Senior Associate Dean for Research Answers Your Questions

UK College of Medicine has committed substantial resources to develop modern research environment to facilitate basic, translational and clinical research. Many faculty and staff have expressed interest in an online, anonymous form to submit questions to me. To expand these resources, we have set up this submission form for you to submit questions. I address these questions through weekly news updates, on this web page, and in person if sufficient information is provided.

In one way or another, I hope I am able to provide you with an answer to your research related questions. Some questions have been combined with others, edited or otherwise altered to provide meaningful answers that will be applicable to the majority of the College community.

Here are some questions I have received:

NIH recently revised the policy on JIT submission. Per notice NOT-OD-12-101, applications receiving an impact score of 40 or less will receive a standard notice and request for submission of JIT information. These notices will be sent via e-mail from NIH eRA Commons to the Project Director(s)/Principal Investigator(s) two weeks after release of the impact score. The scoring level of 40 reflects NIH’s new Impact Scoring system and current tightened paylines, but it does not reflect any individual IC’s payline.

As a reminder, a notification request for JIT information is not a Notice of Award, nor is it an indicator of possible funding by the NIH.
Not necessarily. The acknowledgement of federal funding that directly supported the publication is a requirement of the NIH Public Access Policy. It is the responsibility of any named author to decide if the publication related to the grant/contract scope of work and bore direct costs. "Directly" funded means costs that can be specifically identified with a particular project or activity. Acknowledging every grant on which you receive support without confirming direct applicability would be considered a violation of this federal policy.
Neither of these has a simple yes/no answer. For the internal pilot proposal, it would depend on the origin of the funding as it came to UK (Is it external and treated as a sponsored project?) and whether or not an award within the program would require its own WBS number or that a scope account be set up as part of a larger prime account/WBS number through OSPA. In some cases, the proposal itself may not require an eIAF, but if funds are awarded, then the unit administering the overall sponsored award may ask for an eIAF at the time of award. If the guidelines for the submission aren’t clear, check with your CGO if you have questions about a particular program. For an external pre-proposal or LOI, it also depends on several things. Does the sponsor require an institutional signature and some official commitment of University resources as part of the LOI or pre-proposal submission? Is detailed budget information required? If so, then it’s likely an eIAF will be needed. If all that’s being submitted is a summary of a proposed research idea, or it’s just to inform the sponsor of the intent to submit a full proposal at a later date with no budget details, then an eIAF isn’t usually needed. Please contact your College Grant Officer for guidance.
The accountability requirements for any expenses placed on a grant account (WBS element) reside with the PI. As PI, the subcontract payments should only be approved by the PI (or designate) with first-hand knowledge of deliverables being met and agreement with invoiced costs. If the PI does not feel comfortable approving any invoiced items, he/she should ask for further information or backup. Don’t approve an invoice for payment if the work hasn’t been done to the PI’s satisfaction. Backup documentation could include items like effort reports or invoice copies. Questioning how the expense benefits the project would be a normal review. Receipt of an invoice does not obligate the PI to pay it unless the contracted work has been completed. Questions related to this topic are available for discussion with your College Grant Officer .

NIH regulations require specific/certain certifications upon proposal submission. In compliance with these regulations, UK requires these certifications as part of the IAF (internal approval form) routing process for any external funding source. Signatures are required of the PI, Co-Is, other faculty involved in the project, and staff who hold a leadership role on the project.
Chairs, center directors, and deans must also sign the IAF to confirm the project is within the educational and research objectives of the unit. They are also confirming that the necessary Research Financial Interest Disclosure Statement (or ‘COI’) form has been completed. This form is required upon proposal submission also as a compliance requirement.
Click here for IAF and COI information.

If you have additional questions about this topic, please contact your College Grant Officer (CGO) here

A detailed budget is needed to confirm that sufficient funds are being requested to cover the effort of the personnel being committed; to ensure the correct F&A rate is used and has been applied properly; and so that all represented units have had an opportunity to determine that the proposed enrichment split is equitable, based on the breakdown of the categories listed in the budget.
Yes. Only the following fonts are allowed: Arial, Helvetica™, Palatino™ Linotype, or Georgia®. The font size should be 11 points or larger and applies to all text portions, including the Biosketch, Literature Cited, etc. It also applies to all text sections of paper submissions and all portable document format (PDF) files for electronic submissions. You can use a smaller font size for the following (ensuring that it is readily legible and follows the font typeface requirement): figures, graphs, diagrams, charts, tables, figure legends, and footnotes. The NIH instructions and forms are available here: http://grants.nih.gov/grants/forms.htm Your local College Grant Officer  can assist you with questions.
The DHHS Office of Research Integrity has some advice about image modification here (http://ori.hhs.gov/data-management-0) that refers visitors to the Journal of Cell Biology guidelines here (http://jcb.rupress.org/content/166/1/11.full ). In short, they advise many manipulations constitute inappropriate changes to your original data, and making such changes can be classified as scientific misconduct. Skilled editorial staff can spot such manipulations using features in the imaging software, so manipulation is also a risky proposition. Examples include contrast adjustments, resolution changes, and background changes. Good science requires reliable data. Consequently, to protect the integrity of research, the scientific community takes strong action against perceived scientific misconduct. In the current definition provided by the U.S. government: “Research misconduct is defined as fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results.” For example, showing a figure in which part of the image was either selectively altered or reconstructed to show something that did not exist originally (for example, adding or modifying a band in a polyacrylamide gel image) can represent falsification or fabrication.
The Principal Investigator (PI) on the award is responsible for all activity associated with the R01. As such, the PI should be reviewing and approving any and all expenses on the grant (WBS Element). With reference to the question, the faculty collaborator should be providing the Procard documentation to the PI. In the case of an audit, the PI (and that department) will be responsible for providing the procard documentation requested by the auditor. The UK Policy on what documentation is necessary for Procard transactions is here: http://www.uky.edu/EVPFA/Controller/files/pay/CardholderManual.pdf.
The new PHS Policy on Humane Care and Use of Laboratory Animals FAQs is on the web.  Click here.  Please consult with the Department of Laboratory Animal Resources about the impact of this new policy.
The G/L code is 540311 (chemical and laboratory supplies) unless specifically forbidden by the sponsor’s guidelines. Note:  The purchase of the coat is okay, but the cost of embroidery is not.  The embroidery cannot be specifically identified as necessary to protect the employee.  The coat itself is okay because it is a necessary personal protective item like gloves or eyewear protection.
No, generally, these types of costs are not allowable on regular research grants – like NIH R01s, for example. Because these kinds of costs are needed to support any sponsored project, and are difficult to allocate based on their usage to a specific project, the federal gov’t instead covers these costs of academic institutions via a negotiated indirect cost rate—currently 48.5% at UK -- rather than as a budgeted direct cost of a project.

There are some exceptions noted in OMB Circular A-21, the federal regulatory document that addresses cost principles for educational institutions. If a sponsored project has some sort of special scientific need or purpose that requires a dedicated printer, it may be possible to have the cost of it and the associated supplies budgeted as a direct cost of the project. The printer must be required to fulfill the scientific objectives, be specifically identified with the project, have a preponderance of use (75% or greater) on the project, and be specifically listed in the proposal budget and be awarded. Just needing a printer to produce reports or manuscripts would likely not be a sufficient reason for the grant to cover the cost directly. You should work with your CGO if you believe you may have a situation where direct charging these costs may something to consider and evaluate.
The lab coat cost is an allowable expense on the R01 if the lab tech is working 100% on that project. If the tech is working on several projects, the coat’s cost needs to be allocated based upon their effort to those projects. Note: What is not allowed, as part of the coat cost, is the embroidery or monogramming of that person’s name. The monogramming is not an essential expense that will directly benefit the research and therefore not allowed.

The University of Kentucky does not uniquely restrict the ‘tobacco industry.’ UK Research Foundation has general guidelines that must be met for any grant to be accepted from any funding agency. As long as the industry agrees to the guidelines, their funding may be accepted. Note: Some funding agencies restrict having dual funding from this industry. As an example the American Cancer Society (ACS) has restrictions on being funded by this industry and by ACS at the same time.

This statement is one that may be generated by eRA Commons following an electronic submission of an R01 proposal via Grants.gov.  (Please note that this is a response to a computer validation; while these computer validations will help minimize incomplete and/or non-compliant applications, they do not replace the validations conducted by NIH staff. Applications found not to comply with the requirements may lead to rejection of the application during agency validation or delay in the review process. )   As long as you are confident tha.t when allowing for white space the research strategy section does not exceed the limit of 12 pages, then no action is necessary.  If it does exceed 12 pages,  then the section must be edited so that it doesn’t exceed this limit, and the proposal would need to be resubmitted through your RA in OSPA. 

If you’re not certain of the page limit for your application, refer to the specific program announcement, and the SF424 (R&R) Application Guide.  The PA information takes precedence over the standard application guide.  Your CGO can also assist if you have questions regarding page limits.   


A first step would be to contact your research dean letting them know that you are starting the nomination process. They may be able to provide you with advice or a recommendation.  A second step would be to contact the SRO asking that you be considered and provide them with your CV. NIH maintains a list of study sections (http://www.csr.nih.gov/committees/rosterindex.asp) that could be used to identify potential subject areas within your area of expertise. This list might also be used to identify collaborators on study section. Knowing who is on the section is important as the study section members can nominate new members.

Yes. The Center for Scientific Review (CSR) recommends that you include a cover letter for your application in many situations. The letter is provided to the SRO staff for use in referring your application. The letter is not provided to the review group.
Popular Reasons to Use a Cover Letter include:
• Suggests to assign your application to a particular review group.
• Suggests to assign your application to an NIH institute(s) or center(s) you think would be interested in your research.
• Describe the kinds of expertise needed to review your application.
• Communicate potential reviewers who you feel might be in conflict with your application.
CSR maintains a helpful list of items on how to write a cover letter.  Click  here  to view that list.

A resubmission or renewal application should normally have the same title as the previous application or grant. But, if the specific aims of the project have significantly changed, choose a new title that accurately describes the project. If you do change the title, check the box for a renewal or resubmission and enter the grant number for the Federal ID on the cover component and note the title change in the cover letter.

In an effort to further streamline the routing process for investigators, hard copies of the financial disclosure/COI form no longer need to be sent to your CGO. In addition to the other required attachments, COI forms signed by all College of Medicine investigators must now be attached to the eIAF before it will be certified by Alan Daugherty, Sr. Associate Dean for Research. Before the CGOs will approve an eIAF for further routing, all College of Medicine COI forms must be attached. If the COI forms cannot be attached to the eIAF, please email a scan of the signed form/s to your CGO and they will attach the form/s prior to their approval. If you have questions, please contact your College Grants Officer.

With the implementation of the new eIAF process, emails are system-generated from the “batch user” whenever action is needed by a particular individual on an IAF. Instructions are included in each message, according to the role of the email receiver (PI, Co-I, chair/director) in relation to the IAF referenced in the email. In the email will be the PI’s name, title of the project, and sponsor. Also, a link is provided to the myUK portal where the certification process takes place. Effective November 1, all IAFs must be submitted via the electronic process. Training continues weekly on this process – every Tuesday at 3 p.m. in 72 McVey Hall. No registration is necessary. “Help” documents can be found on the OSPA website. You may also contact your CGO with any questions.

The Department of Health and Human Services (HHS) including the NIH operates under a Continuing Resolution (CR) that was enacted on October 4, 2011. The CR continues government operations through November 18, 2011 at the FY 2011 level minus 1.5 percent. Until FY 2012 appropriations are enacted, NIH will issue non-competing research grant awards at a level below that indicated on the most recent Notice of Award (generally up to 90% of the previously committed level). This is consistent with our practice during the CRs of FY 2006 - 2011. Upward adjustments to awarded levels will be considered after our FY 2012 appropriations are enacted but NIH expects institutions to monitor their expenditures carefully during this period. For a typical noncompeting R01 awarded during the CR, you should receive 90% (225,000) until the new year federal budget is passed. After that time, NIH will determine what it can afford which may provide additional funding.

No. Just-In-Time information will be requested by the NIH when the information is needed. An applicant should only submit this information when requested by the NIH. If you see the "Just-In-Time" button in eRA Commons, that is not considered a request. When the information has been requested (primarily through email) it can be submitted electronically using the Just-In-Time feature in the eRA Commons.

Other types of submission directly to the assigned grants specialist (email, fax, hard copy mail) are also acceptable but the submission must be processed through an authorized institutional official which at UK is the Office of Sponsored Projects Administration.

NIH Notice

Our current human research protection program does not allow for use of an independent or central IRB. UK IRB does have a facilitated review process for NCI supported research and on occasion will enter into a cooperative IRB agreement for review of off-site/collaborative research but otherwise all human subject research must be reviewed by UK IRB. The IRB FAQ page indicates what research is reviewed by the nonmedical vs. the medical IRBs.  For the complete UK HRPP, click here.

NIH regulations require specific/certain certifications upon proposal submission. In compliance with these regulations, UK requires these certifications as part of the IAF (internal approval form) routing process for any external funding source. Signatures are required of the PI, Co-Is, other faculty involved in the project, and staff who hold a leadership role on the project. Chairs, center directors, and deans must also sign the IAF to confirm the project is within the educational and research objectives of the unit. They are also confirming that the necessary Research Financial Interest Disclosure Statement (or ‘COI’) form has been completed. This form is required upon proposal submission also as a compliance requirement. Click here for IAF and COI information.

The Fly America Act is a federal regulation that requires the use of U.S. carriers for air travel that will be reimbursed by federal grants and contracts. Refer to UK’s travel policy Section VI., A. 1. for more details. If the air travel doesn’t comply with the terms of this Act, there is a risk of having it considered an unallowable expense on your grant that would have to be covered by departmental funds.

Lab Coats are part of the overall Chemical Hygiene Plan as directed by Federal Law and carried out at UK by Environmental Health and Safety (EH&S). Personal Protective Equipment (PPE) including lab coats, cover gowns, gloves and goggles should be left in the laboratories and not worn in public areas. The entire chemical hygiene plan is available here and PPE is discussed specifically in Chapter 3.

Individuals are encouraged to respond to a notice published in the Federal Register by NIH or any Federal agency requesting information or public comment. This is not considered lobbying and need not be reported to the UK Office of Federal Relations. However, an official response on behalf of the University of Kentucky must come from an appropriate administrative office, usually the Office of the Vice President for Research. If individuals think that the University should take a particular position on an issue, they should contact Dr. James W. Tracy, Vice President for Research. As a reminder, the University must comply with Federal Law governing lobbying activities. Only individuals approved by the Vice President for Research are authorized to lobby the Federal government on behalf of the University. For more information, visit the Office of Federal Relations website at: http://www.research.uky.edu/vpresearch/fedrelations/index.html.

The Office of Sponsored Projects Administration (OSPA) provides a “Useful Proposal Information” page at this link, http://www.research.uky.edu/ospa/info.html, which provides many of the standard items needed for most proposal submissions. If you can’t find what you need, contact your CGO for assistance.

The UK Proposal Development Office was created to assist faculty, staff, and students seek and secure grants. They have a variety of support features including, but not limited to searches for funding mechanisms, providing template information about UK resources, and reviewing proposal drafts. Given sufficient time to assist with the development of proposals, their office can be of tremendous support.

No. Rebates associated with University purchases are the property of the University of Kentucky and may not be used for personal or non-University purposes. For more information, click here.

Yes, the University recommendation is to use the NIH guidelines. The College of Medicine has established 80% of this scale as a minimum.

Questions about this answer can be directed to the College HR Employee Relations office, Phone: (859) 323-1601.  

The University completes random employee drug screening for positions required to undergo those screenings per federal guidelines but does not have an institution wide random drug screening program. If a University supervisor believes that an employee is under the influence of drug or alcohol in the workplace, he or she should refer to Human Resources Policy and Procedure Number 13.0: Drug Abuse and/or Human Resources Policy and Procedure Number 14.0: Alcohol Abuse and follow the procedure outlined within those policies. Additionally, all UK HealthCare members are subject to fitness for duty screening per UKHC policy and procedure: Fitness for Duty Evaluation # A09-005. UKHC members include all University of Kentucky employees in positions within UK HealthCare units (SAP Personnel Area 1500), all UK HealthCare Medical Staff members, all UK HealthCare Health Professional Staff, all house officers, all University of Kentucky students participating in clinical rotations, all employees of Central Kentucky Management Services, Inc., all employees of Kentucky Medical Services Foundation, Inc. and all volunteers and representatives acting as agents of the University of Kentucky involved in any UK HealthCare activity.

While governmental agencies such as NIH and DOD announce grant opportunities with a several month response period, most private granting agencies announce grant opportunities 6 to 8 weeks prior to the deadline. Many websitesexist that provide access to announcements about grant opportunities. For federal grants, the website is www.grants.gov. For private organizations, websites such as www.scangrants.com or www.cos.com are available. Most of these sites allow you to subscribe to personalized emails containing the latest grant opportunity announcements.

Laundering of lab coats used for work on a series of grants or for general lab work is not normally an allowable charge on a grant. If, however, the lab coats need to be laundered because of work on a specific grant, for example if the grant requires the use of messy reagents, you can charge it to that grant but a budget revision would be required. (The cost would charge to general ledger account 535019; sponsored class E545999.) Work through your business office and OSPA to request a budget revision before the cost is incurred.

Allocation of expenses should be in line with how the product/service was used.
It must be Reasonable. You should be able to justify or defend your logic for any expenses on your grants.
A similar situation is described here:
My research group uses thousands of pipettes each year for our investigations. We conduct research under three separate awards all of which require pipettes to carry out the technical scope of the work. Each project proposal included the cost of pipettes in the budget and the cost was not specifically disapproved by the agency. To take advantage of bulk pricing discounts, we would like to purchase pipettes three cases at a time and would like to rotate the purchases between three sponsored agreements, charging three cases purchased in January to the NSF, three more cases purchased in March to the NIH grant, then three more cases purchased in June to the Packard award, to assure each award gets a share of the total pipette cost. Is this OK?

The costs are allowable as they are required for the technical scope of the projects, but rotating costs between awards does not meet A-21's redistribution standards. Instead, the group must distribute the costs to benefiting functions using some reasonable allocation basis like FTE, head count, square footage etc. The keys to a successful redistribution plan are:
1. all benefiting functions must share in the costs,
2. a reasonable basis for the redistribution is established, and
3. the redistribution basis is documented .

The email list is generated automatically through SAP. People are selected based on what constituency group they are associated with – faculty, staff, medical student, graduate student, house staff, etc. If someone is not coded in SAP as a College of Medicine constituent, then they must be added to the “other” distribution list in order to ensure they receive email from the College of Medicine. If you wish to be added to the distribution list, contact Molly Clark at molly.clark@uky.edu.

Yes. As senior author, you are responsible for all parts of a publication. The adjectives used could be considered by NIH, and/or your home institution, as reason for a misconduct investigation. Taking this a step further, plagiarism would also be a source for an investigation. As senior author, it is your responsibility to have oversight of the work. Exercising due diligence is necessary to assure no misconduct. Lack of oversight of the senior author does not exclude that person from the supervisory responsibility.

If you’d like to include an individual who will contribute to the scientific development or execution of the project but they’re not committing any measurable effort (in person months) – no direct salary support in the grant budget and no cost share commitment – they should be identified in the proposal as “Other Significant Contributors.” NIH has specific guidance in the SF424 (R&R) Application guide on the appropriate way to include them in this role. Your CGO can also advise you on the appropriate way to do this.

Clarification of the Mentor versus Adviser role
In theory, mentors have multiple responsibilities – being an adviser is one of these. According to the Council of Graduate Schools mentors are:
-Advisors: People with career experience willing to share their knowledge.
-Supporters: People who give emotional and moral encouragement. -Tutors: People who give specific feedback on one’s performance.
-Masters: Employers to whom one is apprenticed.
-Sponsors: Sources of information about opportunities and aid in obtaining them.
-Models of identity: The kind of person one should be to be an academic or professional scientist.

In reality, it is unlikely that any one individual can fulfill all possible mentoring roles. For this reason, many argue that the term mentor should be used broadly to mean an individual who helps another with one or more aspects of his or her personal or professional development or both. In this sense, trainees are encouraged to seek out various faculty who can provide some of these components.

An original is the first human-readable form - for example, a printout of a measurement but not a photocopy of it. It should be date, signed, and filed.
"M"Making the Right Moves, a Practical Guide to Scientific Management for Postdocs and New Faculty," Burroughs Wellcome Fund, Howard Hughes Medical Institute. 2nd Edition, 2006.

The UK fiscal year runs July 1 to June 30. pan class="style1">Certain university deadlines must be met as the end of the fiscal year approaches, even if your grant budget year differs from the university’s fiscal year. For example, reimbursements for travel and payments to vendors for expenses any time prior to June 1, 2011 is due to Accounts Payable by June 6.
You should work closely with your administrative staff to meet these university deadlines.
Fiscal Year 2010-2011 Closing Schedule is available here.

The form package should always be downloaded from the appropriate funding opportunity announcement (FOA). All parent announcements for unsolicited or investigator-initiated applications can be found at this link and a search for special announcements can be done at this link. NIH also provides this helpful guide on how to ensure the right forms are being used for the submission here.
Your CGO can also assist you.

In the course of sponsored activity it is often necessary to involve parties outside UK to assist in the technical and programmatic aspects of the project. Normally the need for outside assistance is known during proposal preparation and the details are included in the proposal to the sponsor. The method for formalizing the arrangement is through a subcontract or personal services contract. Both of these relationships require a formal written agreement before work may begin.
For a sub recipient/subcontractor, at the proposal stage, the following documents are normally required: Letter of intent (special format for NIH), Budget, Description of work, Signed sponsor face page and certification pages, and possibly other sponsor specific requirements.
Consult with your CGO a at the proposal stage to ensure you have included the arrangement explanation appropriately in your proposal.

xTrain is an NIH platform within eRA Commons for the management of F and T awards, among others.  The specific list of award types managed by xTrain is here.
NIH has resources to help you navigate xTrain, the electronic appointment system for training grants, fellowships and career development awards herea>.

The University of Kentucky Research Foundation (UKRF) serves as the university's agent in the receipt of all external grants and contracts, intellectual property income and other designated income; oversees the protection, development, and commercialization of intellectual properties; and manages special cooperative agreements. Please see – UKRF for more information.

The sponsor’s guidelines will determine the answer. If a sponsor does not pay UK’s federally negotiated F&A rate, currently at 48.5% for research projects, then the base for calculating F&A costs is the Total Direct Costs, with no exclusions, such as tuition or patient care. However, if the sponsor’s written policy states that it does not pay F&A on particular costs, then those costs must be excluded from the F&A base prior to calculating F&A costs.
Contact your CGO for help on a calculation or clarification of the above information

There are no restrictions on the receipt or use of frequent flyer miles earned on business travel for the University of Kentucky.

Yes, the Office of Sponsored Projects can establish an account in E (expected) status pending Institutional Review Board approval. However, the investigator must acknowledge that no subjects will be recruited or enrolled on the study until IRB approval has been obtained. This can be accomplished by the PI preparing and signing the “No IRB Approval Memo” which can be found at this link on the Office of Sponsored Projects website. This memo must be signed and attached to the Internal Approval Form.

PI effort has to be committed to the project, so PI salary should be listed on the sheet.
For an Industry Sponsored Clinical Trial patient care costs must be listed. However, if there is a reason no patient care charges will be incurred, such as on an observational study, then an explanation should be provided. If any residual is anticipated from the project, then make sure that an explanation is provided for the residual.
Fixed Price Budget Sheet.  Internal Approval Form (IAF).
Please feel free to contact your CGO for assistance.

YES. Don’t touch environmental surfaces – doorknobs, keyboards, computer mouse with your gloved hands. This means when leaving the laboratory TAKE OFF YOUR GLOVES. If you need to wear a glove in the hallway to carry a sample, make sure that the gloved hand is carrying the sample and the non gloved hand is operating door handles, elevator buttons, etc.

For proper technique of putting on and taking off gloves, please see here for Environmental Health & Safety recommendations.

In NSF terms, the “deadline” date is the actual date after which proposals will not be accepted for review. NSF also uses the term “target” date. The NSF Grant Proposal Guide (click here) provides an explanation of the difference which is summarized here.

Many NSF programs accept proposals at any time. Other programs, however, establish due dates for submission of proposals.

The following types of due dates are utilized by NSF:
Target Dates: dates after which proposals will still be accepted, although they may miss a particular panel or committee meeting. Deadline Dates: dates after which proposals will not be accepted for review by NSF. The deadline date will be waived only in extenuating circumstances. Such a deviation may be authorized only in accordance with GPG Chapter II.A.

Should you have questions regarding a specific date noted in a program announcement, contact your CGO for assistance.


The UK Research Foundation indirect (also called overhead, or Facilities and Administration- F&A) rate depends upon the type of work being completed. The current regular research rate is 48.5%. Please contact your CGO if you have questions about the rate applicable to your project. For OSPA website with F&A information click here.


First, as a UK faculty member, refer to the website of UK’s Office for Commercialization and Economic Development.  They have FAQs on Intellectual Property Development at this link, which provides a good starting point.  

Was your item developed using NIH or other federal support?  If so, reporting is required through iEdison.  This is the government’s system for helping government grantees and contractors comply with a federal law, the Bayh-Dole Act, which requires that government funded inventions be reported to the federal agency who made the award.  Start with their home page, which provides a list of federal agencies that use this service.  You can then determine requirements of your specific funding agency.


PD/PIs can no longer manually add publications add publications to eSNAP reports with Commons.  All publications must be managed within myNCBI.  

eRA Commons has partnered with the National Center for Biotechnology Information (NCBI) to link NCBI’s personal online tool, “My NCBI,” to Commons. My NCBI offers an online portal—“My Bibliography”—for users to maintain and manage a list of all of their authored works, such as journal articles, manuscripts accepted for publication, books, and book chapters.  

Linking an eRA Commons account to a new or existing My NCBI account allows references saved in the NCBI My Bibliography to automatically appear in users’ Commons accounts. The proposed association will not be complete until the grant’s PI confirms the request and then it will be listed as official.  Only after the eSNAP has added this publication and submitted to the agency will the process be complete.  
myNCBI:  http://www.ncbi.nlm.nih.gov/sites/myncbi/  

Note: Use the NIH Manuscript Submission (NIHMS) System to upload manuscripts or associate papers with your award. You will be automatically logged into the NIHMS with your NIH eRA Commons user ID.  
Some useful demo information appears at this link.


You should consult with your chair, department administrator, and CGO as soon as the decision has been made to leave UK. There are very specific processes to be followed and paperwork to be completed at least 90 days prior to departure. Refer to the link here and here.  

Not all sponsor policies are the same; some allow transfer of their awards, others do not.  Equipment transfer policy is not the same for all sponsors.  If you purchased equipment on a grant, but the grant has ended, the equipment is under the University’s purview to determine disposition.  Arrangements would need to be made with your new institution to purchase the equipment, once it has been approved through the surplus property process as outlined in the equipment transfer guidance provided above.

Note:  Please do not remove any equipment or supplies until documented approval has been received.

All open records request should be forwarded immediately to the Office of Legal Counsel. Kentucky law mandates that the University must respond to requests for record within three (3) days of receipt. “Receipt” is from the date you or your office receives the request, not from the date when the Office of Legal Counsel receives it. Therefore, it is imperative that you notify the legal office as soon as you receive a request for records so we can review the matter and respond in a timely manner.

The legal office, on behalf of the official University records custodian, is responsible for determining whether the request is proper and whether any legal exemptions are applicable. The legal office is also responsible for gathering the requested documents and then either arranging a time for inspection of the documents or for making copies available to the requestor.

Answer: Yes.
The Vice President for Research has set a deadline to receive final proposals three business days in advance of the sponsor deadline.

This deadline applies to both electronic and paper submissions. You should contact your CGO well in advance of the three day deadline so that he/she can assist you. The Office of Sponsored Projects Administration (OSPA) has a website to accept proposals here.

The version uploaded to the OSPA website should be completed, error-free and ready for submission.   (Find your CGO here)

Note: UK Policy requires the completion of the Internal Approval Form (IAF) and financial conflict of interest form (COI) for all key personnel prior to proposal submission. Please see the IAF instructions here.

Yes. Yes. YES!
Employees refusing to evacuate or prohibiting others from evacuating will be subject to disciplinary action in accordance with Human Resources Policy and Procedure Number 12.0. Students refusing to evacuate or prohibiting others from evacuating will be subject to disciplinary action in accordance with the Code of Student Conduct. Occupants must not return to the building until the fire officials give approval.
Should your department need assistance enforcing this policy, please contact the University Fire Marshal’s office at 257-6326.


On the regular financial reports that PIs should be receiving monthly form their business staff, there should be sufficient detail included for the PI to ascertain that the correct individuals are charging salary and in the appropriate proportion to the grants under his/her area of responsibility. Any discrepancies should be addressed with your department/center business staff. This is especially important when ARRA/Stimulus funds are involved, and also with the increased detail needed and accuracy that is expected on the NIH All Personnel Report portion of NIH non-competing annual progress reports. Your CGO will be comparing this Report to the University’s HR/Payroll system to be certain they agree before the report is submitted to NIH.


No, UK policy doesn’t allow this. Instead, depending on the role of the individual, “collaborator” may be appropriate. Please contact your CGO for assistance, as the sponsor may also have certain title conditions or restrictions that need to be followed. See also: http://www.research.uky.edu/ospa/info/subcontracts.html).


Yes, a proposal  “resubmission” to a sponsor would still be considered a “new” proposal by UK.  And, per UK policy, an IAF is to be completed (fully routed with all required signatures and provided to OSPA) before a proposal is submitted. This is necessary for compliance with NIH policies that require specific certifications by the PI and the authorized official of the submitting institution. If this certification is not completed prior to submission, the University is out of compliance. (Since NIH is the University’s largest funder, we have policies for all submissions that comply with their rules.)


Open Lab doors are not permitted. The open door affects the negative air flow into the lab, causing a potential risk of biohazards or radiation backwashing into corridors, and contamination to tissue culture. Closed doors help contain spills or potentially dangerous situations. If a lab is unoccupied, the door needs to be locked to prevent theft of items.


As early in the process as possible – whether you need a wall knocked down or an electrical outlet upgraded for an equipment purchase in the proposal or any sort of structural or utility work is anticipated – contact Ann Thomas, who is the College of Medicine’s liaison to the Medical Center Physical Plant Division. While there are specific steps to be followed once the project is funded (PDF doc here), it’s important that preliminary discussions are held with Ann as a proposal is being written and developed to ensure the work is feasible, to make certain that a reasonable time frame is possible, and to determine how the costs will be paid. Also keep in mind that other units on campus must also be involved – Environmental Health and Safety, Biological Safety, and the Fire Marshal, for example.

College guidance can also be found in the “Facilities and Equipment” category of the APIP website.

There is a question on the Internal Approval Form (IAF) that asks for a detailed explanation of any renovation or alterations plans related to the project. Be sure this explanation is attached to your IAF. Your CGO can provide assistance with preparing this explanation.


UK requires all Material Transfer Agreements (MTA) to be reviewed by the Office for Commercialization & Economic Development. When a university employee provides or receives biological and chemical materials to or from anyone outside the university they must consult this office.


Per NIH policy, NOT-OD-09-155 which can be found here, Multi-principal investigator applications are eligible for continuous submission if one or more of the Program Directors/Principal Investigators (PD/PI) are eligible for continuous submission.

Arial, Helvetica, Palatino Linotype, or Georgia typeface, black color, and a size of 11 points or larger should be used. A symbol font may be used to insert Greek letters or special characters, but the font size requirement still applies. Find the NIH format specifications here.


CAS is an acronym for "Cost Accounting Standards." As of July 1, 1997, UK was required to comply with these standards. These include: Consistency in Estimating, Accumulating and Reporting Costs; Consistency in Allocating Cost Incurred for the Same Purpose; Accounting for Unallowable Costs; and Consistency in Using the Same Cost-Accounting Period. UK's Disclosure statement outlines how UK complies with the Cost Accounting Standards Board's cost accounting practices.

Additionally, UK must also comply with OMB Circular A-21, Cost Principles for Education Institutions.

You may hear of certain costs being referred to as "CAS items." A partial list are items like clerical support, office supplies, basic telephone service, computers, and space-related expenses. These items are difficult to accurately cost out on a project by project basis. Instead, these costs are reimbursed to an institution through a federally-negotiated indirect cost rate. In special circumstances, however, it is possible to direct charge a CAS item to a grant. In order to do so, you must make sure that the cost is justified and budgeted appropriately. If possible, include these costs in your original proposal submission. If that wasn’t done, then a budget revision request will need to be processed. OSPA provides some good resources on their website to assist in requesting a budget revision for this purpose, here.  Also, your CGO is an excellent resource as you are writing a CAS justification.
Per University definition, computer equipment costs $1000 or more.
Like many situations with sponsored projects, the answer is, it depends.

If the need for computer is known at the time of the proposal submission, then it should be included in the budget at that time. If your submission to NIH requires a detailed budget, include this as an equipment item and provide the necessary justification in your proposal. If it’s a modular submission, and there’s no need for the equipment justification in the proposal, include it in the detailed budget routed with the Internal Approval Form (IAF), along with a justification. Be sure to exclude the cost from the F&A calculation as appropriate.

If the grant is already awarded, and the need for computer equipment arises, you must first determine if there are funds available in the current budget to cover the costs. If yes, a budget revision on the WBS/account must be processed before the computer purchase is made. The request can be made using this form: http://www.uky.edu/eForms/forms/action.pdf. In particular, you must provide an explanation of the need for the computer in relation to the programmatic effectiveness of the project. Explain how the purchase will benefit the project. You should provide details on why the computer will be needed to meet the scientist objectives and that it will have a preponderance of use (75% or greater) on the project. Be specific. This will require a transfer of funds from another budget category, so you must also explain why funds are available in that other category, and explain how the project will still be accomplished with less funding in that budget line.

As computers are normally an indirect cost item, the budget revision will require Dean’s Office approval before it is forwarded to OSPA for processing. Once completed in your department, please send the budget revision form to your CGO. They’ll review it and provide guidance if further details are needed. They will also check to determine if the funds are available to make the requested transfer. They will obtain the required Dean’s approval and then will forward the request to your RA in OSPA.
The University provides a searchable database of externally funded sponsored projects known as SPIFi (Sponsored Project Information Files). Click here for website.
Also, the University’s Proposal Development Office provides an online service to help PI’s identify potential collaborators. Click here for website.
NSF provides several useful vehicles for this purpose via their website. There is a site for searching for funding opportunities (http://nsf.gov/funding/) by key word and program area. Also, upcoming deadlines can be viewed at this link: http://nsf.gov/funding/pgm_list.jsp?org=NSF&ord=date. Individuals can subscribe to a weekly announcement and preferences on announcements to be received can be provided (https://service.govdelivery.com/service/multi_subscribe.html?code=USNSF&custom_id=823).
Your CGO can assist with FastLane account set up.

Your College Grants Officer (CGO), or Research Administrator (RA) in the Office of Sponsored Projects Administration can set up a FastLane account.
The following information is needed to establish an account: Name; Email; Degree Type; Degree Year.
The CGO or RA will assign a temporary password. The PI can then login, and will receive immediate instructions on how to change the password.
Find your CGO here.

A PADR is a Project Account Data Record. PADRs are generated by the Office of Sponsored Projects Administration (OSPA) database. The first PADR is generated when a grant/sponsored project account is first established/set up. Additional PADRs are generated when the budget changes or other account attributes change. Special attention should be paid to the remarks section of the PADR for special notes and instructions from the sponsor and OSPA to the PI. A cost share sheet will be included if applicable. PADRs are sent via email to the PI, Co-Is, business officers, and the College Grant Officer (CGO).

The PADR has boxes numbered 1-18, which contain the following information.

1. WBS # and award status
2. MIS # (unique internal tracking number for OSPA)
3. Research Administrator (OSPA contact), phone, fax and email
4. Financial Administrator (Sponsored Projects Accounting (SPA) contact), phone, email
4a. CGO, phone, email
5. Project History (will provide previous WBS # if this is a new competing segment)
6. Sponsor
7. Sponsor ID #
8. Project Title
9. CFDA (Catalog of Federal Domestic Assistance) #, only applies to federal or federal flow-through funds
10. Responsible Unit – generally, the PI’s dept. # but could be different
11. PI name, department, email, phone
12. Project period – entire time frame of the project
13. Budget period – period of currently provided funding
14. Award type (cost reimbursement, fixed-price, etc.)
15. Indirect/ F&A rate applied
16. Budget information
17. Co-Investigators (names, department, phone, email)
18. Source of funds (new, carry-forward, project fees/other income)
19. Remarks—will provide short explanation of action completed with each PADR. Also includes all specific and general terms and conditions of the award as per the sponsor requirements.

Some formal process for research space evaluation is now common in many medical centers. In 2008, the College initiated a process of evaluating research space based on the methodology used by the AAMC. Given the current space constraints, there is a pressing need to facilitate the efforts of our most productive faculty. The process for performing this analysis was provided to the COM Council of Chairs in July 2009. The slide set for this presentation was provided to the Chair/Director of your academic unit and is also available on the COM website (click here). This process was also presented at the May 17 2010 College General Faculty meeting. This slide set may also be viewed on the COM APIP web site (click here).

The overall aim of the space management process is to ensure that we provide the best possible facilities for our most productive faculty. Furthermore, it will enable the equitable distribution of space that is based on a data driven process. The primary metric is the commonly used “$NASF.” This is calculated based on:

1. Expenditures on sponsored research grants thru the UK Research Foundation (UKRF) within a fiscal year. (This can differ considerably from awards, especially if F&A are included)

2. Research space assigned to a Department/Center. This information is derived from the eBARs system. Departments and Centers are asked to update this information each year at least annually.

If a Department or Center has a low $NASF, this will form the basis for a discussion with the leader Chair/Director of that unit to determine whether there is circumstance of the low $NASF that are appropriate, or whether the space is under used. The College will remain focused on providing a consistent evaluation of space so that allocations are matched to the needs of our researchers.

Federal regulation OMB Circular A-110 requires universities to "avoid purchasing unnecessary items." A scan of current University inventory is required before equipment costs can be budgeted and the purchase completed. You will need to work with your department’s administrative staff to complete the required screening via eBARS.

If the equipment is available on the UK campus, contact Plant Assets at (859) 257-8638 to identify the individual responsible for management of the equipment. After contacting Plant Assets, contact the equipment manager to verify that the equipment will be available for the amount of time that you will need it on your research project. If the equipment is available and access arrangements can be made, then you need to use the existing equipment for your research activities.

If you need equipment and the equipment is available on campus, but will not be available for the amount of time your research requires, or if the equipment is not available at UK, on the Internal Approval Form prior to submission of your proposal indicate “Yes” to the question “If yes, has University inventory been screened for availability of existing equipment”.

Please use the following decision tree (click here) to determine if your purchase is within the University’s equipment definition.

Contact your CGO’s for additional assistance.

The College provides a research website with an extensive amount of useful information – click here.

A good first place to start is to find the College Grants Officer for your unit. These individuals (click here) work for the College of Medicine and are available to assist you with most aspects of the pre-award process. Feel free to call or send them an email and introduce yourself. They are available to meet with you individually to discuss your proposal plans.

Various forms –both University and College-specific – are a required part of any external funding request. Refer to this link for guidance - click here.

The University’s Office of Sponsored Projects Administration also provides a useful website - click here.  In particular, the “Useful Proposal Information” page (click here) is invaluable as you complete your proposal application. 

Please note, the completed (final version) proposal must be received by the OSPA Research Administrator three (3) business days in advance of the sponsor’s deadline. Remember to take into account that the usual department and college approvals are required prior to submission. This is in effect for all proposals, paper or electronic.

If you have a subcontract/subaward in place on your sponsored project, a purchase order (PO) has been established to manage the payments on this agreement. You should have received a copy of this PO when it was set up. A cover letter with the PO details how to pay invoices received. Please click here to view the standard PO cover letter.

Please contact your CGO (click here) for assistance.

The University has a business procedure that addresses these situations – it can be found here. Just because the project takes place outside Lexington and/or away from the main campus doesn't mean it's "off-campus." It must meet two criteria: A portion of sponsored activity must be taking place in rented facilities and the project budget must include this rent cost, or the space must be provided at no cost to the University;  AND More than 50% of the effort for the project must be taking place in this rented space or no cost facility.

If you think you have a project that qualifies for this rate, it is important that you communicate with your CGO (see website here) prior to the proposal submission. OPSA must have an opportunity to review the appropriate supporting documentation (as explained in the business procedure noted above) at least 10 days prior to the proposal’s submission.

If the article is published, the data that supports it should be available to anyone. Related data that is not necessary to support the publication does not need to be provided to the requestor.
If there is intellectual property (IP) to protect, that should be done by the institution or investigator, following institutional rules and applicable IP laws. IP is best protected prior to publication.
Click here for link to UK Commercialization & Economic Development office.


A revised Internal Approval Form (IAF) is required when:
The budget decreases or increases by 25% or more.
There is a change in the cost share commitment.
There is a change in the split of enrichment funds.
There is a change in PI.
There is a change in the responsible unit for the project.
This list is not inclusive, other scenarios that would require a revised IAF. 
Please contact your CGO if you have questions about this or believe a revised  IAF is needed.

Following the close out of a fixed priced sponsored project (account number that starts with a 304xxxxxx), Sponsored Project Accounting (SPA) sends an email to the Office of Sponsored Projects Administration (OSPA) notifying the Research Administrator (RA) for the project that the residual process can begin. Attached to the email will be a financial report (from BW) of the expenditures. The RA will use this report to complete the right side of the “Fixed-Price Agreement Budget Form” from the grant file. The fixed-price agreement budget form was completed when the project was initiated and was included with the internal approval form.

There must be PI effort or the RA will ask the department/center for an explanation. Also, if it’s a clinical trial, if there are no patient care costs the department will have to explain. The RA will make sure fully allowable F&A is charged.

If the balance remaining exceeds 25% of the cash received, the RA will ask the department to provide a written explanation of the balance.
Whenever further information is needed from the department, they will have 30 days to respond. If deadlines aren’t met, the department may forfeit any claim to remaining residual funds.

Once OSPA has finished their review and completed the form, it will be sent to the department for PI signature. Once signed, the PI then returns it to OSPA, who sends it on to SPA for final processing. SPA prepares a journal voucher for the residual balance to transfer the funds from the grant account to the Provost office. From there -- provided the balance is over $1000 -- the Provost office, following Dean’s office approval, would transfer the residual back to the PI’s department/center.

If you have additional questions about this topic, please contact your College Grant Officer (CGO) here

Answer:  Other support includes all financial resources, whether Federal, non-Federal, commercial or organizational, available in direct support of an individual’s research endeavors, including, but not limited to, research grants, cooperative agreements, contracts, or organizational awards.  Other support does not include training awards, prizes, or gifts.

Other sponsors have their own requirements and you should refer to their guidelines to fulfill their request.

If you have additional questions about this topic, please contact your College Grant Officer (CGO) here

Answer:  The purchase of food from NIH grants is possible, but there are several items to consider.
Entertainment costs, such as food, are unallowable
If the supplies are not specifically allocable to the grant, they are considered general office supplies and should not be charged as a direct cost to the grant account.
Meals are allowable when (1) they are provided by a conference grant (for scientific meetings supported by the conference grant); (2) they are provided to subjects or patients under study provided that such charges are not duplicated in participant’s per diem or subsistence allowances, if any; and (3) such costs are specifically approved as part of the project activity in the NGA.
Note:  Recurring business meetings, such as staff meetings, are generally not considered meetings to disseminate technical information. 
Note: The College of Medicine requires the pre-authorization of purchases of food/meals from grants via the authorization form (here).  If you have additional questions about this policy, please contact your College Grant Officer (CGO) here

Answer: NIH defines the extension of some grants beyond the original expiration date as a no cost extension. The extension is one time and up to 12 months in increments of 3 month periods. The following criteria also have to be met:
No Additional Funds are required.
The project's originally approved scope will not change and any one of the following:
Additional time beyond the established expiration date is required to ensure adequate completion of the originally approved project.
Continuity of NIH grant support is required while a competing continuation is under review.
The extension is necessary to permit an orderly phase-out of a project that will not receive continued support.
Remember that funds remaining at the expiration of the grant is NOT, in itself, justification for an extension. Also note any additional extension beyond the one-time extension requires NIH prior approval.
Note: Not all NIH awards can be extended automatically via this process. If you have questions whether your award can be extended or if you would like to extend your award, please contact your College Grant Officer (CGO) here

Answer: The UK fiscal year runs July 1 to June 30. Certain university deadlines must be met as the end of the fiscal year approaches, even if your grant budget year differs from the university’s fiscal year (fiscal year 09-10 closing schedule is available here).
For example, reimbursements for travel during the period of June 1- June 15 must be submitted to Accounts Payable by June 25. You should work closely with your administrative staff to meet these university deadlines. 
Fiscal Year 2009-2010 Closing Schedule is available here.

Answer: Yes.  The Vice President for Research has set a deadline to receive final proposals three business days in advance of the sponsor deadline.   This deadline applies to both electronic and paper submissions.  You should contact your CGO well in advance of the three day deadline so that he/she can assist you.  The Office of Sponsored Projects Administration (OSPA) has a website to accept proposals here.

The version uploaded to the OSPA website should be completed, error-free and ready for submission.  .  (Find your CGO here)

Note:  UK Policy requires the completion of the Internal Approval Form (IAF) and financial conflict of interest form (COI) for all key personnel prior to proposal submission.  Please see the IAF instructions here.

Answer: UK policy about travel states the expenses shall be the most economical standard transportation available. With this institutional policy, we are not allowed to fly first class. See the UK policy here.  Further education from the DHHS office of research integrity about this topic is available here.

Answer: Per the University’s F&A Rate Agreement with the U.S. Department of Health and Human Services, (at this link), which is applicable to all federal and federal flow-through awards,  Modified Total Direct Costs shall exclude equipment, capital expenditures, charges for patient care, tuition, rental costs of  off-site facilities, scholarships and fellowships, as well as the portion of each subaward/subcontract in excess of $25,000. Certain sponsors have their own policies regarding F&A rates and exclusions.  Make sure to review these guidelines before you prepare your proposal budget. 
Additionally, CGOs are available to assist with specific questions or concerns.  Find your CGO here

Answer: Standard reports (also known as WBS ledgers or grant account ledgers) are available from SAP and BW. Units may present their reports in a format of their choosing on a monthly basis.  Understanding these reports is essential to both the administrative unit and the PI(s).  OSPA has developed specific administrative staff training courses (RATE classes) for assistance in all aspects of research administration.  The class information is available here.
PIs may choose to have direct access to the financial reports in SAP by completing three training requisite courses.  Registration for these classes is through the myUK function of SAP.
FI_GM_310 Grants Analysis
FI_GM_315 Grants Analysis Refresher
UK_100 IRIS Awareness and Navigation  
Additionally, CGOs are available to assist with specific questions or concerns.  Find your CGO here

Answer: Yes. As PI (Principal Investigator) you are responsible for insuring that only allowable costs related to your project are charged to the account (WBS element) set up to reflect the spending on your project. Further, you should receive a monthly report from your respective area administration with sufficient detail providing this information (also known as a ledger sheet). The basis of this report should be the information in the UK fiscal system SAP.

Answer: During the initial phase of discussion for a basic or clinical research study, a sponsor may ask an Investigator to enter into a non-disclosure agreement. These CDAs (Confidentiality Disclosure Agreement) are a legal contract between at least two parties which describes confidential material or information the parties wish to share with one another, but want to restrict access to by third parties. At the University of Kentucky, these agreements must be reviewed and executed by Intellectual Property Development within the Office for Commercialization and Economic Development. Contact information for that office can be found here. You can also discuss this and any other research related issue with your CGO (College Grant Officer).

Answer: The College of Medicine created a college calendar that is available to every department to post their events and see any college event. The calendar is here and available as an RSS Feed to which you can subscribe. Each department has a representative with permission to post events to the calendar. If your department is having trouble with posting its events to this calendar, please contact Steve Welch.

Answer: Per UK policy, an IAF (also known as an Internal Approval Form or Route Form) is to be completed (fully routed with all required signatures and provided to OSPA) before a proposal is submitted. This is necessary for compliance with NIH policies that require specific certifications by the PI and the authorized official of the submitting institution. If this certification is not completed prior to submission, the University is out of compliance. (Since NIH is the University’s largest funder, we have chosen policies for all submission that comply with their rules.)

Answer: Each faculty member involved in the project AND any other person who is responsible for the design, conduct or reporting of the research must complete a COI form.

Answer:  When the award is received, in most cases, the University will first reduce the direct costs by the amount of F&A costs allowed by the sponsor and apply that amount to F&A.  If the F&A was calculated incorrectly in the proposal on subcontracts, or an expense was included as though exempt from F&A but which is not – for example, listing 250 items, costing $100 each, as one $25,000 piece of equipment – the department/center will be responsible for the F&A costs.  Please contact your College Grant Officer (CGO) with any questions.