Part 200 of the Code of Federal Regulations (CFR) includes guidance to Federal Agencies on how to administer grants, contracts, and cooperative agreements. This is known as the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, or Uniform Guidance. BSOS has created a version of the Uniform Guidance based on the electronic CFR (eCFR) which can be accessed here. This includes highlights of relevant and or commonly referenced clauses.
Roles and Responsibilities
Research administration at the University involves many moving parts from many offices and departments across campus. In concert with representatives from most of these offices, ORA developed a matrix outlining roles and responsibilities for various tasks and approvals required throughout the life-cycle of an award. This matrix is hosted on ORA's website and should be consulted when a PI or research administrator is determining what office or individual to work with on a specific issue.
What is allowable?
The most important factors to consider when determining allowability is relevance to the scope of work and benefit to the project and sponsor. A sponsored project should not be charged for a cost that is not directly related to the scope of work in the approved proposal, or that does not benefit the work conducted under that scope of work.
For specific items of cost, consider the order of precedence of sponsored projects to determine what is allowable and what is not:
- Scope of Work
- Award document
- Agency Terms and Conditions
- Federal Guidelines (Uniform Guidance, Federal Acquisition Regulations, Public Laws)
Some other questions to consider regarding allowability:
- Is this cost normally covered by the department or the institutional F&A rate? (aka consistent treatment)
- Is the item necessary for the completion of the scope of work?
As an agency of the State of Maryland, we are additionally bound to State of Maryland laws, and institutional policies.
For more on consistent treatment of costs, see the attached memo on the Consistent Application of Salary Costs to Sponsored Projects.
Research Computing Resources
There are a variety of research computing resources available to investigators and students, including experts who will help determine the needs and how to fill them. More information can be found on the research computing resources page.
Intellectual Property (IP) Policy Waivers
The University of Maryland Intellectual Property (IP) Policy outlines the ownership and protection of IP created by personnel and students at the University. Occasionally in the course of research, sponsors, particularly Foundation or other non-Federal agencies, include terms or conditions in their award notices that include language which does not match UM's IP Policy. In these cases, the Office of Research Administration (ORA) works with the sponsor to negotiate mutually agreeable terms, preferably that reflect the UM IP policy. If the sponsor cannot accept UM's IP policy terms, the investigator and research team may be asked to waive some of their IP rights in order to accept the award.
When negotiations on IP language come to an impasse but the investigator and research team still wish to pursue the award, ORA will initiate an IP Policy Waiver ("IP waiver") which then must be reviewed by the research team, Chair, and Dean before proceeding to review by UM Ventures (formerly Office of Technology Commercialization) and final determination by the Vice President for Research (VPR). Waivers should be carefully considered before acceptance and signing, particularly when there are graduate students working on the research project.
The BSOS Dean's Office requires the following documents prior to signing an IP waiver:
- IP waiver document (initiated by ORA)
- Note: when describing the type of IP expected (question 2 on the form) use plain language anticipating a non-scientific audience
- Additional signature pages for affected parties (if necessary)
- Language from the sponsored agreement (relevant language quoted or the entirety of the agreement)
- Communications with ORA regarding why the waiver is necessary (optional but preferred)
This documentation should be sent to Rebecca Hunsaker (hunsaker [at] umd [dot] edu) with a copy to Stephanie Scribner (sfscrib [at] umd [dot] edu) who will review the request before presenting it to the Associate Dean of Research for signature. IP waiver packages should not be sent directly to the Dean or Associate Dean.