Policies, Guidelines, and Recommendations

In order to ensure that research is conducted by those who have the requisite training and education, as well as an appropriate relationship with the University, the University generally will only support proposals for projects that are already in progress when the PI holds an appointment by the University as an assistant professor, associate professor, professor, and/or distinguished professor, or is a full-time staff member of the University. Other members of the University community must obtain an exemption to University policy in order to serve as a PI. Exemptions require the special approval of the Provost, Vice Provost, and the Dean of the relevant school.

To facilitate the exemption review and approval process, the proposed PI must submit a photocopy of the AUTHORIZATION FOR EXTERNAL FUNDING FORM, the abstract, his/her curriculum vitae (CV), and a completed PRINCIPAL INVESTIGATOR ELIGIBILITY FORM, signed by the proposed PI's department chairperson.

RGFR will not submit a grant application or, as in some instances, request transfer of an award from another institution to the University until an exemption request is approved by those mentioned above.

For further information regarding eligibility, please contact RGFR.

The PI must allow adequate time prior to submission for RGFR's review and preparation of application materials. Accordingly, RGFR must receive all finalized materials at least one (1) calendar week prior to the sponsor's deadline. For example, if a proposal is due on a Wednesday, RGFR must receive the finalized application package by the previous Wednesday. Upon receipt of the final application package, RGFR will conduct necessary compliance checks and route the proposal for approval and subsequent submission. Materials received after the internal administrative deadline will not be submitted for consideration.

Before a proposal may be submitted for any sponsored project, the Principal Investigator (PI), working in conjunction with RGFR, must obtain authorization through RGFR's routing system. Authorizations for proposals submitted through RGFR are required from the PI, and generally include the Department Chairperson (if applicable), the Dean or Director of the School, the Major Area Budget Manager, the Associate Provost for Research, the Vice Provost, and the Provost.

Before an award may be accepted for any sponsored project, the Principal Investigator (PI), working in conjunction with RGFR, must complete, sign and obtain all other required authorizing signatures on the AUTHORIZATION FOR EXTERNAL FUNDING form. Authorizations for awards submitted through RGFR are required from the PI, and generally include the Department Chairperson (if applicable), the Dean or Director of the School, the Major Area Budget Manager, the Associate Provost for Research, the Vice Provost, and the Provost.

Policies on Conflict of Interest in Research Overview

Additional Links:

• Policy on PHS/NIH Conflict of Interest in Research
• Policy on Conflict of Interest in Research

Responsible Conduct of Research Training Instructions and Overview

Summer Salary Overview

During the performance of the project, the PI may realize that modifications to the budget are necessary. Many sponsors are flexible with respect to how project funds are expended, and generally allow budget changes that are necessary to carry out the project. PIs must know the specific requirements for their awards and, if necessary, request prior approval for budget modifications. Rebudgeting to include vertebrate animal care costs or human subject costs is not permitted without prior IACUC or IRB approval. The RGFR Compliance Monitoring Officer is available via telephone at (310) 506-6996 to provide further information to PIs regarding any matters related to budget modifications.

RGFR, with support from the Controller's Office, General Counsel's Office, and University Auditing, has implemented a Cost Transfer Policy, effective immediately. A cost transfer is a movement of costs associated with a transaction between two chartstrings (CFS), of which at least one must be a federally sponsored project. A Cost Transfer Justification Form will be used each and every time that charges need to be corrected BETWEEN federally sponsored projects. Charges will need to be corrected via a transfer FROM a federally sponsored project to another CFS, or changes need to be corrected via a transfer TO a federally sponsored project from another CFS.

Cost Sharing Overview

The PI must plan and manage project work in an efficient manner such that the project will be finished within the timeframe and funds authorized. Despite a PI's best efforts, he/she must sometimes seek additional time to complete the project, with or without additional funds.

A no-cost extension is a request to extend the termination date of a project without any additional funds.

Allowability of No-Cost Extension Requests

Whether a no-cost extension will be permitted depends upon the sponsor. Some federal sponsors allow the institution to internally approve the extension, while other sponsors require that a formal request for additional time be submitted for their approval.

No-Cost Extension Effort Level

PIs must continue to devote the same level of effort as in the period preceding the extension unless prior approval for the reduction has been received.

Carry Forward of Funds 

Relatedly, the carrying forward of funds that are unspent at the end of a multi-year project is dealt with differently by different sponsors.

No-Cost Extension Contacts

For any questions, information, or assistance regarding the topics above, RGFR should be consulted for the specific requirements of the award and the sponsor.

When a PI will be absent from a project for three (3) or more consecutive months or reduce effort by 25% or more, the PI must seek prior approval from the University and the sponsor. In the event of such and absence or effort reduction, the sponsor may require a change in the PI. PIs may also need to be added or removed from a project under other scenarios. Please contact RGFR's Compliance Monitoring Officer via telephone at (310) 506-6996 for further information.

Sponsors' record retention requirements (usually three [3] years for federal sponsors) usually commence on the date that the last financial report is submitted to the sponsor. However, for certain sponsors (NSF for example), the record retention obligations continue until three years from the date that the PI submits the technical report. Notwithstanding sponsor record retention requirements, which vary from sponsor to sponsor, PIs must also review and conform to the University Record Management Policy and University Records Retention Schedule. For questions regarding record retention requirements, please contact the RGFR Compliance Monitoring Officer, available via telephone at (310) 506-6996.

If a sponsor seeks an audit of an award, the sponsor or its designated representative must perform the audit or otherwise arrange for the audit to be conducted at its own expense. When an audit is sought, the PI must notify RGFR immediately if the audit is not sought through RGFR. The PI's notice to RGFR should include information regarding when and how (i.e. through whom) the sponsor plans to conduct the audit. The PI must also provide to RGFR reasonable assistance throughout the audit process. If costs charged to the audited sponsored project are disallowed in the course of the audit, those costs will be borne by the PI's department and/or school. RGFR will coordinate with the department to prepare and submit a revised final invoice and/or Financial Status Report if required as the result of the audit.

Separate from any audit initiated by the sponsor, a certified public accounting firm performs an annual financial audit of the University's accounting records. The annual audit includes a review of sponsored project accounts funded by federal agencies or institutions, and a determination of the University's compliance with federal regulations. This audit is conducted in accordance with OMB Circular A-133: Audits of States, Local Governments, and Nonprofit Organizations and satisfies most federal audit requirements. RGFR works closely with General Accounting, which serves as the University representative to coordinate this audit, to respond to all inquiries regarding University sponsored project accounts posed by the accounting firm during the course of the audit. However, the PI's department may be asked to assist with the audit as deemed necessary and appropriate.

Finally, in addition to the above-described audits, University Auditing Services may conduct internal audits or consults. When such audits or consults are conducted, departments may be called upon to participate in some manner. Internal audits or consults serve numerous purposes. More detailed information regarding these types of audits or consults is discussed at Section 15, entitled Auditing Services, of the University's Financial Policies.

Preparation for the closeout of an award should begin immediately upon receiving the award. The PI must personally review the Notice of Award Memorandum, the accompanying agreement, and the budget to ensure accuracy and future compliance.

At a time before the termination date of the award, attention should be given to a complete review of the account in preparation for closeout. The review should involve the collaboration of the PI and his/her Major Area Budget Manager.

After completion of the award period, the PI will work with RGFR and their budget manager to complete all closeout requirements on behalf of the sponsor and Pepperdine University.

Subrecipient/Subaward Policy Overview

Capital Equipment Administration Policy Overview

The Federal Government prohibits expending federal funds on goods and/or services from any entity suspended or debarred from doing business with the federal government. 

Procurement

A procurement contract is considered a “covered transaction” if it is for an amount equal to or greater than $25,000. Procurement of goods and/or services of a covered transaction with federal funds from a supplier or contractor shall be checked for debarment and suspension before purchasing and/or awarding a contract or subaward. 

To ensure that Pepperdine University is not doing business with vendors who have been suspended or debarred from doing business with the Federal government, the department/school should reach out to RGFR to conduct a debarment and suspension check before creating a purchase order or making a payment. Results from the SAM.gov search shall be made part of the purchase order/contract documentation.

The department/school may also verify debarment and suspension by obtaining certification from the entity, or adding a clause or condition to the covered transaction with the entity. The department/school must provide the certification, clause, or condition to RGFR for review and documentation.

University Copyright & Patent Policy

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Copyright Ownership

Copyrightable materials which are developed by University personnel within the course of employment or which are developed with the use of University funds or facilities shall be the property of the University. Written works or software created by faculty members in discipline-related areas will be accepted from this general rule and will be viewed by the University as the property of the author. The University shall, however, be entitled to use of the software without payment of copyright royalties or fees of any kind for use by the University for its purposes.

"Copyrightable materials" include the following types of materials: written works such as books, journal articles, texts, glossaries, bibliographies, study guides, laboratory manuals, syllabuses, tests and proposals; lectures, musical or dramatic compositions and unpublished scripts; films, filmstrips, charts, transparencies, and other visual aids; video and audio tapes; live video or audio broadcasts; computer programs; pictorial, graphic and sculptural works; sound recordings; and other similar materials.

Patent Ownership

Every invention or discovery or part thereof that results from research or other activities carried out at the University or that is developed with the aid of the University's facilities, staff, or through funds administered by the University, shall be the property of the University. As a condition of employment or enrollment and attendance, every invention or discovery shall be assigned to the University.

Exceptional Circumstances — Appeal Procedure

There may be instances in which University personnel create materials or inventions which would be University property under the terms of this policy but which the creator believes were created under unique circumstances deserving of special consideration.

In such instances, personnel may submit a written petition explaining the exceptional circumstances to the Vice President over his or her department. The appropriate Vice President will review the petition and issue a written determination regarding ownership rights in the material. If this determination is unsatisfactory to the petitioning party, final appeal may be made to the office of the President of the University.