Accept funding with discipline. Protect the integrity of the work.

Proposal and Signature Authority

Researchers and program leaders may develop proposals, but only authorized institutional representatives should submit applications, negotiate terms, accept awards, or sign sponsor agreements.

No person should commit Institute funds, facilities, personnel, cost sharing, intellectual property, data access, publication rights, or future obligations without appropriate review and approval.

Pre-Award Review

Before submission, proposed awards should be reviewed for:

• Mission and program alignment
• Eligibility and sponsor requirements
• Realistic staffing, schedule, and deliverables
• Facilities, equipment, technology, and data needs
• Human participant, animal, environmental, export, or security review
• Intellectual-property, publication, confidentiality, and licensing terms
• Financial capacity, cash-flow timing, matching, and cost sharing

Budgets, Indirect Costs, and Cost Sharing

Budgets should reflect the full expected cost of performing the work, including salaries, benefits, supplies, travel, equipment, subawards, facilities, security, administration, reporting, and closeout.

Voluntary cost sharing, waived indirect costs, or unfunded institutional commitments should be approved before submission because they use unrestricted resources.

Award Acceptance and Account Setup

Awards should be reviewed for final terms before acceptance. Material differences from the proposal may require revised budget, scope, staffing, legal review, or board approval.

No spending should begin until the award, budget, project period, responsible personnel, financial account, and compliance requirements are established, unless a documented pre-award exception is approved.

Research Independence and Publication

Sponsor agreements should preserve the Institute’s ability to conduct work honestly, report limitations, correct errors, and publish valid findings subject to reasonable confidentiality, patent, security, and review periods.

Funding sources and material sponsor relationships should be disclosed in publications and public communications where appropriate.

Allowable Costs and Financial Control

Award expenses should be necessary, reasonable, allocable to the project, consistently treated, within the approved period, and supported by documentation.

• Use approved purchasing and reimbursement procedures
• Document personnel effort and payroll allocation
• Track equipment and sponsor-owned property
• Review budget variances and unspent balances
• Exclude personal, unsupported, or unrelated costs
• Correct mischarges promptly

Subawards, Contractors, and Collaborators

The Institute should distinguish a subrecipient carrying out part of a sponsored program from a vendor providing goods or services.

Subrecipients should be evaluated for capability, compliance, financial systems, conflicts, risk, reporting, audit status, and ability to meet sponsor terms.

Changes to Scope, Budget, Personnel, or Schedule

Changes requiring sponsor or institutional approval should be identified before implementation.

These may include changes in principal investigator, key personnel, scope, participant population, budget category, equipment, subaward, project period, location, or intellectual-property terms.

Programmatic, Financial, and Compliance Reporting

Reports should be complete, accurate, timely, supported by records, and reviewed by responsible personnel.

Reporting may include progress, milestones, participant data, publications, inventions, equipment, financial activity, cost sharing, audit findings, incidents, or final deliverables.

Closeout, Audit, and Disallowed Costs

At closeout, the Institute should reconcile the account, confirm deliverables, submit final reports, resolve property and data obligations, collect receivables, and preserve required records.

Costs rejected by a sponsor, auditor, or regulator may need to be transferred to an appropriate unrestricted account, repaid, disputed, or recovered from a responsible party when permitted and justified.

Framework date: July 2026