The Office of Research and Sponsored Programs (ORSP) serves as the University's central administrative unit responsible for securing external resources through grants and contracts and providing financial and contractual stewardship of awards.ORSP provides dynamic and proactive services to cultivate and maximize external resources for relevant research, scholarly and creative pursuits.ORSP provides guidance and support to the University community in an environment that fosters the creative process and the enrichment of students and teaching, while ensuring protection of the University's financial, contractual, and regulatory obligations as well as accountability to external funding sources.

Purpose of the Office of Research and Sponsored Programs

The Office of Research and Sponsored Programs (ORSP) is designated as both the advocate and the administrative oversight office for all externally funded contracts and grants related to the research, training, and public service activities within the University. ORSP provides proposal and funding advice and assistance, award negotiations, post-award administration, accounting services, and financial administration for faculty interested in grants and contracts. Through the programs which it administers, ORSP contributes to professional development of faculty, enhances the educational experiences of students, and facilitates the University's efforts to address critical concerns of the community and region.

Objectives of the Office of Research and Sponsored Programs

Ensure University community understanding and knowledge of ORSP services and how external funding can assist them in achieving individual and institutional goals.

Ensure ORSP knowledge of University programs and faculty interest which can benefit from use of external contract and grant funding.

Provide effective management of the ORSP Trust Fund to assure required cash flow, meet statutory and legal requirements, and enhance future development of research and training activities at the University.

Provide services which facilitate and expand access to external funding by the University and enhance our success in acquiring such resources.

Ensure that the terms and conditions of grants and contracts are met and that productive working relations are maintained with sponsoring agencies.

Provide timely and highly accurate fund management and accounting services for contract and grant funds.

Support and assist faculty and staff to effectively carry out the activities supported by grants and contracts within the complex milieu of sponsor rules and requirements and university, state, and federal regulations.

Ensure continued growth in the capacity of ORSP staff and other University personnel to work effectively to achieve our mission through use of grant and contract resources.

Contribute to ensuring a university environment which is supportive of research and scholarship and service to the larger community.

Values of the Office of Research and Sponsored Programs

In the conduct of its daily activity, ORSP incorporates: a learning approach to ensure effectiveness within a dynamic working environment; a commitment to excellence and professionalism in its delivery of services; and assurance of integrity in carrying out its responsibilities within a supportive and collaborative working environment.

Establishment of the Office of Research and Sponsored Programs

Florida Statutes 1004.22 provide for the establishment of a Office of Research and Sponsored Programs at any University in the State University System. In 1975, the Board of Trustees, with the concurrence of the Board of Education, established the Office of Research and Sponsored Programs at the University of North Florida.

The Role of the Office of Research and Sponsored Programs

The primary mission of a university is to provide a forum for the growth and exchange of ideas. Since ideas develop in the minds of people, communication between scholars and between faculty and students is the first basic function of a university. But without ideas to communicate, teaching can be an exercise in futility. Therefore, the second basic function of a university must be research, characterized by the spirit of free inquiry and the exploration and synthesis of ideas. These two objectives of the university are complementary. A superior educational experience can be provided to students most effectively through dual experience of exposure to both vigorous teaching and equally stimulating research. Extramural resources acquired through ORSP, can facilitate both teaching and research, as well as the application of ideas through public service.

The implementation of sponsored activities is greatly facilitated by a centralized administrative unit supporting project personnel in both pre- and post-award negotiations and procedures. Project managers are more efficiently kept abreast of new agency requirements, changes in contractual and grant regulations, fiscal procedures and reporting requirements, etc. A research and sponsored programs unit exercises influence in keeping duplication to a minimum and provides significant help in upgrading proposal quality through consultation with proposal authors and the application of the principles of grantsmanship. Not the least contribution of such a unit is its ability to lessen the problems encountered by faculty when they become immersed in the clerical, budgetary, and other administrative requirements of producing and managing contract and grant proposals and awards. The establishment of ORSP at the University ensures effective support for project managers and personnel as well as adequate supervision of the University's responsibilities in managing funds received.

Organization of the Office of Research and Sponsored Programs

ORSP is a component of the Office of Academic Affairs. Research and training implemented through ORSP and supported by monies administrated through the permanent ORSP Trust Fund will be initiated, conducted, and supervised by the faculty of the University. Wherever possible, the utilization of supporting services for Sponsored Programs and training will be through the usual University organization with as little duplication of effort as possible. ORSP is the unit responsible for giving leadership to the planning, organization and administration of the University's grant and contract activities. ORSP is a self-supported unit which pays for its operation through recovered Facilities and Administrative costs realized from contracts or grants received by the University.

Operation of the Office of Research and Sponsored Programs

ORSP is an integral part of the University. Its operating policies and procedures conform to those established by the University, the Board of Trustees, and state statutes.

General Administration of the Office of Research and Sponsored Programs

ORSP functions under the authority of the President through the Office of the Provost and Vice President of Research with day-to-day management by the Director of the Office.

The President of the University appoints a Director of ORSP who is the administrative head of the office.

The President is authorized to develop any additional policies and procedures they deem necessary for the proper conduct of ORSP, provided they are not in conflict with the law. Copies of additional policies and procedures implemented are furnished to the University Board of Trustees.

ORSP maintains appropriate records and related security measures.

ORSP prepares budget recommendations, including applicable personnel positions and rates, and manage the permanent ORSP Trust Fund.

An annual report of the operations and activities of ORSP is prepared and presented by the President to the University Board of Trustees.

ORSP provides continual review of the administrative operation of the office to insure that it is providing adequate service to the University.

Operating Expense of the Office of Research and Sponsored Programs

Operating expenses of ORSP are paid from the permanent ORSP Trust Fund. These expenses include salaries, other personnel services, supplies and expenses, operating capital outlay, and other costs associated with on-going operations and/or special projects or programs which contribute to the continued growth of extramural resources.

Impact of Grants and Contracts on Education

Assessment of the impact of research and training contracts, grants, and gifts on the educational program of the University and the welfare of the State is a shared responsibility of the faculty initiating the proposal, the appropriate department, and ORSP.

The Principal Investigator (PI) determines with the department chair and academic dean: (a) a schedule of duties and release time, if any, that provides adequate time to pursue the proposed sponsored program; (b) compatibility of the proposed program with the interests and objectives of the department; and (c) assurances that the facilities of the department are adequate for performance of the proposed sponsored training or research.

The PI also provides copies of the proposed project to their Academic Dean for review for conformance to college objectives and programs. The concurrence of the Academic Dean is required. Proposals are further reviewed by the Director of ORSP to determine if the project is compatible with the role and scope of the University and that the contract or grant is basically sound and in accord with applicable regulations.

Functions of the Office of Research and Sponsored Programs

ORSP provides advice and assistance to faculty and staff in preparing and submitting proposals requesting funds for research and other sponsored programs. There are four (4) major areas of responsibility and activity through which this is accomplished.

1. Liaison ORSP is the University unit through which local, state, and federal government and other prospective funding agencies and organizations channel their requests for assistance utilizing grants and contracts. In addition, it is the agent through which faculty coordinate their efforts in the development of research and other sponsored programs. ORSP assists faculty in making contracts with government and private foundation officials; works to stimulate the interests of these agencies in appropriate University programs; and, provides a clearinghouse for information on faculty interests and University capabilities.

2. Information Services Through established contacts with governmental agencies, private foundations, professional associations, and special periodicals, ORSP maintains a resource collection of current information about funding sources. Information about sources of program support both public and private proposal guidelines, new programs, and funding trends is shared with faculty, staff, administrators, and other persons affiliated with the University or requesting assistance from the University. ORSP supports access to Internet and other databases and sources providing online information on funding sources.

3. Proposal Preparation and Submission In most instances faculty members initiate proposals for specific program interests that require outside funding. The initial faculty interest, along with the department and college support, is important to successful proposal development. In order to facilitate the preparation of the proposals, ORSP:

Assists faculty members in identifying specific funding sources;

Provides appropriate guidelines and other program information;

Reviews proposals for completeness and format;

Assists with actual proposal document preparation and submission;

Assists with budget preparation, including coordination of institutional cost sharing, required space, faculty release time and other commitments;

Coordinates university review procedures, required assurances and certifications, and transmittal to funding source;

Determines whether human subjects and animal care protection compliance are necessary and assists in developing adequate procedures;

Coordinates conferences and sponsored credit activities with Division of Continuing Education;

Monitors the status of pending proposals;

Attempts to expedite their review and approval;

Negotiates the legal and technical components of research grants and contracts or other agreements on behalf of the institution; and

Provides general assistance to the University in the planning and development stages of new programs and facilities whenever outside funding is a consideration.

4. Award Administration Once a grant or contract is awarded to the University, ORSP maintains and coordinates review procedures necessary to insure compliance with applicable University, State of Florida, and grantor policies and guidelines; provides general administrative services to the PI, including the establishment of accounts and records, general coordination of other fiscal procedures, and general institutional support of the program; provides academic and other administrative units with appropriate reports and current status of all sponsored programs and funded research activities; monitors the compliance with both federal and state regulations; conducts all contract negotiations, including revisions, on behalf of the University; and monitors expenditures to assure compliance with University and funding agency policies.

5. Regulatory Compliance ORSP is responsible for the administration and facilitation of regulatory compliance efforts associated with research activities at the University. This is accomplished through the coordination and monitoring activities of the Institutional Review Board for the Protection of Human Subjects (IRB) and the Institutional Animal Care and Use Committee (IACUC) as well as tracking and oversight of various compliance issues by ORSP staff. ORSP provides administrative assistance to the IRB and IACUC members. Additionally, ORSP is responsible for the University's program for education of faculty, staff, and students regarding compliance regulations and responsibilities of human subjects, animal care, and related issues.

Services provided by the Office of Research and Sponsored Programs

ORSP is staffed by a team of professionals who provide the following services:

Proposal Development and Award Processing

Sponsor identification
Proposal development
Networking and team building
Proposal preparation
Proposal submission and tracking
Proposal approval and contract negotiation
Input, maintenance and reporting of information related to grant/contract submission, award and performance
Management report development and analyses

Fiscal and Program Management

Contract negotiation and modification
Project management assistance
Preparation and submission of project amendments
Preparation and monitoring of subcontracts
Approval of payments to subcontractors
Monitoring of compliance with federal/state regulations and funding guidelines

Grants Accounting Services

Internal accounts and budgets establishment within the University's accounting system

Invoice preparation to funding agencies

Fiscal report preparation to funding sources, the Florida Board of Governors and various state and federal agencies

Regulatory Compliance

Administration and facilitation of compliance associated with research activities at the University

Administrative support to IRB and IACUC

Education of faculty, staff, and students regarding compliance issues

Maintenance of a training certification database

Monitoring of intellectual property issues related to contracts and grants

Coordination of copyright and patent application procedures

Tracking University compliance with various regulatory requirements (such as drug-free workplace, radiation safety, nondiscrimination, etc.)

SECTION II: PROPOSAL DEVELOPMENT AND AWARD PROCESSING

The Office of Research and Sponsored Programs (ORSP) is the unit at the University of North Florida (UNF) responsible for planning, organizing, and administering the University's grant and contract activities. When a faculty or staff member is interested in submitting a proposal for external funding, they should contact ORSP to receive proposal preparation assistance, to ensure their proposal is in compliance with agency and University policies, and to secure University approvals prior to submission.

ORSP assists University faculty and staff interested in pursuing external funding for research and training projects in the proposal development process by:

Identifying funding sources;
Obtaining funding agency applications and guidelines;
Reviewing proposals for adherence to University and agency guidelines and clarifying proposal requirements;
Assisting in the preparation of proposals to include: reviewing proposals for consistency with the funding announcement as well as providing feedback on proposal language, editing assistance, providing standard wording regarding the University and its policies and procedures, and assisting with standard application forms;
Developing proposal budgets in accordance with University and agency policies by providing data regarding salaries, fringe benefits, facilities and administrative costs, etc.;
Initiating the internal approval process by preparing the internal approval forms;
Preparing the proposal package for submission to the funding agency in compliance with the agency's requirements, making copies, and forwarding to the funding agency.

SOLICITATION OF CONTRACTS AND GRANTS

The Director of ORSP or other authorized persons may solicit research and training support, but all requests for support through contracts and grants must conform to the University policy and must have the approval of the Director of ORSP and other appropriate University officials prior to submission.

Funding Sources and Agency Guidelines

ORSP maintains current data and information on the availability of support for potential sponsored projects and the application packages and guidelines for applying for funding from granting agencies and organizations. ORSP distributes funding announcements to faculty and staff either electronically via e-mail or in printed format. ORSP maintains copies of Requests for Proposals (RFPs), proposal forms, annual reports and other information from federal and state agencies, and private foundations and corporations to aid proposal preparation. ORSP houses a library including proposal writing handbooks and grant management handbooks, along with copies of federal, state, and university regulations.

Solicitation of Funding Resources

ORSP maintains subscriptions to several online and print catalogs of funding resources. ORSP performs individualized searches for University faculty and staff for area- or interest-specific funding sources upon request. Faculty and staff can also receive regular funding announcements via e-mail based on key interests.

PROPOSAL DEVELOPMENT

Proposal Documents

ORSP staff members are available to play an active role in development of proposal documents. ORSP reviews proposals and makes comments and suggestions for improvements, provides editing assistance, furnishes information regarding the University for inclusion in proposals, forges collaborative relationships with other faculty on and off campus, and develops proposal budgets. Should a faculty or staff member desire assistance with the document preparation or development of the budget, staff in ORSP must be notified in sufficient time, usually three (3) weeks in advance of the mail due date, in order to make arrangements to provide the assistance requested.

Proposal Budgets

ORSP assists in the development of or, at a minimum, reviews and approves all project proposal budgets prior to submission and acceptance. ORSP provides assistance during the proposal preparation process by helping investigators draft a budget using appropriate calculations for salaries, fringe benefits rates, state travel and equipment rates, and Facilities and Administration (F&A) (indirect cost) rates. ORSP must review all proposal budgets for compliance with funding agency, state and University policies. The review pays particular attention to salaries and fringe benefits, F&A (indirect) costs, cost-sharing requirements, purchase of equipment, and the reasonableness and adequacy of proposed expenses as they relate to the proposal narrative.

Facilities and Administrative (Indirect) Costs

ORSP recoups the general costs incurred by the University in the course of conducting sponsored programs by charging F&A costs to grant and contract projects. These are real costs of supporting grants and contracts and thus are included in proposal budgets for external funding.

F&A costs, formally known as indirect costs, are defined by the U.S. Office of Management and Budget (OMB) Circular A-21, Cost Principles for Educational Institutions, as costs "that are incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular sponsored project, an instructional activity, or any other institutional activity."

F&A cost rates for the University are calculated using the federal cost principles detailed in OMB Circular A-21. The proposed rates are audited by the federal government and negotiated by the University Controller with the government's representative at the Department of Health and Human Services, the University's federal cognizant agency. The calculation results in an F&A rate that is applied to a base calculation.

Commitment of Cost Sharing

UNF is willing to consider cost sharing based upon review of the project. Cost sharing is the portion of the grant or contract cost not borne by the sponsor. Whenever cost sharing is explicitly set forth and committed in a proposal and an award is made based on that proposal or cost sharing is required as a condition of an award, the cost sharing must be documented in the University's records and included in the grant file.

Sources of Cost Sharing

It is the Principal Investigator's (PI's) responsibility to secure cost sharing from University chairs, deans, department heads, vice presidents and/or from external sources. Common forms of cost sharing include salary related to faculty and staff effort, matching funds for equipment, or cash or in-kind contributions form external sources. When cost sharing is required and if allowable by the funding agency, the University may contribute the difference between the F&A rate allowed by the agency and its federally negotiated F&A rate, if the agency rate is less, as in-kind cost sharing to the project. When cost sharing is required, and if allowed by the funding agency, the University may calculate the F&A costs on its cash cost-sharing portion of the project and contribute them as in-kind cost sharing.

Cost Sharing Guidelines

All cost sharing resources must meet the following criteria as outlined in OMB Circular A-110:

They must be verifiable from the contributor's accounting records.
They may not be included as contributions for any other federally assisted project or program in either the current or any prior period.
They must be necessary and reasonable for proper and efficient accomplishment of project or program objectives.
They must be allowable under the applicable cost principles (OMB Circular A-21). This is true even if the asset is derived from a third party contribution. Therefore, a matching contribution must be for something for which the organization or institution could have spent federal funds.
They may not consist of federal funds. Funds from one federal program may not be used to match or cost share with another.
They must be provided for in the approved project budget.

PROPOSAL SUBMISSION

Proposal Review

ORSP functions as a central clearinghouse for all outgoing proposals and all incoming grants and contracts. Only those proposals conforming to the University's role and scope and which promote teaching, research, and public service of the highest caliber are transmitted to prospective granting agencies and organizations. Further, University research must be conducted only for purposes that are consistent with the University's principal missions of preservation, pursuit, dissemination, and application of knowledge.

Approvals

All proposals submitted to external agencies involving sponsored programs and training activities must be reviewed by ORSP and approved by the Director of ORSP before they are submitted to the funding agency. The President has delegated his authority under Florida Statutes 1004.22 to negotiate, enter into, and execute research contracts; to solicit and accept research grants and donationsto the Director of ORSP.

Collaborations and Cooperative Applications

The University encourages faculty and staff to collaborate with their colleagues at other institutions. The requirements that apply to internal review of proposals submitted solely by the University also apply to collaborative activities. Internal review is also required when the University is a proposed subcontractor or participant on a proposal submitted through another institution.

Internal Approval Process

Before a proposal may be submitted or a contract executed, a Request for Proposal Approval and Submission or Contract/Award Acceptance Internal Routing Form must be completed and routed for signature. The Principal Investigator (PI) assumes primary responsibility for its completion. Required approvals, indicated by signature and secured in sequence, must be denoted on the form before certification and submission of the proposal by ORSP. This form outlines personnel assignments, resource commitments, as well as regulatory compliance and other issues related to the proposal.

Investigators interested in pursuing external funding for a particular project should begin the internal approval process as soon as possible to allow adequate time for review by all individuals involved. Prior to initiation of the internal routing form, all proposals must be reviewed by the Assistant Director for Pre-Award Services in ORSP who has the responsibility of reviewing proposals for compliance with University and agency guidelines.

Compliance Certifications

In addition to its function as the documentation of university approval of a proposal, the Request for Proposal Approval and Submission or Contract/Award Acceptance Internal Routing Form also documents certification of proposal compliance with various regulations. By signing this document, the PI(s), Chairpersons, Deans, and other administrators certify that the proposal is in compliance with the following internal and external guidelines listed on the document which may include but are not limited to (1) conflict of interest, (2) protection of human subjects/IRB review, (3) animal care and use/IACUC review, (4) biosafety, and
(5) radiation safety.

Space Requirements

The Request for Proposal Approval and Submission or Contract/Award Acceptance Internal Routing Form certifies that adequate space is available for the project prior should it be awarded.

AWARD NEGOTIATION

Negotiations and Execution of Sponsored Research and Training Contracts and Grants

ORSP negotiates the terms and conditions of applicable grants and contracts with granting agencies and organizations. Negotiations of sponsored contracts and grants may be conducted between the agency and ORSP staff and the PI at the University. The Director of ORSP is ultimately responsible for university negotiations in all matters affecting the substance of the project to be conducted and associated fiscal matters with the approval of the PI who, in turn, must have departmental and college concurrence.

Legal Aspects of Contracts and Grants

All potential proposed contracts and grants are examined for appropriateness and legal compliance prior to their execution. Any prospective contract or grant that would unduly obligate the University in any way or which has questionable aspects will be referred to the University Legal Counsel for review, revision, approval, or further referral if necessary.

Grant Acceptance

The President "is authorized to negotiate, enter into, and execute research contracts; to solicit

And accept research grants and donations(Florida Statutes 1004.22). The President has delegated this authority to the Director of ORSP.

AWARD PROCESSING

Notification of Award

ORSP has the responsibility of reviewing award documents and conditions of award. ORSP staff make recommendations for acceptance to the Director, secure appropriate additional acceptance signatures if required, set up meetings with the PI and their chair and/or dean if it is deemed advisable, and notify other appropriate ORSP staff that the award has been received so that files might be created, a new account established, and other tasks necessary to implement a new award can be completed.

Award Notification Packet

When an award is received by the University, the award letter must be forwarded to ORSP for processing. ORSP reviews the award conditions and establishes an account for the project in the University's accounting system. [Further information about account establishment is discussed in the following section, Account Establishment.] When the account has been established, ORSP forwards an Award Notification Packet to the PI. An award notification packet, at a minimum, includes: an announcement of the grant award to campus officials (including News and Publications); a Notification of Account Number form; and special instructions applicable to individual awards (such as cost sharing instructions) if necessary.

Guidance for New Investigators and Support Staff

The Assistant Director for Post-Award Services meets with all new PIs to explain the policies and procedures related to the administration of grants and contracts at the University; the responsibilities of the PI and of ORSP in the administration of grants and contracts; the assistance that ORSP provides to the PI in the administration of grants and contracts; and any restrictions and regulations related to a specific grant or contract. It may also be necessary for project support staff to meet with ORSP staff to review procedures for processing travel, hiring personnel, purchasing items for the project, etc.

SECTION III: ACCOUNT ESTABLISHMENT AND RECORDS

Once a grant or contract award has been received and approved, the Office of Research and Sponsored Programs (ORSP) establishes an account to maintain and administer the awarded funds based on the terms of the award document and to ensure compliance with all applicable statutes, regulations, and guidelines. Accounts are maintained in accordance with generally accepted accounting principles and cost accounting standards.

GRANT AND CONTRACT PROJECT ACCOUNTS

Funding received from grants and contracts makes up the majority of funds managed through the ORSP Trust Fund.

Types of Funding

1. Funding from grant awards

2. Funding from research and training contracts and agreements

Sources of Funding

1. Federal (direct and flow-through)

2. State

3. Local government

4. Private

Account Establishment and Administration

Once an award document has been received from a sponsor and approved by the University, ORSP establishes an account in an appropriate numeric sequence as determined by the source of funding. ORSP reviews the proposal and/or award or contacts the Principal Investigator (PI) to determine the appropriate budget categories to input a budget in the University's accounting system.

Authorization and Expenditure of Funds

For grants and contracts, in addition to all general state and federal regulations, the authorization and expenditure of funds is determined by the source of funding. These guidelines are generally found in the grant or contract award or other documentation provided by the funding source, such as sponsoring agency policy manuals. PIs are responsible for reviewing applicable guidelines for their particular grant or contract award and ensuring that all expenses are directly related to and necessary for the successful completion of the project. ORSP provides assistance, as requested, to PIs in interpretation and application of all pertinent guidelines.

Allowable Expenditures

Approved categories of expenditures and allocation of funds for each category are determined by the grant or contract award. For expenditures that are not specifically authorized in the award document, the PI must contact ORSP for determination of expenditure allowability or to initiate necessary modifications to the existing award.

Costs must meet the following criteria in order to be charged to the account:

1. Expenditures must be allocable to the project.The cost must have a direct benefit and be directly attributable to the project or activity being performed.

2. Expenditures must be allowable according to university and sponsor policies.

3. Expenditures must be reasonable and necessary for the performance of the project.

4. Expenditures must be charged in accordance with the sponsor's regulations.

5. Transfers of costs from one budget period to the next solely to cover cost overruns generally are not allowable.

PRELIMINARY ACCOUNTS

When the University has received notification that a grant or contract award will be made but an official award document has not been received, an account can be established which authorizes up to ninety (90) days of expenditures prior to the effective date of the award if pre-award costs are allowed by the sponsoring agency.

Types of Funding

1. Funds from grants and contracts for which the University expects receive an award within ninety (90) days of account establishment from sponsors that allow expenditure of funds prior to award

2. Funds from University accounts provided as backup if an award is not received

Account Establishment and Administration

The PI must submit a Preliminary Account Request form to ORSP to initiate establishment of a preliminary account. This form must include the account number that will cover the expenditures incurred against that account if an award is not received. The account is available for ninety (90) days prior to the official award date. Once an official award is received, the account is modified to account for the entire award.

Authorization and Expenditure of Funds

For preliminary accounts, in addition to all general state and federal regulations, the authorization and expenditure of funds is determined by the source of funding of the expected award. These guidelines are generally found in the grant or contract award or other documentation provided by the funding source, such as sponsoring agency policy manuals. PIs are responsible for reviewing applicable guidelines for their particular grant or contract award and ensuring that all expenses are directly related to and necessary for the successful completion of the project. ORSP provides assistance, as requested, to PIs in interpretation and application of all pertinent guidelines.

Allowable Expenditures

All pre-award costs must meet the following criteria in order to be charged to the account:

1. Expenditures must be allocable to the project.The cost must have a direct benefit and be directly attributable to the project or activity being performed.

2. Expenditures must be allowable according to university and sponsor policies.

3. Expenditures must be reasonable and necessary for the performance of the project.

4. Expenditures must be charged in accordance with the sponsor's regulations (including the certification of effort) and the authorized pre-award budget (as requested in the form).