Policies & Compliance
- Research Conduct
- Combatting Human Trafficking
- Federal Disclosure Requirements
- Research Handbook
- 1. Roles & Responsibilities
- 2. Standards for Conduct of Research
- 3. Overview of Sponsored Projects Administration
- 4. Funding Sources & Opportunities
- 5. Proposal Development
- 6. Budget Development
- 7. Procedures for the Submission of Proposals
- 8. Award Acceptance
- 9. Award Management
- 10. Research Related Regulations, Policies & Procedures
- 11. Other Conduct of Research Issues
- 12. Acronyms & Definitions
- 13. Glossary
- Procedure Library
- Regulations Library
Standards for Conduct of Research
2.1 Standards of Business Conduct
2.1.1 Federal Regulations
As a recipient of federal funding, the University of Utah is required to administer all grants, contracts, cooperative agreements, and other sponsored agreements in accordance with federal reguations, agency-specific guidelines, and the Uniform Guidance (2 CFR 200). These requirements establish standards for financial management, procurement, internal controls, allowability of costs, and research compliance.
Although specific terms and conditions vary by sponsor, all sponsored awards - federal, state, local, or private - must be administered consistently and in compliance with federal standards. OSP is available to assist investigators and departmental administrators in interpreting sponsor rules, federal regulations, and award requirements.
2.1.2 Debarment and Suspension
Definitions
- Debarment- A debarment is an action by a federal agency that excludes an individual or entity from participating in federally funded transactions for a specified period.
- Suspension- A suspension is a temporary exclusion imposed while an investigation or legal proceeding is underway. Suspension may lead to debarment.
Federal regulations, including Executive Order 12549 and related procurement rules, require the University - when applying for or receiving federal funds - to certify that neither the institution nor its officers or project personnel:
- Are currently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from participation in federally funded transactions.
- Have been convicted of or had a civil judgment for fraud, criminal offense, antitrust violations, embezzlement, theft, bribery, falsification of records, making false statements, or receiving stolen property within the preceding three years.
- Are currently indicted or otherwise charged (criminally or civilly) with any of the offenses listed above.
- Have had one or more public transactions terminated for cause or default within the preceding three years.
Any individual who meets any of the above conditions must immediately notify OSP. Such individuals are prohibited from receiving federal salary support or serving on federally funded projects.
PIs must also disclose debarment or suspension status on the Document Summary Sheet (DSS) during proposal routing.
2.1.3 Lobbying
Under Section 1352, Title 31, U.S. Code (The Byrd Amendment), federal funds may not be used to influence or attempt to influence any officer or employee of the Executive or Legislative branches for the purpose of:
- Obtaining a federal award
- Extending, renewing, or modifying an existing award
This restriction applies not only to institutions but also to individual employees, including faculty, researchers, and administrative staff.
Key Requirements for University Personnel
-
Federal fund may not be used for lobbying.
This includes charging salary, travel, or other expenses to a federal award for the purpose of influencing an agency's funding decision. -
Long-term University employees (>130 days employed) have more flexibility in discussing research with program officers than nonemployees or new hires.
Newer faculty or staff should avoid discussing specific funding requests until they are sufficiently established at the University. -
Acceptable communication:
"When will a decision be made on my proposal?" -
Unacceptable communication:
Advocacy for funding a particular proposal ("Here is why my proposal should be selected...")
Program officers are trained to manage these boundaries, but responsibility is shared. When uncertain, investigators should ask OSP for guidance.
Certification Requirements
For federal proposals that exceed $100,000, the University must certify at submission that:
- It has not used federal funds for lobbying; and
- If non-federal funds were used for permitted lobbying activities, the University must file the required disclosure report.
Investigators must notify OSP immediately if they are aware of any facts that would render this certification inaccurate.
Penalties
Violations can result in:
- Fines of $10,000 -$100,000 per violation
- Loss of an award
- Institutional suspension or debarment
These penalties apply both to the individual and to the University.