Office of Research and Grants (ORG)

Legal Entity Name: Lipscomb University

IRS Entity Type: Non-Profit 501(c)(3)

Organization Type: Private Institution of Higher Education

Incorporation: February 2, 1901, State of Tennessee

Director, Office of Research & Grants: Robyn Saakian

Chief Financial Officer: Jeffrey Baughn

Chief Academic Officer: Jennifer Shewmaker

Academic Finance Director: Rebecca Johns

Research Integrity Officer: TBD

Unique Entity Identifier (UEI): LUENG479WQW1

Commercial And Gov’t Entity Code: CAGE Code - 0MZ75

Employer Identification Number: 62-0485733

Dun & Bradstreet Number (D&B): 075381186

FICE Institutional Code: 003486

Human Subjects Assurance (FWA): FWA00027444

Integrated Postsecondary Ed ID: 219976

Standard Industrial Classification: 8211- College and Universities

State Representative District: District 56

State Senate District: District 21

U.S. Congressional District: Tennessee 05 (TN-005)

Misconduct in Research Filing Date: March 2022

NICRA Cognizant Federal Agency: U.S. Department of Health and Human Services

NICRA Approved Rates: 36.20% On-Campus, 27.60% Off-Campus

NICRA Rate Term: 06/01/2023 to 05/31/2027 (all programs) 

NSF Awardee/Performing Code: 0034868000

ORG utilizes and recommends Grant Forward (Lipscomb subscription-based) to find grants and research funding entities. Notify us if you have difficulty accessing this resource or have questions about conducting a grant search.

The Office of Research and Grants requires that all externally supported proposals (e.g., federal, state, corporate, or foundation funding source) be approved for submission through a process in which an institutional Routing Form is completed and signed. DocuSign® is how ORG streamlines the grant application approval workflow. The signature process is initiated by our office, and the Routing Form is distributed via email to appropriate signatories. 

Please contact us at researchandgrants@lipscomb.edu if you intend to apply for external funding in order to start the routing process at least two weeks before the application deadline. Please see the Routing Form to be prepared ahead of time regarding the questions that the Principal Investigator/Project Director will need to complete via DocuSign®. The Routing Form below is used as an example. 

Institutional Routing Forms are required to be filed:

• Prior to submission for all externally supported proposals (e.g., federal, state, corporate, or foundation funding source)
• Prior to award acceptance in cases where an award is received for which no proposal was developed and/or submitted
• For all research and programmatic grants, externally funded contracts, cooperative agreements, and subcontracts
• Prior to submission when a Letter of Intent requires a signature from an Authorized Organizational Representative (AOR) or other authorized institutional representative

When an award (general term for external funding) is received, it goes through a negotiation process through which the contract is reviewed and can be amended before signing. Usually, negotiations are only required if there are issues of non-conformance.

Once terms are reached, the award acceptance is signed by the sponsor of the award and a university official within the ORG. No faculty or staff member has the authorization to negotiate and sign. The document would be non-binding.

After the award is accepted, it is entered into our system to track and report expenses. The ORG then oversees these metrics, as well as the Principal Investigator/Project Director's management, upon which an award is contingent. 

Policy Statement

Lipscomb University (“Lipscomb”) personnel must submit all documentation for externally funded research and sponsored programs for internal approval, which is only authorized for submission upon approval by the Office of Research and Grants.

Purpose

The purpose of this policy is to establish guidelines for the preparation and approval of externally funded programs to be ultimately submitted by the Office of Research and Grants (which provides an authorized signatory agent for proposals).

Applicability

This policy is applicable to any Lipscomb full-time, exempt employee participating in an externally funded research or sponsored program administered by the Office of Research and Grants, unless an exception has been granted by the executive administration.

Definitions

Capitalized terms that are used but not otherwise defined in this policy have the following meanings:

• Principal Investigator (PI) and Project Director (PD). Lipscomb considers a PI and PD to be the individual who bears the responsibility for the overall operation and performance of the award, including management, reporting, subrecipient monitoring, record retention, compliance, effort certification, and other activities supporting program delivery and management. The term PI may be commonly seen in research grants, whereby PD is commonly used for awards which are more programmatic in nature without a dedicated research component. The term principal investigator is intended to include, by reference throughout this policy, the role of co-principal investigator.

Procedures

Routing Form. All proposals for external funding must be approved by the PI/PD’s supervisor(s) on the institution’s Routing Form prior to any review or subsequent approval by the Office of Research and Grants. No proposal may be submitted without completing the Routing Form without pre-approval by the Office of Research and Grants.

Authorization to Submit. Proposals on behalf of Lipscomb are only authorized to be submitted by the Office of Research and Grants, unless otherwise delegated.

Timeline for Submission. PI/PDs are encouraged to submit all proposal documents and the Routing Form in ample time to enable all approvers and the Office of Research and Grants to review all documentation for compliance. As a general practice, PI/PDs are encouraged to submit to the Office of Research and Grants any and all materials two (2) weeks prior to the proposal due date.  

Limited Submissions. Certain solicitations limit the number of proposals that Lipscomb may submit. Such proposals shall be coordinated through the Office of Research and Grants, whose determination shall be final.

Forms

• Proposal Routing Form (to be located electronically on the website of the Office of Research and Grants).

Contact

For additional information or questions regarding this policy, contact the Office of Research and Grants, which can be reached at 615.966.5907.

Effective Date

This policy was approved by the Office of the Provost on November 3, 2022. This policy should be reviewed, and any appropriate changes made and duly approved, on an annual basis to ensure compliance with applicable law.

Policy Statement

Lipscomb University (“Lipscomb”) provides a consistent process to establish who is eligible to participate in externally funded research and sponsored programs in the role of the Principal Investigator or Project Director (PI/PD).

Purpose

The purpose of this policy is to set forth the eligibility requirements of a PI/PD on an extramurally funded research and sponsored program at Lipscomb.

Applicability

This policy applies to all externally funded research and sponsored program.

Definitions

Capitalized terms that are used but not otherwise defined in this policy have the following meanings:

• Principal Investigator (PI) and Project Director (PD): Lipscomb considers a PI and PD to be the individual who bears the responsibility for the overall operation and performance of the award, including management, reporting, subrecipient monitoring, record retention, compliance, effort certification, and other activities supporting program delivery and management. The term PI may be commonly seen in research grants, whereby PD is commonly used for awards which are more programmatic in nature without a dedicated research component. The term principal investigator is intended to include, by reference throughout this policy, the role of co-principal investigator.

Policy

Eligibility to Serve as PI/PD
Only eligible Lipscomb faculty, staff, and appointees (when appropriate) may serve as a PI/PD on extramurally funded research and sponsored program. Eligibility includes full-time faculty, staff, and administrative members. Part time/adjunct faculty, part-time staff, visiting faculty, other part-time personnel, and affiliates (including but not limited to emeritus faculty), may only serve upon prior written approval of the Chief Research Officer.

Students, Fellows, and Trainees:
Postdoctoral fellows and trainees (postdoctoral fellows and graduate students) may be eligible to be principal investigators on fellowship and training programs when such a designation is required by the funding agency and a PI-eligible faculty or staff personnel is identified as their sponsor/mentor. Undergraduate students are not eligible to serve as a PI, but may serve as co-PI under the condition that the PI is duly eligible to serve in that capacity.

Awards to the Institution:
All extramurally funded research and sponsored programs administered on behalf of Lipscomb shall be assigned a PI/PD.

Contact

For additional information or questions regarding this policy, contact the Office of Research and Grants, which can be reached at 615.966.5907.

Effective Date

This policy was approved by the Office of the Provost on November 3, 2022. This policy should be reviewed, and any appropriate changes made and duly approved, on an annual basis to ensure compliance with applicable law.

Policy Statement

This policy provides a consistent and compliant process for the approval of participation of any person or entity in externally funded research and sponsored programs of Lipscomb University (“Lipscomb”).

Purpose

The purpose of this policy is to outline the procedure for ensuring that all participants, entities, and subawards are eligible for participation in externally funded research and sponsored programs. The procedures set forth in this policy help ensure that externally funded research and sponsored programs adhere to and comply with the highest standards, are in continual compliance with Federal rules and regulations, and are conducted consistently across all contracts and awards held or submitted by Lipscomb.

Applicability

This policy is applicable to any Lipscomb employee or student participating in an externally funded research or sponsored program, including, without limitation, participation in any grant, contract, subaward, or other externally funded contractual obligation.

Definitions

Capitalized terms that are used but not otherwise defined in this policy have the following meanings:

• CFR means the Code of Federal Regulations.
• Federal Agency or Agency, as defined in 5 U.S.C. § 551(1), generally means each authority of the Government of the United States, whether or not it is within or subject to review by another agency.
• FR means the Federal Register.

Authority

This policy is aligned with applicable Federal rules and regulations, including, without limitation, the following:

• (a) Executive Order 12549, which establishes federal regulations “… in order to curb fraud, waste, and abuse in Federal programs, increase agency accountability, and ensure consistency among agency regulations concerning debarment and suspension of participants in Federal programs.”
• (b) Executive Order 12689, which indicates that “[n]o agency shall allow a party to participate in any procurement or nonprocurement activity if any agency has debarred, suspended, or otherwise excluded (to the extent specified in the exclusion agreement) that party from participation in a procurement or nonprocurement activity.”
• (c) 2 CFR § 200.214, which states that “[n]on-federal entities and contractors are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689 … . [These regulations] restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.”
• (d) Section (H) of 2 CFR Appendix II to Part 200, which states that “[a] contract award (see 2 CFR 180.220) must not be made to parties listed on the governmentwide exclusions in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), ‘Debarment and Suspension.’ SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549.”

Procedures

Debarment and Suspension Search

Any externally funded contract award, including any subaward received from a partnering entity, issued to Lipscomb may not include or involve any person or entity engaged in the management or operation of the research or sponsored program who is federally debarred or suspended from such participation. To ensure compliance with applicable federal rules and regulations, Lipscomb will conduct a search of all such persons and entities prior to the acceptance of any such award using the publicly accessible System for Award Management (SAM) website, located at www.sam.gov.

To ensure that a consistent process is established to govern the flow of all contract mechanisms, Lipscomb’s Office of Research and Grants may also conduct debarment and suspension searches of any person or entity participating in activities funded by non-federal grants.

Confidentiality

Lipscomb’s Office of Research and Grants shall maintain the confidentiality of any results produced from a debarment and suspension search conducted through www.sam.gov. Notwithstanding the foregoing, the Office of Research and Grants may notify any entity of any federal debarment or suspensions identified in the public record and, at its discretion, may decline the related award or substitute the participation of other persons or entities that are not debarred or suspended from participating in such research or sponsored program.

Ineligibility Received During Participation

Any person or entity administering or participating in a contract award issued to Lipscomb that receives notification from a federal agency that such person or entity is considered ineligible (through debarment or suspension) while participating in such a contract award shall immediately notify Lipscomb’s Office of Research and Grants regarding their eligibility status. Such notifications shall be in writing and contain appropriate documentation from the federal agency of such status.

Contact

For additional information or questions regarding this policy, contact the Office of Research and Grants by email at researchandgrants@lipscomb.edu or by phone at 615.966.5907.

Effective Date

This policy was approved by the Office of the Provost on November 3, 2022.

Policy Statement

Lipscomb University (“Lipscomb”) monitors and documents the time and effort of faculty, staff, students, and other personnel expended on externally funded research and sponsored programs in compliance with 2 CFR § 200.430 and other regulations. Time and effort shall be documented and reported consistently in all externally funded research and sponsored programs managed through the Office of Research and Grants.

Purpose

The purpose of this policy is to promote consistency in reporting time and effort devoted to externally funded research and sponsored programs. This policy ensures that Lipscomb:

• Documents allowable salaries and benefits;
• Maximizes indirect cost recovery;
• Is positioned to meet committed matching requirements;
• Remains federally compliant and auditable;
• Upholds its reputation for being a responsible steward of funding; and
• Maintains documentation sufficient to serve as a subcontractor on federal flow-through awards issued to Lipscomb by partnering institutions.

Applicability

This policy is applicable to any Lipscomb employee or student participating in an externally funded research or sponsored program managed through the Office of Research and Grants.

Definitions

Capitalized terms that are used but not otherwise defined in this policy have the following meanings:

Budget, as defined in 2 CFR §200.1, means the financial plan for the Federal Award that the Federal Awarding Agency or pass-through entity approves during the Federal Award process or in subsequent amendments to the Federal Award. It may include the Federal and non-Federal share or only the Federal share, as determined by the Federal Awarding Agency or pass-through entity.

CFR means the Code of Federal Regulations.

Federal Agency or Agency, as defined in 5 U.S.C. § 551(1), generally means each authority of the Government of the United States, whether or not it is within or subject to review by another agency.

Federal Award, as defined in 2 CFR §200.1, has the following meaning, depending on the context:

• (i) The Federal financial assistance that Lipscomb receives directly from a Federal Awarding Agency or indirectly from a pass-through entity, as described in 2 CFR §200.101; or (ii) the cost-reimbursement contract under the Federal Acquisition Regulations that a non-Federal entity receives directly from a Federal
• The instrument setting forth the terms and conditions. The instrument is the grant agreement, cooperative agreement, other agreement for assistance covered in paragraph (2) of the definition of Federal financial assistance in 2 CFR §200.1, or the cost-reimbursement contract awarded under the Federal Acquisition Regulations (48 CFR §52.204-17). Federal Award does not include other contracts that a Federal Agency uses to buy goods or services from a contractor or a contract to operate Federal Government owned, contractor operated facilities. See also the definitions of Federal financial assistance, grant agreement, and cooperative agreement in 2 CFR §200.1.

Federal Awarding Agency, as defined in 2 CFR §200.1, means the Federal Agency that provides a Federal Award directly to a non-Federal entity.

Principal Investigator, or PI, and Project Director, or PD, mean the individuals who bear the responsibility for the overall operation and performance of the externally funded research or sponsored program, including management, reporting, subrecipient monitoring, record retention, compliance, effort certification, and other activities supporting program delivery and management. PI is commonly used in research grants, whereas PD is commonly used for awards that are more programmatic in nature without a dedicated research component. As used in this policy, Principal Investigator includes the role of co-Principal Investigator.

U.S.C. means the United States Code.

Procedures

Authorizing Individuals: The PI or PD shall serve as the individual authorized to certify the time and effort of all individuals working on any externally funded research or sponsored program, including themselves, regardless of whether such individuals receive compensation for such time and effort. In all cases, the PI or PD certifying time and effort reporting must have first-hand knowledge of the participation of all individuals for whom the PI or PD is certifying. All completed Time and Effort Reporting Forms must be forwarded to the Director of the Office of Research and Grants to ensure compliance with federal and other requirements.

Frequency: All Lipscomb time and effort reporting is completed on an after-the-fact basis, including the completion or compilation of any and all appropriate supporting documentation for all externally funded research or sponsored programs at least on a quarterly basis (as aligned with applicable funding requirements).

Delegation Approval: The PI or PD may temporarily delegate, with approval of the Office of Research and Grants through consultation of the applicable department, the authority to certify the time and effort of all individuals working on an externally funded research or sponsored program to another individual who has sufficient knowledge of the project activities and a reliable means of verifying work performed. Delegation of such certification may be approved on a case-by-case basis, such as extended absence of the PI or PD because of lengthy travel, sabbatical, or other circumstances where the PI or PD has limited access to verify accuracy, or severe illness. The duration of the delegated authority shall be determined and approved by the Office of Research and Grants to ensure compliance with 2 CFR § 200.308, which requires prior approval from a Federal Awarding Agency for a Budget or program revision in the event that the PI or PD should, for any
reason, become disengaged from the project for more than three (3) months or a 25 percent reduction in time devoted to the project.

Archival: The PI or PD shall forward all verified and certified Time and Effort Reporting Forms to the Office of Research and Grants, who shall in turn ensure that documentation is retained appropriately and provided to authorized individuals and auditors.

Conflict: This policy is subject to applicable law. In the event of a conflict between the provisions of this policy and applicable law, including, without limitation, 2 CFR §200, the provisions of applicable law shall control.

Form(s)

Time and Effort Reporting Form

This document is aligned with 2 CFR 200.430(i) and is to be completed on an after-the-fact basis for all funding sources and for all externally funded projects administered by the Office of Research and Grants (ORG). This form must be submitted to ORG at least on a quarterly basis, or as otherwise directed by ORG and signed by the individual or delegate with first-hand knowledge of the performance and distribution of effort presented. Please complete the below fields and email this form, with appropriate supporting documentation, directly to researchandgrants@lipscomb.edu. Charges for salaries and wages (including those authorized for cost sharing) must reasonably reflect all activities for which the employee is compensated by Lipscomb University, not exceeding 100% of compensated activities. In accordance with FLSA requirements (29 CFR part 516), charges for nonexempt employees must include the total number of hours worked daily.

Contact

For additional information or questions regarding this policy, contact the Office of Research and Grants by email at researchandgrants@lipscomb.edu or by phone at 615.966.5907.

Effective Date

This policy was approved by the Office of the Provost on November 3, 2022.

Policy Statement

This policy outlines the conditions and limitations in which certain personnel of Lipscomb University (“Lipscomb”) may receive Extra Compensation as a result of participation in externally funded research or sponsored programs at Lipscomb.

Purpose

The purpose of this policy is to apply federal regulations governing the issuance of any Extra Compensation to Lipscomb personnel in the performance of externally funded research and sponsored programs, recognizing that service above and beyond the normal scope of an employee’s assigned duties and job functions may be required.

Applicability

This policy is applicable to any Lipscomb employee participating in an externally funded research or sponsored program administered by the Office of Research and Grants, unless an exception has been granted by the executive administration.

Definitions

Capitalized terms that are used but not otherwise defined in this policy have the following meanings:

CFR means the Code of Federal Regulations.

Extra Compensation means any compensation or extra service payment issued by Lipscomb that is in addition to the recipient’s IBS for services performed outside of the recipient’s principal
appointment (including services for research or programmatic projects). Extra Compensation shall not include compensation or reimbursement received for jury duty or court attendance pursuant to a subpoena, nor is it inclusive of any compensation received for any non-Lipscomb affiliated arrangement. Compensation included within an individual’s IBS may include, without limitation, appointments to roles such as director or department chair, if such a role is defined within an appointment letter or employment contract.

Institutional Base Salary or IBS, as defined in 2 CFR § 200.430(h)(2), means the annual compensation paid by Lipscomb for an individual’s appointment, whether that individual’s time is spent on research, instruction, administration, or other activities. IBS excludes any income that an individual earns outside of duties performed for Lipscomb.

Principal Investigator, or PI, and Project Director, or PD, mean the individuals who bear the responsibility for the overall operation and performance of the externally funded research or sponsored program, including management, reporting, subrecipient monitoring, record retention, compliance, effort certification, and other activities supporting program delivery and management. PI is commonly used in research grants, whereas PD is commonly used for awards that are more programmatic in nature without a dedicated research component. As used in this policy, Principal Investigator includes the role of co-Principal Investigator.

Procedures

Method of Compensation 

The preferred method of compensating any Lipscomb personnel who provide services for an externally funded research or sponsored program is through release time or course buy-out. If release time is not available or not favorable for a particular award, and personnel are eligible to receive Extra Compensation as set forth in this policy and applicable federal regulations (including, but not limited to, 2 CFR §200.430(h)), Extra Compensation may generally be approved under the following conditions:

• Extra Compensation is clearly indicated in the awarded budget, or Lipscomb has received prior written approval by the awarding agency; and
• Extra Compensation is approved by the employee’s supervisor and the Office of Research and Grants.

Extra Compensation

To ensure consistency across all awards, the Office of Research and Grants shall apply the appropriate federal regulations, including, but not limited to, 2 CFR §200.430(h), with respect to the issuance of Extra Compensation to eligible exempt faculty and staff.

Exempt faculty and staff may not earn or receive any Extra Compensation exceeding 25% of their IBS as remuneration for effort expended in connection with an externally funded research or
sponsored program, unless an exception has been approved by the Provost of Lipscomb, in consultation with the Office of Research and Grants.

Non-exempt employees may generally not receive Extra Compensation. Written requests for Extra Compensation for Lipscomb non-exempt employees must be approved in advance by the Office of Research and Grants, the Office of Human Resources, the employee’s supervisor, and the funding agency or organization. Any approved Extra Compensation for non-exempt employees must comply with the applicable requirements of the Fair Labor Standards Act.

Conflict

This policy is subject to applicable law. In the event of a conflict between the provisions of this policy and applicable law, including, without limitation, 2 CFR § 200.430, the provisions of applicable law shall control.

Forms

• Proposal Routing Form (available at the Office of Research and Grants)

Contact

For additional information or questions regarding this policy, contact the Office of Research and Grants by email at researchandgrants@lipscomb.edu or by phone at 615.966.5907.

Effective Date

This policy was approved by the Office of the Provost on November 3, 2022. This policy should be reviewed, and any appropriate changes made and duly approved, on an annual basis to ensure compliance with applicable law.

Policy Statement

This policy outlines the conditions and limitations for cost sharing in externally funded research or sponsored programs at Lipscomb University (“Lipscomb”).

Purpose

The purpose of this policy is to establish consistent guidelines for cost sharing in externally funded research or sponsored programs of Lipscomb.

Applicability

This policy is applicable to any Lipscomb employee or student participating in any externally funded research or sponsored program of Lipscomb.

Definitions

Capitalized terms that are used but not otherwise defined in this policy have the following meanings:

CFR means the Code of Federal Regulations.

Cost Sharing or Matching, as defined in 2 CFR § 200.1, means the portion of Project Costs not paid by Federal funds or contributions (unless otherwise authorized by Federal statute).

Project Cost, as defined in 2 CFR § 200.1, means total allowable costs incurred under a Federal award and all required cost sharing and Voluntary Committed Cost Sharing, including third-party contributions.

Unrecovered Indirect Costs, as defined in 2 CFR § 200.306(c), means the difference between the amount charged to the Federal award and the amount which could have been charged to the Federal award under the non-Federal entity’s approved negotiated indirect cost rate.

U.S.C. means the United States Code.

Voluntary Committed Cost Sharing, as defined in 2 CFR § 200.1, means cost sharing specifically pledged on a voluntary basis in the proposal’s budget on the part of the non-Federal entity and that becomes a binding requirement of Federal award.

Procedures

Voluntary Cost Sharing: Lipscomb does not encourage voluntary Cost Sharing or Matching contributions committed toward any externally funded research or sponsored program on behalf of Lipscomb, regardless of whether the cost is committed by Lipscomb or a third party. Voluntary commitments made toward such a program may have the effect of:

• Reducing Lipscomb’s capacity to provide such commitments at a later time or when required by another federally funded program;
• Negatively impacting Lipscomb’s indirect cost rate calculation;
• Requiring additional human capital to maintain financial data to support audits;
• Requiring fair market value valuations, institutional base salary calculations, and other rates, as required; and/or
• Being non-compliant with the regulations of the funding entity, especially for those organizations that generally prohibit Cost Sharing or Matching.

Mandatory (or Statutory) Cost Sharing: Mandatory Cost Sharing or Matching are those commitments that are required by the funding agency as a condition of receiving an award, and are generally subject to audit. Such commitments are documented by the Office of Research and Grants to support future audits, and such commitments must be approved in advance in writing (through the applicable Routing Form) by the applicable department chair and academic dean.

Recovered Indirect Costs: Indirect costs may not be voluntarily committed as a Cost Sharing or Matching without prior approval from the Office of Research and Grants. Indirect cost calculations are based on a percentage of actual expenditures, which involves both variability and risk in commitment level. In addition, indirect costs are applied by Lipscomb to support the research enterprise and may not be committed on behalf of Lipscomb by a principal investigator or project director for a specific cause or purpose.

Unrecovered Indirect Costs: Unrecovered indirect costs may only be committed at the discretion of the Office of Research and Grants, as prior approval of the funding agency is required in accordance with 2 CFR § 200.306(c)). Should a funding agency (federal, state or private) approve the utilization of unrecovered indirect costs toward a statutory matching requirement, the Office of Research and Grants will retain a written copy of the funding agency’s approval for any future audit.

Conflict: This policy is subject to applicable law. In the event of a conflict between the provisions of this policy and applicable law, including, without limitation, 2 CFR § 200, the provisions of applicable law shall control.

Forms

• Routing Form (available at the Office of Research and Grants)

Contact

For additional information or questions regarding this policy, contact the Office of Research and Grants by email at researchandgrants@lipscomb.edu or by phone at 615.966.5907.

Effective Date

This policy was approved by the Office of the Provost on November 3, 2022.

Policy Statement

This policy establishes the methodology for applying Indirect Costs with respect to externally funded research or sponsored programs at Lipscomb University (“Lipscomb”).

Purpose

The purpose of this policy is to:

• Establish guidelines and procedures governing the inclusion of Indirect Costs, using Lipscomb’s Negotiated Indirect Cost Rate Agreement (as allowable), within proposals and contracts related to externally funded research or sponsored programs; and
• Establish Lipscomb’s incentive policy for the distribution of recovered Indirect Costs.

Applicability

This policy is applicable to any Lipscomb full-time employee participating in an externally funded research or sponsored program administered by the Office of Research and Grants.

Definitions

Capitalized terms that are used but not otherwise defined in this policy have the following meanings:

Budget, as defined in 2 CFR §200.1, means the financial plan for the Federal Award that the Federal Awarding Agency or pass-through entity approves during the Federal Award process or in subsequent amendments to the Federal Award. It may include the Federal and non-Federal share or only the Federal share, as determined by the Federal Awarding Agency or pass-through entity.

CFR means the Code of Federal Regulations.

Cognizant Agency for Indirect Costs, as defined in 2 CFR § 200.1, means the Federal Agency responsible for reviewing, negotiating, and approving cost allocation plans or Indirect Cost proposals on behalf of all Federal Agencies. The Cognizant Agency for Indirect Costs is not necessarily the same as the cognizant agency for audit, as defined in 2 CFR § 200.1. For assignments of cognizant agencies for institutions of higher education, see Section C.11 of Appendix III to 2 CFR Part 200.

Cost Sharing or Matching, as defined in 2 CFR § 200.1, means the portion of Project Costs not paid by Federal funds or contributions (unless otherwise authorized by Federal statute).

Federal Agency or Agency, as defined in 5 U.S.C. § 551(1), generally means each authority of the Government of the United States, whether or not it is within or subject to review by another agency.

Federal Award, as defined in 2 CFR §200.1, has the following meaning, depending on the context:
            (1)(i) The Federal financial assistance that Lipscomb receives directly from a Federal Awarding Agency or indirectly from a pass-through entity, as described in 2 CFR §200.101; or (ii) the cost-reimbursement contract under the Federal Acquisition Regulations that a non-Federal entity receives directly from a Federal Awarding Agency or indirectly from a pass-through entity, as described in 2 CFR §200.101.
            (2) The instrument setting forth the terms and conditions. The instrument is the grant agreement, cooperative agreement, other agreement for assistance covered in paragraph (2) of the definition of Federal financial assistance in 2 CFR §200.1, or the cost-reimbursement contract awarded under the Federal Acquisition Regulations (48 CFR §52.204-17). Federal Award does not include other contracts that a Federal Agency uses to buy goods or services from a contractor or a contract to operate Federal Government owned, contractor operated facilities. See also the definitions of Federal financial assistance, grant agreement, and cooperative agreement in 2 CFR §200.1.

Federal Awarding Agency, as defined in 2 CFR §200.1, means the Federal Agency that provides a Federal Award directly to a non-Federal entity.

Indirect Costs, as defined in 2 CFR § 200.1, means those costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefited, without effort disproportionate to the results achieved. To facilitate equitable distribution of indirect expenses to the cost objectives served, it may be necessary to establish a number of pools of indirect (facilities & administrative) costs. Indirect (facilities & administrative) cost pools must be distributed to benefitted cost objectives on bases that will produce an equitable result in consideration of relative benefits derived. Indirect Costs are further identified in 2 CFR § 200.414.

Principal Investigator means the individual who bears the responsibility for the overall operation and performance of the externally funded research or sponsored program, including management, reporting, subrecipient monitoring, record retention, compliance, effort certification, and other activities supporting program delivery and management. As used in this policy, Principal Investigator includes the role of co-Principal Investigator.

Project Cost, as defined in 2 CFR § 200.1, means total allowable costs incurred under a Federal Award and all required cost sharing and Voluntary Committed Cost Sharing, including third-party contributions.

Unrecovered Indirect Cost, as defined in 2 CFR § 200.306(c), means the difference between the amount charged to the Federal Award and the amount which could have been charged to the Federal Award under the non-Federal entity’s approved negotiated Indirect Cost rate.

Voluntary Committed Cost Sharing, as defined in 2 CFR § 200.1, means Cost Sharing specifically pledged on a voluntary basis in the proposal’s Budget on the part of the non-Federal entity and that becomes a binding requirement of Federal Award.

Procedures

Inclusion of Indirect Costs within Grant and Contract Budgets: The Indirect Cost rate (as identified in Lipscomb’s Rate Agreement from the U.S. Department of Health and Human Services, the Cognizant Agency for Indirect Costs) shall be consistently applied across all externally funded research and sponsored programs at Lipscomb, unless such a rate is unallowable or must otherwise be reduced by the funding Agency with a modification approved by the Office of Research and Grants.

Grants or contracts for any externally funded research or sponsored program at Lipscomb may not be subject to more than one Indirect Cost rate. Lipscomb has been assigned separate Indirect Cost rates for projects performed on- or off-campus. The off-campus rate shall be used only for those activities performed in facilities not owned by Lipscomb and for which rent is directly allocated to the project(s). If more than 50% of the time and effort of all individuals working on any externally funded research or sponsored program is performed off-campus, the off-campus rate will apply to the entire project. Working remotely from home shall not be considered off-campus activities. The final Indirect Cost rate applied by the Office of Research and Grants shall constitute the rate used for both submission and award management of all externally funded research or sponsored programs.

Indirect Costs shall not be voluntarily applied as a Cost Sharing or Matching unless required by the funding Agency, is in the best interest of Lipscomb, applies unrecoverable Indirect Costs prior to any other commitments (as allowable), and is pre-approved for use by the Office of Research and Grants under the administration of the Chief Research Officer.

Incentive Policy for the Distribution of Recovered Indirect Costs: Indirect Costs will be recovered according to the regulations set forth in 2 CFR Part 200 or the written policies or procedures of the funding Agency. The federal government does not provide directives to institutions of higher education regarding how recovered Indirect Costs must be disbursed, spent, or otherwise applied. Therefore, after all other costs or expenses related to any externally funded research or sponsored program at Lipscomb have been paid, Lipscomb will distribute recovered Indirect Costs as follows, unless the Office of Research and Grants directs otherwise:

• 75% to the Office of Research and Grants, which may be used at the discretion of the Office of Research and Grants to support salaries, ongoing research administration, incentives, or other costs as deemed appropriate. Any such amount distributed to the Office of Research that exceeds the annual budget of the Office of Research and Grants shall be used at the discretion of the Provost;

• 12.5% to the Principal Investigator, which will be placed into a dedicated institutional account for use in future research and related activities. Funds in these accounts may roll over from one fiscal year to the next and may accumulate. Principal Investigators may choose to use these funds for activities that may include, without limitation, traveling to a conference, hiring a graduate research assistant, and/or purchasing a subscription to an academic software solution or journal. In situations where any externally funded research or sponsored program was managed by one or more co-Principal Investigators, a distribution, agreed upon in writing by all such investigators in accordance with the level of contribution provided to the project, shall determine the allocation to each investigator. While utilizing these funds, Principal Investigators must comply with all applicable policies and procedures of Lipscomb, including without limitation, the Travel, Entertainment, and Expense Reporting Policy. If all Principal Investigators for an externally funded research or sponsored program cease to be employed by Lipscomb for any reason, any funds remaining in the corresponding dedicated institutional account will be placed in a dedicated institutional account to support the appropriate academic college(s), as determined by the Office of Research and Grants; and

• 12.5% to the academic college, which will be placed into a dedicated institutional account to be used at the discretion of the dean to support ongoing college, institute, department, or unit level research activities. Funds in these accounts may roll from one fiscal year to the next and may accumulate. Appropriate expenditures may include, without limitation, upgrading computer or research equipment, providing compensation to personnel to support proposal development, matching future grant proposals (when and if allowable by the funding Agency), and/or supporting faculty or staff whose compensation is not currently funded by any externally funded research or sponsored program to engage in research activities or collaborative efforts that could create opportunities to obtain future funding.

This incentive program is limited to the distribution of applicable recovered Indirect Costs not previously approved as Cost Sharing or Matching within awarded proposals or grants. Unrecovered Indirect Costs shall not be included in any distribution pursuant to this incentive policy.

Institutional Responsibilities: Post-award grant accounting personnel will be responsible for (i) approving the awarded budget (to ensure that charges were properly calculated with institutional rates), and (ii) preparing the distribution report at the end of each fiscal year (or other applicable period, as may be required), after affected Indirect Costs have been recovered (generally up to 45 days). The report shall be provided to the Office of Research and Grants and the Provost for pre-approval of disbursement. The Office of Research and Grants shall approve the disbursements, which shall be administered by the post-award grant accounting personnel.

Conflict:This policy is subject to applicable law. In the event of a conflict between the provisions of this policy and applicable law, including, without limitation, 2 CFR § 200, the provisions of applicable law shall control.

Related Documents/Policies

• Travel, Entertainment, and Expense Reporting Policy, available on myLipscomb

Contact

For additional information or questions regarding this policy, contact the Office of Research and Grants by email at researchandgrants@lipscomb.edu or by phone at 615-966-5907.

Effective Date

This policy was approved by the Office of the Provost on April 5, 2023.

Policy Statement

Lipscomb University (“Lipscomb”) requires that all faculty, students, postdoctoral fellows, and investigators participating in any externally funded research or sponsored program successfully complete responsible conduct of research (“RCR”) training if the Federal Awarding Agency makes RCR training a term or condition of the award. In addition, Lipscomb’s Office of Research and Grants (“ORG”) or Lipscomb’s Institutional Review Board (“IRB”) may direct any other individuals participating in any externally funded research or sponsor program to complete RCR training. Lipscomb encourages and welcomes all members of the Lipscomb research community to participate in RCR training.

Purpose

The purpose of this policy is to promote research ethics and integrity at Lipscomb through RCR training.

Applicability

This policy is applicable to any Lipscomb employee or student participating in an externally funded research or sponsored program administered by the Office of Research and Grants.

Definitions

Capitalized terms that are used but not otherwise defined in this policy have the following meanings:

• CFR means the Code of Federal Regulations.
• Collaborative Institutional Training Initiative (CITI or CITI Program) is the virtual training provider currently utilized by Lipscomb to provide training in research, research conduct, and compliance.
• Federal Agency or Agency, as defined in 5 U.S.C. §551(1) and further clarified in 5 U.S.C. §552(f), generally means each authority of the Government of the United States, whether or not it is within or subject to review by another agency.
• Federal Award, as defined in 2 CFR §200.1, has the following meaning, depending on the context:
  • (1)(i) The Federal financial assistance that Lipscomb receives directly from a Federal Awarding Agency or indirectly from a pass-through entity, as described in 2 CFR §200.101; or (ii) the cost-reimbursement contract under the Federal Acquisition Regulations that a non-Federal entity receives directly from a Federal Awarding Agency or indirectly from a pass-through entity, as described in 2 CFR §200.101.
  • (2) The instrument setting forth the terms and conditions. The instrument is the grant agreement, cooperative agreement, other agreement for assistance covered in paragraph (2) of the definition of Federal financial assistance in 2 CFR §200.1, or the cost-reimbursement contract awarded under the Federal Acquisition Regulations (48 CFR §52.204-17). Federal Award does not include other contracts that a Federal Agency uses to buy goods or services from a contractor or a contract to operate Federal Government owned, contractor operated facilities. See also the definitions of Federal financial assistance, grant agreement, and cooperative agreement
    in 2 CFR §200.1.
• Federal Awarding Agency, as defined in 2 CFR §200.1, means the Federal Agency that provides a Federal Award directly to a non-Federal entity.
• Institutional RCR Coordinator means the individual appointed by Lipscomb to provide or coordinate compliant RCR and ethics training opportunities that support the research enterprise.
• Principal Investigator, or PI, and Project Director, or PD, mean the individuals who bear the responsibility for the overall operation and performance of the externally funded research or sponsored program, including management, reporting, subrecipient monitoring, record retention, compliance, effort certification, and other activities supporting program delivery and management. PI is commonly used in research grants, whereas PD is commonly used for awards that are more programmatic in nature without a dedicated research component. As used in this policy, Principal Investigator includes the role of co-Principal Investigator. As used in this policy, Principal Investigator includes the role of co-Principal Investigator.
• Responsible Conduct of Research (“RCR”), as used by the National Institutes of Health (“NIH”), promotes the aims of scientific inquiry, fosters a research environment that enables scientists to work together toward common goals, and promotes public confidence in scientific knowledge and progress for the public good.

Procedures

Lipscomb requires that all faculty, students, postdoctoral fellows, and investigators participating in any externally funded research or sponsored program successfully complete RCR training if the Federal Awarding Agency makes RCR training a term or condition of the award. In addition, the ORG or IRB may direct any other individuals participating in any externally funded research or sponsor program to complete RCR training. Lipscomb encourages and welcomes all members of the Lipscomb research community to participate in RCR training.

COMPLIANCE
Federal Awarding Agencies have statutory requirements as to which individuals participating in externally funded research or sponsored programs need to complete RCR training. Lipscomb’s compliance with this training requirement is tracked by the ORG and IRB. Federal Awarding Agencies requiring completion of virtual or face-to-face RCR training include, but are not limited to, the NIH, the National Science Foundation (“NSF”), and the U.S. Department of Agriculture’s National Institute of Food and Agriculture (“NIFA”). Compliance is also required for direct federal flow-through awards as well as subawards received by partnering institutions and organizations.

NON-COMPLIANCE
Non-compliance with RCR training requirements may result in any of a number of consequences, including, but not limited to, disallowance of salary and any associated expenses charged to the externally funded research or sponsored project, removal of the PI from the project, the appointment of a replacement PI, removal from research support roles for a sponsored project, loss of eligibility to apply for future grants, termination of assistantships, or referral for academic disciplinary action.

VIRTUAL TRAINING
Lipscomb provides training courses through the CITI Program available at www.citiprogram.org. On the CITI Program website, click on “My Courses” and “Log In” if you already have an account, or “Register” an account in the system if you do not have an account. Select “Lipscomb University” as the Organization Affiliation. Enroll in the course entitled “Responsible Conduct of Research (RCR).”

IN-PERSON OR FACE-TO-FACE TRAINING
Lipscomb also provides a minimum of eight hours of in-person RCR training, which is required by the NIH for selected awards. The in-person RCR training must be completed within the first year of the appointment to the project or before the applicable person graduates or otherwise leaves Lipscomb, even if that imposes a shorter deadline. Upon completion of RCR training requirements, a certificate of completion will be issued by ORG to document that the requirements of the externally funded research or sponsored program have been met. It is the responsibility of the individual receiving the certification to provide appropriate copies to the IRB and/or the PI.

RESPONSIBILITIES
Lipscomb’s Institutional RCR Coordinator, who serves in the ORG, shall:

• Develop, deliver, and/or coordinate ORG-led, face-to-face, online/virtual, and hybrid trainings for the campus community in compliance with the applicable requirements of a Federal Awarding Agency (e.g., NIH, NSF, or NIFA);
• Take attendance and issue Certificates of Participation or Certificates of Completion to attendees;
• Retain appropriate documentation for all RCR training sessions in accordance with 2 CFR § 200.334, which may include slideshows, attendance, surveys, guest speakers, handouts, presentation dates/times/durations, and other relevant information; and
• Provide appropriate documentation to applicable Federal Awarding Agencies upon request, reporting, and/or audit purposes.

The ORG shall:

• Ensure that PIs of awards requiring RCR as a term or condition of the award are informed of the requirement and can communicate that requirement to appropriate senior personnel, faculty, staff, students, and others;
• Ensure that an annual RCR training calendar of in-person events is available to the campus community on Lipscomb’s website;
• Complete federal or sponsoring agency certifications, approved by the Authorized Organizational Representative, attesting that Lipscomb has or will provide an appropriate RCR training plan at the time of funding and will communicate all such requirements to the Institutional RCR Coordinator to ensure continuity of programming (if such an attestation is required at the time of submission or award acceptance);
• Provide RCR training plans to the Federal Awarding Agency (and auditors) upon request; and
• Retain all certificates for at least three years after completion, in compliance with 2 CFR § 200.334.

CONFLICT
This policy is subject to applicable law. In the event of any conflict between the provisions of this policy and applicable law, including, without limitation, Section 7009 of the America COMPETES Act, the provisions of applicable law shall control.

Contact

For additional information or questions regarding this policy, contact the Office of Research and Grants, which can be reached at 615-966-5907.

Effective Date

This policy was approved by the Office of the Provost on May 12, 2023.

Policy Statement

Lipscomb University (“Lipscomb”) requires that all faculty, staff, and students engaged in research involving Human Subjects successfully complete training appropriate to the type of research and activities being conducted.

Purpose

The purpose of this policy is to ensure that all researchers, whether or not such research is externally funded, have obtained appropriate regulatory and ethical training prior to the conduct of research or the performance of any research activities involving Human Subjects.

Applicability

This policy applies to any Lipscomb employee or student engaged in Human Subjects Research, whether or not the research or activities are performed on- or off-campus (including virtually).

Definitions

Capitalized terms that are used but not otherwise defined in this policy have the following meanings:

• CFR means the Code of Federal Regulations.
• Collaborative Institutional Training Initiative (CITI or CITI Program) is the virtual training provider currently utilized by Lipscomb to provide training in research, research conduct, and compliance.
• Human Subject, as defined in 45 CFR § 46.102(e)(1), means a living individual about whom an investigator (whether professional or student) conducting research: (i) obtains information or biospecimens through intervention or interaction with the individual, and uses, studies, or analyzes the information or biospecimens; or (ii) obtains, uses, studies, analyzes, or generates identifiable private information or identifiable biospecimens.
• IRB means the Lipscomb Institutional Review Board, which is the committee that performs ethical review of proposed research involving Human Subjects.
• Human Subjects Research involves a wide variety of research procedures, including, but not limited to, the collection of Human Subject data through survey mechanisms; direct or indirect observations; interventions; standardized tests from the fields of education, psychology or human performance; investigational drugs or devices; randomized clinical trials; research utilizing medical records; and/or research using existing pathological specimens, discarded tissue, or secretions.
• Research, as defined in 45 CFR § 46.102(l), means a systematic investigation, including research development, testing, and evaluation, designed to develop or contribute to generalizable knowledge. Activities that meet this definition constitute research for purposes of this policy, whether or not they are conducted or supported under a program that is considered research for other purposes. For example, some demonstration and service programs may include research activities. For purposes of this policy, the following activities are deemed not to be research:
  1. (1) Scholarly and journalistic activities (e.g., oral history, journalism, biography, literary criticism, legal research, and historical scholarship), including the collection and use of information, that focus directly on the specific individuals about whom the information is collected.
  2. (2) Public health surveillance activities, including the collection and testing of information or biospecimens, conducted, supported, requested, ordered, required, or authorized by a public health authority. Such activities are limited to those necessary to allow a public health authority to identify, monitor, assess, or investigate potential public health signals, onsets of disease outbreaks, or conditions of public health importance (including trends, signals, risk factors, patterns in diseases, or increases in injuries from using consumer products). Such activities include those associated with providing timely situational awareness and priority setting during the course of an event or crisis that threatens public health (including natural or man-made disasters).
  3. (3) Collection and analysis of information, biospecimens, or records by or for a criminal justice agency for activities authorized by law or court order solely for criminal justice or criminal investigative purposes.
  4. (4) Authorized operational activities (as determined by each agency) in support of iintelligence, homeland security, defense, or other national security missions.

Procedures

HUMAN SUBJECTS RESEARCH TRAINING
Human Subjects Research training courses are available at www.citiprogram.org. On the CITI Program website, click on “My Courses” and “Log In” if you already have an account, or “Register” an account in the system if you do not have an account. Select “Lipscomb University” as the Organization Affiliation.

Lipscomb provides the campus community with three CITI training courses in Human Subjects Research. Researchers (and faculty advisors, as appropriate) must earn a CITI Certificate of Completion in one course that is most closely aligned to the type of Research being conducted. The three available Human Subjects Research courses are as follows:

Option 1: Social-Behavioral-Education (“SBE”) Human Subjects Research
Researchers shall take this course if the proposed Research focuses only on social, behavioral, or educational subjects and DOES NOT involve Research of physical health, mental health, biomedical topics, blood draws, investigational drugs or devices; randomized clinical trials; Research on medical records; or Research using existing pathological specimens, discarded tissue, or secretions.

Option 2: Health Sciences, Biomedical, or Pharmaceutical Human Subjects Research
Researchers shall take this course if the Research involves physical health, mental health, biomedical topics, blood draws, investigational drugs or devices; randomized clinical trials; Research on medical records; or Research using existing pathological specimens, discarded tissue, or secretions.

Option 3: Interdisciplinary-SBE and Health Sciences+
Researchers shall take this course if the Research focuses upon a combination of social, behavioral, or education subjects and involves physical health, mental health, biomedical topics, blood draws, investigational drugs or devices; randomized clinical trials; Research on medical records; or Research using existing pathological specimens, discarded tissue, or secretions. The Interdisciplinary-SBE and Health Sciences+ course should be taken if there is doubt regarding the applicability of the other courses.

REQUIRED AND SUPPLEMENTAL MODULES
Each training course contains both required and supplemental training modules. All required modules must be successfully completed. Furthermore, researchers must take any and all supplemental modules directly related to the Research or activity(ies) being performed. Failing to take appropriate supplemental modules may cause significant delays to the IRB review process. Supplemental modules may include, but are not limited to:

• Prisoners (ID: 8 or ID: 506)
• Children (ID: 9 or ID: 507)
• Pregnant women, fetuses, and neonates (ID: 10)
• International research (ID: 14081 or ID: 509 or ID: 971)
• Public elementary and secondary schools (ID: 805)
• Internet research (ID: 510)
• Non-English speakers (ID: 17260)
• Gender and sexuality diversity (ID: 16556)
• Undocumented status (ID: 16656)
• Critically ill (ID: 16592)
• Decisionally impaired (ID: 16610)
• Older adults (ID: 16502)
• Socially or economically disadvantaged (ID: 16539)
• Physical disabilities and impairments (ID: 16657)
• Students in research (ID: 1321)
• Workers and employees (ID: 483)
• Public health (ID: 17637, 17638, 17639, 17640)

In addition, a CITI Certificate of Completion may be required for one or more of the following courses, as specified for the applicable type of Research:

Supplemental Course:
Information Privacy and Security
This course is required if a Research study includes data from medical records or other health-related information.z

Supplemental Course:
Good Clinical Practice Social/Behavioral Research Best Practices for Clinical Research
This course is required for any individual engaged in Research regulated by the U.S. Food and Drug Administration. This type of Research typically involves drug, device, or biologic agents or products. This course is recommended for any beginning researcher learning the steps involved in high-quality Research and participant safety, and may also be included in Research methodology courses.z

Supplemental Course:
Responsible Conduct of Research (“RCR”)
Completion of this course does not meet requirements for Human Subjects Research; however, completion of a Human Subjects Research course and RCR may be required in certain externally funded Research and sponsored programs. The Office of Research and Grants will notify all researchers if this course is required as a condition of any award.z

Supplemental Course and In-Person Training:
RCR plus Eight Hours of Face-to-Face Training
Virtual and face-to-face training is required for certain categories of Research funded by the National Institutes of Health, and potentially other funding agencies. The Office of Research and Grants will notify all researchers if this course is required as a condition of any award.

CONFLICT
This policy is subject to applicable law. In the event of a conflict between the provisions of this policy and applicable law, including, without limitation, 45 CFR § 46, the provisions of applicable law shall control.

Contact

For additional information or questions regarding this policy, contact the Office of Research and Grants, which can be reached at 615-966-5907.

Effective Date

This policy was approved by the Office of the Provost on May 12, 2023.