination date of the award project period.
For assistance with cross campus subawards,
Submitting Invoices for Payment
The Principal Investigator (PI) must approve invoices for payment. This task may not be delegated.
SPS will not approve and Accounts Payable will not issue a payment for invoices which are not signed by the PI (delegation is not permitted).
Resolving Invoice Issues
- If the PI identifies a concern with subrecipient performance, the PI will request clarification from the subrecipient PI.
- If the department grant administrators identify any unusual, apparently excessive, or potentially unallowable charges invoiced by a subrecipient and if the explanations from the subrecipient are insufficient to render a prudent judgment on the allowability of the cost, the department grant administrator shall refer the matter to SPS for resolution with the subrecipient’s institutional authorities.
- When SPS is satisfied that the issues are resolved, they will notify the department and PI to proceed with approval for payment. Invoices will not be approved for payment until all issues or concerns have been resolved.
