Mount Mary University Policies and Regulations

Copyrights/Publications, Software, Patents, and Inventions
In accordance with the custom of institutions of higher learning, the right of first publication shall be the property of the author unless the copyrightable material resulted from an assisted or assigned project, or unless the terms of the grant or contract specify otherwise.

Discoveries or inventions that, in the judgment of the Principal Investigator, appear to be patentable must be brought to the attention of the University, which will determine whether and to what extent the University has a property interest in the discovery or invention. In addition, federal patent law requires that all employees file with the University an agreement that they will report any inventions made during the course of a federally funded project and assign rights to the institution. View Mount Mary University's copyright policy.

Classified Research
The University does not accept funding of research projects that (1) restrict publication of the results of the project or (2) prohibit the free exchange of ideas. However, it is recognized that contracts and grants may legitimately vest proprietary rights in products or by-products and that the investigator may be required to protect these rights against disclosure.

The practice of many sponsors is to require that results and reports be submitted to the sponsors for their information, review and comment before publication. This practice is viewed by the University as being normal and legitimate provided that such comment time does not prevent publication for more than sixty (60) days. Contractual language that provides for sponsor review and approval shall not be accepted by Mount Mary University.

University Affiliation for Project Director
In view of the substantial responsibility inherent in the Principal Investigator's position, the named Principal Investigator/Project Director should be a full-time member of the faculty or professional staff, or be a full-time administrative officer of the University. In some cases a faculty member under a percentage employment agreement or temporary employee whose appointment is the term of their grant period of performance may be supported in the role of PI/PD as suits the University's mission.

Intergovernmental Personnel Assignment Agreements
Under the Intergovernmental Personnel Act (IPA) of 1970, University faculty and staff may arrange to work with government agencies for a temporary period, or federal government employees may arrange to work at the University. Since such assignments may incur commitments and liability on the part of the University, IPA's must be signed by an authorized University official.

To insure accuracy and completeness, all IPA's must be processed and submitted through the Development Office to the appropriate agency. The IPA should be forwarded with a Mount Mary University Fundraising Initiation Form, and be signed by the appropriate department, college, and University officials with an acknowledgment of any cost-sharing commitments that may be required.

Personnel Expenses
As a recipient of federal funds, the University must comply with the Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) as well as other federal requirements for certifying effort expended on sponsored awards. MMU requires all individuals who receive federal sponsored funding to comply with institutional policies and sponsoring agency regulations regarding the proposing, charging, and reporting of effort on those awards.

MMU faculty and staff are expected to charge their time to sponsored awards commensurate with the committed effort expended on all activities they perform. All individuals who receive any compensation from a federal award or a non-federal award where the non-federal sponsor requires effort reporting (“Sponsored Projects”) are required to certify their effort. This process ensures that salaries and wages are properly expended and that actual effort is consistent with the committed and budgeted effort.

Policy Statement
A. Effort reports shall reasonably reflect the percentage distribution of effort expended by MMU employees involved in Sponsored Projects. The Effort Report must represent, in percentages totaling 100%, a reasonable estimate of an employee’s effort for the period being reported. These reports shall reasonably reflect the activity for which the employee is compensated and shall encompass all activities on an integrated basis. “Effort” includes all research, teaching, administration, service, and any other activity for which an individual received compensation from MMU. Note: Section 200.430(c) states, “It is recognized that teaching, research, service, and administration are often inextricably intermingled in an academic setting. When recording salaries and wages charged to Federal awards for IHEs [Institutions of Higher Education], a precise assessment of factors that contribute to costs is therefore not always feasible, nor is it expected.”

B. Each employee whose time is partially or fully committed to a federally Sponsored Project is required to complete reporting forms and provide them to the lead grant coordinator. The coordinator will individually approve each form and submit the completed reporting forms to the Business Office electronically. Depending on the effort of commitment to the project and appointment at MMU, an effort reporting form will be submitted either quarterly or monthly. Reporting is required regardless of whether such time is paid by the sponsor, or is an unpaid contribution, i.e. cost share match. Committed cost sharing must be included in effort reports.

C. Reporting is required regardless of whether such time is paid by the sponsor, or is an unpaid contribution, i.e. cost share match. Committed cost sharing must be included in effort reports. Faculty and Administration employees are paid on a monthly basis and will be required to complete the Effort Report and certification documentation quarterly. Students and staff employees are paid on a semi-monthly basis and will also be required to submit Effort reporting documentation quarterly.

D. MMU uses an “after-the-fact” effort reporting system to certify that salaries charged or cost-shared to Sponsored Projects are reasonable and consistent with the work performed. This indicates that the distribution of salaries and wages will be supported by activity reports signed by the employee and certified by a responsible person with suitable means of verification that the work was performed, generally the Principal Investigator (PI), at the end of the specified reporting periods. Effort reports shall be incorporated into the records of MMU and retained in accordance with the sponsor regulations and/or MMU’s Records Retention schedule. These documents will be filed in the Business Office with the official grant documentation.

E. The federal government can impose severe penalties and funding disallowances as a result of missing, inaccurate, incomplete, or untimely effort reporting. MMU expects that PIs will complete Effort Reports in a timely manner. Consequences to not doing so may include, at the discretion of the administration, withholding submission of a new grant proposal and/or or withholding compensation on effort expended. MMU also reserves the right to charge cost disallowances on Sponsored Projects resulting from the PI’s failure to submit appropriate Effort Reports to the departmental operating account.

Allowable Costs
All expenditures incurred under NSF cost-reimbursable grants are governed by federal regulations and must conform to NSF policies, grant special provisions and grantee internal policies. In general, NSF grantees should ensure that all costs claimed under NSF grants are allowable, allocable, reasonable and necessary, as defined by 2 CFR §200, Subpart E - Cost Principles, NSF policy, and/or the program solicitation. For-profit organizations and small businesses should continue to use the Federal Acquisition Regulations (FAR) Subpart 31.2 to determine the types of costs that may be considered allowable uses of federal grant funds. Both 2 CFR §200.400 and FAR Subpart 31.2 detail the types of costs that cannot be incurred by federal awards, either as direct or indirect costs. A few examples of these costs are alcoholic beverages, certain types of advertising, entertainment/amusement, bad debts, contributions and donations, fines, and penalties.

Participant Support
Participant Mount Mary University (MMU) defines participant support as the cost of transportation, per diem, stipends (scholarships), and other related costs for participants or trainees (but not employees) in association with conferences, meetings, symposia, training activities and workshops. Participant support may not be used by grantees for other categories of expenses without the specific, prior written approval. MMU accounts for participant support costs separately in its accounting system. This is typically accomplished through the use of separate general ledger accounts. MMU will document participant support costs and record these costs separately in its accounting system.

Sponsored Programs
View Mount Mary University's policy on sponsored programs