Office of Sponsored Projects (OSP)

Projects funded by external sources must adhere to both HPU's policies and guidelines as well as those set forth by the sponsors. In case of any conflicts between the two, the agreement/contract governing the parties' relationship should specify which institution's policies and procedures take precedence. If the agreement/contract is silent on this matter, the general rule is to follow the strictest requirements. However, it is essential to note that federal and state laws and regulations supersede university policies, and university policies and guidelines take precedence over school, department, or lower unit bylaws, policies, or guidelines. In any situation where there is uncertainty, PD/PIs are encouraged to reach out to OSP, or the OUC for guidance.

Federal and state funding sources have stringent policies and guidelines for awardees. The OMB issued the "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards" (Uniform Guidance) (2 CFR Chapter I, Chapter II, Part 200, et al.) in December 2013, which outlines these requirements. A copy of the OMB Uniform Guidance is hyperlinked above. Additional information can be found on the updates and guidance effective in November 2020 which can be downloaded: https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200.

• HPU Grant procurement policies (HPU website)
• HPU University’s Travel Policy: Can also be found using the steps below.
  • Access My.hpu.edu
  • Click on faculty Services (on the left sidebar menu)
  • Click on Human Resources
  • Under Manual section, look for “Travel & Expenses Policy “
• Contract Approval Guidelines: Can also be found using the steps below.
  • Access My.hpu.edu
  • Click on faculty Services (on the left sidebar menu)
  • Click on Human Resources
  • Under Manual section, look for “Contract Approval Guidelines “
• Policy on Faculty Compensation from Grants
• Policy for Fringe Benefits from Grants
  • Under HPU's Facilities and Administrative Cost rate agreement (2021-2025), the Fringe benefits are included in the direct costs: FICA, WORKERS COMPENSATION, MEDICARE, MEDICAL/LIFE/DRUG/VISION/DENTAL INSURANCE, UNEMPLOYMENT COMPENSATION, TEMPORARY DISABILITY INSURANCE, RETIREMENT, AND TUITION WAIVER.
• Grant Property and Inventory Management Policy
  • Fixed Assets Inventory Memo and Fixed Assets Inventory Procedures (OSP website)
• HPU Conflicts of Interest (For employees) : Can also found using the steps below.
  • Access My.hpu.edu
  • Click on faculty Services (on the left sidebar menu)
  • Click on Human Resources
  • Under HR Form section, look for “Conflict of Disclosure Form”
  • The policy is on Page 2.
• HPU Signature Authority Limits Schedule : Can also found using the steps below.
  • Access My.hpu.edu
  • Click on faculty Services (on the left sidebar menu)
  • Click on Human Resources
  • Under Manual section, look for “HPU Signature Authority Limits Schedule “

FEDERAL AND STATE REGULATIONS

• The University complies with all state and federal regulations, including:
• Title VI of the Civil Rights Act of 1964
• Title IX of the Education Amendments of 1972
• Section 504 of the Rehabilitation Act of 1973
• The Older Americans Act of 1975
• The American with Disabilities Act of 1990
• OMB Circulars A-21, A-110, A-122, A-133

OMB 2 CFR Chapter I, Chapter II, Part 200, et al. (Uniform Guidance)

Contractual Policy: All contractual agreements between HPU and external sponsors must undergo a thorough review and approval process, adhering to HPU's contracting policies. This process includes comprehensive legal and financial assessments of contracts and requires signatures from authorized institutional representatives.

Non-discrimination Policy: HPU upholds a strict non-discrimination policy, ensuring that race, color, national origin, gender, age, disability, or veteran status do not influence any of its policies, practices, or procedures. As a private university, HPU is exempt from Federal Income Tax under section 501(c)(3) of the Internal Revenue code. For inquiries concerning tax deductible donations, please direct your questions to the Office of University Advancement.

The Office of Management and Budget (OMB) has issued the “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” (Uniform Guidance) (2 CFR Chapter I, Chapter II, Part 200, et al.) in December 2013. The OMB Uniform Guidance supersedes and streamlines requirements from eight OMB circulars, A-21, A-87, A-110, A-122, A-89, A102, A-133 and A-50 into one document.

• Additional information can be found on the updates and guidance effective in November 2020 which can be downloaded here.

For National Science Foundation (NSF), a copy of the Grant Policy can be downloaded HERE.

For National Institutes of Health (NIH) projects, the policy manual can be found in HERE.

For U.S. Department of Health and Human Services (HHS), the grant management guidance is available for reference HERE.

PRE-AWARD

OSP uses a variety of forms for various parts of the grant application. The most common OSP forms can be downloaded in the hyperlinks below:

• OSP-1 Proposal Routing form: OSP-1
• OSP-2 Proposal Budget form: OSP-2
• OSP-3 Proposal IDC Waiver form: OSP-3
• OSP-5 Conflict of Interest form [one for each person on the team]: OSP-5
  • Subrecipient Commitment Form (template)
  • Sub-Recipient Risk Analysis Tool (reference only, OSP internal process)

POST-AWARD MANAGEMENT

• Sub-Recipient Risk Analysis Tool (reference only. OSP internal process)
• Subrecipient Monitoring Action Record (OSP website)
• Service Contract Template for reference (No faculty/staff are allowed to sign as HPU representative except the personnel listed on the Contract Approval Guidelines (Refer to Appendix IV.) (OSP website)
• W-9 Form (Non-HPU Employees, HPU students, and businesses/organizations)
• Out of Pocket Reimbursement Form (Use for HPU employees and HPU Students ONLY)
• Federal Grant Travel Reimbursement Form
• General Ledger Expense Reclass Form

PRE-AWARD PROCESS

Only regular HPU faculty or full-time employees can serve as the Project Director/Principal Investigator (PD/PI) or Co-PI, and are eligible to submit grant research proposals, either individually or jointly. This requirement ensures that sponsored research and programs are led by qualified individuals with appropriate institutional affiliations, and typically, Office of Sponsored Projects (OSP) supports proposals from PD/PIs.

Requests for special support will be assessed on a case-by-case basis. The prospective PD/PI can access OSP grant-support services as outlined in the HPU Grant Guidebook. Before the internal review process begins, it is essential to discuss the draft of the project with the PI's dean and OSP. This collaborative discussion will streamline the internal review, as OSP can identify and address any potential issues in the proposal. Ideally, the discussion with OSP should occur at least 30 days before the proposal due date, or as early as possible based on the grant application opportunity's publication date.

All grant and contract applications require internal review/routing and approval from HPU before submission to the funding agency. OSP guides the grant proposal through the routing and approval process. Faculty, administrators, or staff are not authorized to seek grants or external funding on behalf of the university without prior approval. The initial step involves filling out the OSP Form1 (routing form), obtaining all necessary approval signatures, and sending it to OSP. Proposals leading to extramural funding should have early buy-in, support, and input from HPU leadership, including chairs, deans, Provost, and key directors, to ensure alignment with institutional, college, and department priorities. Refer to Appendix III for details.

Complete proposals should be submitted to OSP (PREAWARD@HPU.EDU) at least ten (10) business days before the sponsor deadline to allow for review of the proposal, budget, and all required attachments and forms. If advice or input from other university departments such as University Counsel, Human Resources, or Financial Aid is needed, additional time will be required. OSP is available to meet with PD/PIs as needed before the internal submission deadline to coordinate the grant application elements and clarify expectations during the final routing process. Appendix II provides information on the typical Roles and Responsibilities of different parties involved in the process.

For a grant or contract to be valid and enforceable, it must be signed by an authorized university official with specific delegation for signing on behalf of the university. Negotiating and resolving proposal and award issues may require coordination among the sponsoring agency, OSP, PD/PI, and, where necessary, the Office of University Counsel (OUC) and Business Office. The involvement of each party is critical for a successful award with mutually acceptable terms and conditions.

OSP and OUC have the primary responsibility for negotiating award terms and conditions with sponsors. The HPU PD/PI is involved in this process and can play a crucial role in achieving mutually acceptable award terms. However, final authority to accept an award rest with OSP and/or OUC. Prior to acceptance, OSP and OUC will review the award to ensure its compatibility with the university's sponsored research regulations, policies, and procedures, inclusion of all agreed-upon elements, approved contract language, and the PD/PI's concurrence with any non-standard or complex terms.

Payment/Reimbursement Processing

PD/PI is responsible for initiating all grant-related payment processing including submitting vendor invoices, expenses reimbursement and Purchasing Card purchases. PD/PI should follow the OSP procurement policy and HPU travel policy and additional guidelines listed in this guidebook to get appropriate approval.

For each expense/reimbursement process, the PD/PI should consider the following:

1. Check the grant budget.
2. Check the agreement to confirm any unallowable items.
3. Write down the justification (the reason of spending) which needs to benefit to the specific grant and then sign and submit to OSP along with a copy of the budget to identify the available of budget amount and category.
4. Email the forms and backup information to GRANT_PMT@HPU.EDU . All requests will be processed by first come first process base. Special requests will be evaluated case by case base.
5. If the payment is made through the p-card, PI needs to make sure the balance of the grant is good enough to cover the payment. OSP will check on the allowability—it will be a risk for the payer to absorb the expense if the payment is not allowable. If the amount is over $2500, need to get pre-approval from OSP
6. For Grant-funded travel, pre-approval should be submitted before traveling.

When OSP receives the request, Senior Grant Specialist – Grant Accounting (SGS-GA) will check all needed documents, all required approvals, the budget allowability and balance of the category to approve. If the PD/PI provides a copy of the budget, it will move the approval faster.

After OSP approves the payment, the request will be forwarded to the Business Office for processing.

Any participant support payment or stipend, PD/PI should allow more time to work with SGS-GA. Those requests are very labor intensive and need a lot of documents collected such as vendor form, W-9. OSP is very eager to assist the PD/PIs. However, more preparation time is needed to prepare a successful experience.

Billing the Sponsors (Fund Drawdown and Invoicing)

Most of the grants and contracts are cost reimbursable. OSP will run Cognos financial report per grant fund number. OSP will perform a review of the financial records and then send them to the PD/PI for review. If any errors and any missing transaction will be fixed in this time. If PD/PI confirms no issue, OSP will notify the Business Office for fund drawdown and draft out the invoices to the Business Office to review, sign off and send to the sponsor.

The Business Office will perform fund drawdown from The Payment Management Services (PMS) to request grant payments if the direct sponsors are Federal agencies. The Business Office will submit invoices to direct sponsor for payment if the direct sponsor is a non-federal agency. The prime sponsor may be federal agencies and pass the federal funding through non-federal agencies to HPU.

A very small portion of grants and contracts are “fix-priced”. The funding of the grants/contract is fixed regardless of the actual spending. Those contracts are mainly deliverable or product. The Business Office and OSP will work with PIs to confirm the deliverables before invoicing.

RESPONSIBLE CONDUCT OF RESEARCH (RCR) TRAINING

The responsible and ethical conduct of research (RCR) is critical for excellence, as well as public trust, in science and engineering. Consequently, we consider education in RCR essential to the preparation of future scientists. .  You are greatly encouraged to motivate your grant team to go over the topics through https://about.citiprogram.org.

For the USDA/NIFA, NSF and NIH grant/contract recipients, there are mandatory  Responsible and Ethical Conduct of research (RCR) training Requirements.  Most (but not all. i.e. NIH’s requirement) of the training can be fulfilled through CITI Program training: Research, Ethics, and Compliance Training, https://about.citiprogram.org. 

• UNITED STATES DEPARTMENT OF AGRICULTURE (USDA/ NIFA)

The RCR training requirement: Section 2, 3, and 8 of 2 CFR Part 422

Minimal Requirement for RCR: Online or face-to-face training with minimum content requirement determined to be appropriate by the Principal Investigator

(For NIFA, while the method of delivery or minimum hours of instruction are not specified, the Principal Investigator should determine the number of appropriate courses to take to allow for broad understanding in the practice of research)

Who Must complete the Training: Program Directors, Faculty, Undergraduate Students, Postdoctoral Scholars, any staff participating in the project.

Note that the training referred to herein shall be either on-campus or off-campus training. The general content of the ethics training will, at a minimum, emphasize three key areas of research ethics: authorship and plagiarism, data and research integration, and reporting misconduct.

• National Science Foundation (NSF)

The RCR training requirement: The provisions of Section 7009 of the America COMPETES Act (8/20/2009)

Minimal Requirement for RCR: Online or face-to-face training with minimum content requirement determined to be appropriate by the Principal Investigator

(For NSF, while the method of delivery or minimum hours of instruction are not specified, the Principal Investigator should determine the number of appropriate courses to take to allow for broad understanding in the practice of research. However, the July 31, 2023 update expanded the training topics which should now include mentor training and mentorship.)

Who Must Complete the Training: Principal investigators, co-investigators, and other academic appointees, Senior Personnel, Undergraduate Students, Graduate Students and Postdoctoral Scholars

Note: Students who receive only scholarship or stipend support to enroll in an academic program through such NSF programs as S-STEM and Noyce are not required to receive RCR training. However, students must take RCR training if they receive NSF scholarship or stipend support to engage in research, or if conducting research is included in their academic program. Also, volunteers or participants for NSF project(s) are not directly supported from salary or stipends paid by NSF, you are not subject to the RCR training requirement.

• National Institutes of Health (NIH)

The RCR training requirement: On Nov. 24, 2009, NIH updated its policy for instruction of trainees in the responsible conduct of research.

Minimal Requirement for RCR: At least 8 hours of face-to-face training/interaction (online CITI training can be a component of the overall training but cannot be the only tool)

Principal Investigators will be responsible for ensuring that all trainees, fellows, and participants complete the RCR training as described in their NIH-funded proposal. See the following links for more information on developing a training plan for the NIH funding programs listed.

As of September 25, 2022, NIH expects the following topics to be covered for a training plan to be deemed acceptable:

• conflict of interest – personal, professional, and financial – and conflict of commitment, in allocating time, effort, or other research resources
• policies regarding human subjects, live vertebrate animal subjects in research, and safe laboratory practices
• mentor/mentee responsibilities and relationships
• safe research environments (e.g., those that promote inclusion and are free of sexual, racial, ethnic, disability and other forms of discriminatory harassment)
• collaborative research, including collaborations with industry and investigators and institutions in other countries
• peer review, including the responsibility for maintaining confidentiality and security in peer review
• data acquisition and analysis; laboratory tools (e.g., tools for analyzing data and creating or working with digital images); recordkeeping practices, including methods such as electronic laboratory notebooks
• secure and ethical data use; data confidentiality, management, sharing, and ownership
• research misconduct and policies for handling misconduct
• responsible authorship and publication
• the scientist as a responsible member of society, contemporary ethical issues in biomedical research, and the environmental and societal impacts of scientific research

Who Must Complete the Training: Trainees, Fellows, Postdoctoral Scholars, Graduate Students, Undergraduate Students

Note: For NIH, the RCR requirements apply to all NIH Institutional Research Training Grants, Individual Fellowship Awards, Career Development Awards (Institutional and Individual), Research Education Grants, and Dissertation Research Grants. The programs are listed as: D43, D71, F05, F30, F31, F32, F33, F34, F37, F38, K01, K02, K05, K07, K08, K12, K18, K22, K23, K24, K25, K26, K30, K99/R00, KL1, KL2, R25, R36, T15, T32, T34, T35, T36, T37, T90/R90, TL1, TU2, and U2R. This policy also applies to any other NIH-funded programs supporting research training, career development, or research education that requires instruction in responsible conduct of research as stated in the relevant funding opportunity announcements.

PIs include detailed RCR training plans that meet NIH requirements in the proposal submission. It is the responsibility of the PIs to adhere to the plans, verify that training is completed and maintain training records. On February 17, 2022, Notice NOT‐OD‐22‐055 provided new recommendations on the format, frequency, and timing of instruction in the RCR and suggests additional topics for consideration.

Also, PI should send a copy of the certification or record of workshops/ discussion to OSP.

One suggestion: After your team completes the citi online module, host group discussion meetings (in person or through zoom/team) about each topic. OSP needs the documentation of the discussion meeting. Send a sign-in worksheet if the meetings are in person. If there are zoom meetings, please take a photo of the screen, and send OSP (OSP@hpu.edu) the meeting time and topics so that OSP can save the proof.

There are some additional materials for RCR training. Especially, the NIH projects, those materials can help the learning and team discussion on the topics related to your projects.  

Below are links to core topics for education in the Responsible Conduct of Research (RCR) courtesy of the Office of Research Integrity (ORI), https://ori.hhs.gov/. Follow the “RCR Resources” tab, there are a lot of resources gathered by ORI.

Follow the “RCR Resources” tab on the ORI home page, there are a lot of resources gathered by ORI.

1. Conflict of interest/commitment – https://ori.hhs.gov/research-misconduct
2. Human Subject Research - https://ori.hhs.gov/human-subject-research
3. Animal Resource - https://ori.hhs.gov/animal-resources
4. Collaborative Science - https://ori.hhs.gov/collaborative-science-0
5. Peer review - https://ori.hhs.gov/peer-review-0
6. Data management - https://ori.hhs.gov/data-management
7. Research misconduct - https://ori.hhs.gov/research-misconduct
8. Authorship and publication - https://ori.hhs.gov/publicationsauthorship
9. Mentor/mentee responsibilities and relationships - https://ori.hhs.gov/mentorship

JOSEPHINE (JODY) WONG, MBA, CRA

Assistant Vice President, Sponsored Projects

E: jowong@hpu.edu

P: 808-544-1489

L: WP6-401

MARK YABUI

Senior Grant Specialist – Pre-award/Grant Process

E: myabui@hpu.edu

E: PREAWARD@HPU.EDU

E: AWARDS@HPU.EDU (Sponsor Communication)

P: 808-544-9341

L: WP6-401

VALERIE SEO

Senior Grant Specialist – Grant Accounting

E: vseo@hpu.edu

E: GRANT_PMT@HPU.EDU

E: OSP@HPU.EDU (General questions)

P: 808-687-7060

L: WP6-401

Export Controls

Export Control Laws are a set of federal regulations that restrict the release of certain items, information, and software to foreign nationals in the United States and abroad. HPU is fully committed to compliance with all U.S. Government export control laws and regulations. Export Compliance is the responsibility of all HPU faculty and staff. All personnel retained by or working at, consulting to, or volunteering for the University must comply with all export control laws and regulations while teaching, conducting research or providing service activities at or on behalf of the University.

Penalties for non-compliance with export control laws are severe and impact both the institution and the researcher. If an export control violation is determined by an investigating agency, an individual may be subject to civil and criminal penalties, and HPU may be subject to, among other penalties, debarment from government contracts. Contact the Office of University Counsel for further information and inquiry.

Export Control Laws and Regulations

"Export Controls" are federal laws and regulations that govern the transfer or disclosure of goods, technology, software, services, and funds originating in the United States to persons or entities in foreign countries OR to non-U.S. persons, even if located in the U.S. The University Counsel's Office provides support for university activities subject to the three primary export control regulations listed below.

• International Traffic in Arms Regulations (ITAR)
  • Citation: 22 CFR 120-130
  • Agency: Directorate of Defense Trade Controls (DDTC), US Department of State
  • Statutory Authority: Arms Export Control Act (AECA)
  • Scope: Primarily military technology, technical data, and services.
  • Examples of Items Controlled: satellite technology, some unmanned aerial vehicles, global positioning systems, chemicals, night vision technology, navigation systems, sonar and radar systems, military electronics, and software.
• Export Administration Regulations (EAR)
  • Citation: 15 CFR chapter VII, subchapter C
  • Agency: Bureau of Industry & Security (BIS), US Department of Commerce
  • Statutory Authority: Export Administration Act (EAA) and the International Emergency Economic Powers Act (IEEPA)
  • Regulations: Export Administration Regulations (EAR)
  • Scope: Items in US commerce that are not controlled by another agency. Controls are predominantly related to dual-use (those with military and commercial utility) technology listed on the Commerce Control List.
  • Examples of Items Controlled: lasers, infectious agents, computers, encryption technology, sensors, navigation and avionics, propulsion systems, toxins, chemicals, certain materials for the manufacture of controlled goods, and telecommunications equipment.
• Embargoes and Trade Sanctions or Foreign Assets Control Regulations (FACR)
  • Citation: 31 CFR 500-598
  • Agency: Office of Foreign Assets Control, US Department of the Treasury
  • Statutory Authority: Presidential National Emergency Powers and various legislation impacting international trade.
  • Regulations: International Trade Regulations
  • Scope: Varies among the different sanction programs. Sanctions may be comprehensive or limited.
  • Examples of Controls
    • Country-Based: Iran, Cuba, certain Ukraine regions, Syria, and North Korea.
    • List-Based: Counter Terrorism, Non-proliferation, and Counter Narcotics Trafficking.
    • The Iran Sanctions Guidance Document spells out specifics for Cornell faculty, staff, and students wishing to travel to Iran or engage with and Iranian entity.
• Other Federal Agencies with Export Control Authority
  • Although the Departments of State, Commerce & Treasury are the primary agencies with export control authority for items, technology, associated non-public information, and services, there are other agencies that have authority over other types of goods and materials. The agencies listed below are examples, not a comprehensive list:
  • Office of Diversion Control, Drug Enforcement Agency, Department of Justice
  • Import/Export Quick Reference Guide and website
  • Food and Drug Administration
  • Export Guidance website
  • US Fish & Wildlife Service, Department of the Interior
  • USFWS Import/Export Permit website
  • Nuclear Regulatory Commission
  • NRC Export-Import website
  • Department of Energy
  • National Nuclear Security Administration website; Office of Nuclear Energy website
  • Animal and Plant Health Inspection Service, Department of Agriculture

APHIS Import/Export website