Policies & Procedures
Conflict of Interest
Conflict of Interest
- AR 7:2 Research Conflict of Interest and Financial Disclosure Policy
- AR 7:9 Institutional Conflicts of Interest Involving Research
- AR 3:9 Consulting and Other Overload Employment
- GR XIV Ethical Principles and Code of Conduct
- KRS 164.390
Federal Regulations, Policy & Guidance on Financial Conflicts of Interest
Internal Proposal Receipt Deadline
To support the success of UK’s research enterprise, Office of Sponsored Projects Administration (OSPA) staff work collaboratively with you, as a Principal Investigator, and others across campus to provide client-centered professional support and administrative expertise in sponsor requirements, budget development and proposal submission. OSPA is committed to the timely submission of complete, accurate and fully compliant proposals.
Over the last several months with input from Associate Deans for Research, OSPA has been exploring how to ensure the best delivery of services and facilitate submission of the highest quality proposals with the highest probability of success. We recognize you spend a great deal of time and effort preparing proposals and are committed to helping lessen the risk of a missed deadline or rejected proposal. To that end, OSPA is putting into effect a new submission deadline for sponsored project proposals to external funders. Starting on October 8, 2019, a complete and final proposal, accompanied by a fully approved Internal Approval Form (IAF), must be received by the Research Administrator (RA) in OSPA at least three (3) business days prior to the sponsor’s deadline. The new 3-day deadline supports the timely submission of error-free, compliant proposals and facilitates discussions with your RA and others after review of the proposal so any necessary revisions or corrections can be made prior to the sponsor’s deadline.
The new proposal deadline goes into effect after the NIH October 5th deadline to allow sufficient time for you and your department to make any corresponding internal adjustments to proposals, instructions or deadlines. Please note that colleges may impose additional deadlines or other requirements for review and approval of proposals.
OSPA is committed to assisting you and providing the maximum level of customer service to ensure proposal review and submission go smoothly and, at its core, this new proposal deadline policy is intended to ensure both.
Electronic Internal Approval Form (eIAF) Deadlines
IAFs must be received by OSPA at least three business days prior to the sponsor's published deadline. Some colleges have additional eIAF Internal Deadlines:
NOTE: guidelines refer to business days
- Agriculture - 5 days (includes OSPA's 3 day rule)
- A&S - 7 days for a single college/ 14 days for an inter-college proposal (includes OSPA's 3 day rule)
- B&E - 5 days (includes OSPA's 3 day rule)
- Communications - 7 days for a single college/ 14 days for an inter-college proposal (includes OSPA's 3 day rule)
- Education - 10 days (includes OSPA's 3 day rule)
- Engineering - 10 days (in advance of OSPA's 3 day rule)
- Health Sciences - 7 days (in advance of OSPA's 3 day rule)
- Medicine - 6 days (includes OSPA's 3 day rule)
- Nursing - 14 days (includes OSPA's 3 day rule)
- Pharmacy - 10 days (includes OSPA's 3 day rule)
- Social Work - 4 days (includes OSPA's 3 day rule)
For more information about the eIAF, see the Electronic Resources page.
Foreign Government Influence in University Research
Effective May 25, 2021, NIH requires the following:
- Supporting documentation, which includes copies of contracts, grants or any other agreement specific to senior/key personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support. If the contracts, grants or other agreements are not in English, recipients must provide translated copies.
- Immediate notification of undisclosed Other Support. When a recipient organization discovers that a PI or other Senior/Key personnel on an active NIH grant failed to disclose Other Support information outside of Just-in-Time or the RPPR, as applicable, the recipient must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.
For more information about these requirements, see NOT-OD-21-073.
The current regulatory landscape informing the research enterprise includes serious growing concerns by the US Government concerning inappropriate influence by foreign entities over federally funded research. As a result, academic research institutions have a heightened interest in understanding the affiliations and dealings faculty members may have with foreign governments and entities. The University of Kentucky encourages international collaboration, and recognizes it is important for investigators to be transparent about their foreign relationships and activities.
Federal agencies have issued statements expressing growing concerns over the potential for foreign influence in the following areas:
- failure by some researchers to disclose substantial contributions of resources from other organizations, including foreign governments;
- diversion of intellectual property to foreign entities;
- sharing of confidential information by peer reviewers with others, including in some instances with foreign entities, or otherwise attempting to influence funding decisions.
Additional information on the current regulatory landscape and guidance for actions that faculty should take in light of the focused national attention on foreign influence is available on the Guidance Regarding Foreign Influence in University Research page.
Industry Sponsored Agreements
The University of Kentucky is committed to building on its history of successful collaborations by providing a cooperative and supportive environment that benefits our research faculty, staff and students, and our sponsors.
Please use this Industry Sponsored Agreements guide for information on common issues involved in research agreements.
As required by 2 CFR §200.113, all faculty, staff, and students of the University of Kentucky must disclose, in a timely manner, all violations of Federal law potentially affecting a Federal award or sub-award, including without limitation any criminal, civil or administrative proceeding that could lead (or could have led to had the matter not been resolved by consent or compromise with an acknowledgment of fault) to a conviction, a finding of fault or liability, or a payment of a fine or penalty, reimbursement, restitution, or damages.
All potential violations must be reported to the Executive Director of the Office of Sponsored Projects Administration (OSPA).
All such disclosures will be reviewed by the appropriate University offices (e.g., OSPA, Office of Research Integrity, Research Administrative & Fiscal Affairs, Research Financial Services, Office of Legal Counsel, etc.) and, when warranted, reported to the relevant Federal awarding agency, pass-through entity, or other parties. Failure to make a required disclosure may result in any number of significant remedies, including without limitation suspension or debarment.
Excerpt: 2CFR 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements For Federal Awards § 200.307 Program Income
(a) General. Non-Federal entities are encouraged to earn income to defray program costs where appropriate.
(b) Cost of generating program income. If authorized by Federal regulations or the Federal award, costs incidental to the generation of program income may be deducted from gross income to determine program income, provided these costs have not been charged to the Federal award.
(c) Governmental revenues. Taxes, special assessments, levies, fines, and other such revenues raised by a non-Federal entity are not program income unless the revenues are specifically identified in the Federal award or Federal awarding agency regulations as program income.
(d) Property. Proceeds from the sale of real property or equipment are not program income; such proceeds will be handled in accordance with the requirements of Subpart D—Post Federal Award Requirements of this part, Property Standards § 200.311 Real property and § 200.313 Equipment, or as specifically identified in Federal statutes, regulations, or the terms and conditions of the Federal award.
(e) Use of program income. If the Federal awarding agency does not specify in its regulations or the terms and conditions of the Federal award, or give prior approval for how program income is to be used, paragraph (e)(1) of this section must apply. For Federal awards made to IHEs and nonprofit research institutions, if the Federal awarding agency does not specify in its regulations or the terms and conditions of the Federal award how program income is to be used, paragraph (e)(2) of this section must apply. In specifying alternatives to paragraphs (e)(1) and (2) of this section, the Federal awarding agency may distinguish between income earned by the recipient and income earned by subrecipients and between the sources, kinds, or amounts of income. When the Federal awarding agency authorizes the approaches in paragraphs (e)(2) and (3) of this section, program income in excess of any amounts specified must also be deducted from expenditures.
(1) Deduction. Ordinarily program income must be deducted from total allowable costs to determine the net allowable costs. Program income must be used for current costs unless the Federal awarding agency authorizes otherwise. Program income that the non-Federal entity did not anticipate at the time of the Federal award must be used to reduce the Federal award and non-Federal entity contributions rather than to increase the funds committed to the project.
(2) Addition. With prior approval of the Federal awarding agency, program income may be added to the Federal award by the Federal agency and the non-Federal entity. The program income must be used for the purposes and under the conditions of the Federal award.
(3) Cost sharing or matching. With prior approval of the Federal awarding agency, program income may be used to meet the cost sharing or matching requirement of the Federal award. The amount of the Federal award remains the same.
(f) Income after the period of performance. There are no Federal requirements governing the disposition of income earned after the end of the period of performance for the Federal award, unless the Federal awarding agency regulations or the terms and conditions of the Federal award provide otherwise. The Federal awarding agency may negotiate agreements with recipients regarding appropriate uses of income earned after the period of performance as part of the grant closeout process. See also § 200.343 Closeout.
Roles and Responsibilities
The Roles and Responsibilities Matrix outlines expectations throughout the life of a sponsored project.
Please note : The Principal Investigator is ultimately responsible for the proposal and should review the final version prior to submission.