Policies & Compliance

Below are frequently referenced policies regarding Seattle University and Federal policies relating to research and stewardship of sponsored funding. If you don't find guidance for an issue or question you need addressed, please contact OSP.

Acceptance of Online Agreement Request

Does your funder require acceptance of an agreement or amendment through their unique online portal? Please note that all agreements require signature by the Authorized Organizational Representative. In order to facilitate these unique online portals, please follow the below procedure and use the Request for Online Acceptance Form:

Allegations of Research Misconduct Policy

Seattle University is committed to supporting a research community that operates at the highest level of integrity. This commitment extends not only to supporting research that is conducted with high, technical quality but with the collegial, professional and ethical processes with which research is performed. As part of this commitment it is necessary to clarify actions that are not acceptable (e.g. constitute Research Misconduct) and the procedures that will allow both the unveiling of Research Misconduct and adequate safeguards against the potential damage caused by inappropriate accusations. With the goal of promoting research integrity, this policy defines (a) “Research Misconduct,” (b) the steps for making an allegation of Research Misconduct, (c) the steps for examining and acting on such allegations and (d) the efforts the University will make to foster responsible conduct and provide training intended to prevent Research Misconduct. For more information, please review the below policy: 

If research miscoduct is suspected, please review the below procedure for reporting misconduct allegations:

For Responsible Conduct of Research training, please continue down this webpage.

Biosafety and Chemical Hygiene

If your sponsored project involves biosafety concerns, hazardous materials, or chemical hygiene matters or policies related to them, please direct any questions relating to the Chemical Hygiene and Biosafety Office, Sheila Lockwood. Phone: (206) 220-8273

Effort Certification

The verficiation of compensation for effort expended on sponsored agreements is a requirement in accordance with the provisions of the Office of Management and Budget (OMB) Uniform Guidance. Seattle University has established policies and procedures to ensure that all employees compensated through sponsored funding are certifying effort to provide a reasonable basis for distributing salary charges among major university functions (e.g., instruction, organized research, sponsored projects, other institutional activities). The policy and related documents are available below:

Export Controls

For any questions regarding Export Controls please contact the OSP Director, Rebecca McColl

Financial Conflict of Interest Disclosure Policy

Seattle University and its employees are committed to the principle of free, open, and objective inquiry in the conduct of its teaching, research, and service missions. In the fulfillment of these missions, it is natural that opportunities arise for its faculty and staff to develop relationships with external entities and to explore commercial activities. The University encourages such endeavors as they enhance personal competency and benefit the community and the institution.

These interactions, however, create the potential for financial conflicts of interest where an individual's financial or personal considerations may affect or appear to affect their SU activities related to externally sponsored programs. The existence of a real or apparent financial conflict does not necessarily mean that the activity at issue must be avoided or discontinued. A financial conflict of interest depends on the situation, and not on the character or actions of the individual.

It is through disclosure to Seattle University of significant financial interests related to an Investigator's research or sponsored program that such activities may be reviewed and, if warranted, managed. The identification of significant financial interests does not necessarily imply any improper activities or motives on the part of the Investigator. This policy establishes that disclosure, review, and management process.

As part of OSP's responsibility of mitigating institutional risk, we require all grant proposers and active PIs to complete a Financial Conflict of Interest (FCOI) disclosure form on an annual basis. 

Fringe Benefits & Indirects

All grant budgets with salary included (excludes student wages) will be charged fringe benefits at a rate of 28.4%.

Additionally, all sponsored projects are subject to indirect charges. Indirect charges are the unallocable costs to the institution to facilitate sponsored projects including facilities (buildings, utilities, maintenance) and administration (administrative staff, SFS, payroll, OSP, legal counsel, etc. and minor office supplies, copying, etc.). 

  • Federally negotiated on campus indirect rate = 42% modified total direct costs (MTDC)
  • Federally negotiated off campus indirect rate = 17% of MTDC
    • The off campus rate only applies if more than 50% of your research takes place off campus (i.e. field work, an external lab)
  • MTDC includes salaries and wages, fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward
  • MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000.
  • Privately funded grants are charged 15% of total direct costs, or as otherwise noted or negotiated with each sponsor. 

Gift vs. Sponsored Projects

Gifts made to SU or your department are voluntary contributions by an external donor, without expectations of any tangible benefits. Gifts do not require a specific work plan, deliverables, or financial reporting though they may be donated for a particular cause (i.e. Undergraduate research, etc.).

Sponsored Projects are an exchange between SU and an external entity. Characteristics of a sponsored projects includes: specific scope of work or research plan, committed effort, expected deliverables, programmatic and financial reporting requirements, penalization of non-performance, return of unused funds, and/or a signed agreement with terms and conditions of intangible property.

The following forms can help you determine if your external funding is a grant or gift, and how best to manage it.

Grant Faculty Salary Compensation Policy

For guidelines regarding including faculty salary within your grant budget, please review the Sponsored Projects Compensation Policy:

Additionally, our Budget Development webpage and Developing a Grant Proposal Budget Powerpoint slides can assist in incorporating salary into a grant proposal budget.

Intellectual Property

The below policies can assist in the case that your research project results in intellectual property (IP). If your project is funded by a sponsored project, please also consult your grant agreement for additional IP provisions or contact your Sponsored Research Officer for additional guidance.

Institutional Review Board and Human Subjects Research

The Institutional Review Board is a separate, yet complementary, entity from the Office of Research Services & Sponsored Projects. If your project includes work with human subjects, please review the IRB website and connect with the faculty who run the IRB:  the IRB administrator, Andrea McDowell, or chair, Michelle DuBois.  They encourage pre-submission consultations to assist you with details of the process that apply to your research project.

Participant Support

Participant support expenses are the direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to, or on behalf of, participants or trainees (but not employees) in connection with conferences or training projects. Please review the full Participant Support policy for correctly classifying expenses for this purpose.

Program Income

Program income is gross income earned by the University that is directly generated by a grant supported activity or earned as a result of an award. Does your sponsored project receive revenue? If so, please review the following policy:

Responsible Conduct of Research

OSP is responsible for ensuring SU is compliant with federal standards of responsible conduct of research and maintaining institutional risk.

The National Science Foundation (NSF) requires that institutions applying for or receiving grants have in place training and oversight in the responsible conduct of research for students who will be supported by an NSF grant in the conduct of research.

As Seattle University continues to build its research infrastructure to support the scholarly excellence of its faculty and students we are establishing policies and procedures that are consistent with the practices of other universities and that also bring us into compliance with federal regulations. While the NSF requirement applies only to students funded by NSF grants we require RCR training for all faculty, students, and staff who engage in research of any kind.

Seattle University subscribes to CITI, the recognized national standard for research ethics training. For instructions on setting up a user account for CITI and access to their website please see the links below.

Signature Authority

All sponsored project proposals (including letters of intent or pre-proposals) and all agreements with external entitities require signature by SU's Authorized Organizational Representative (AOR) prior to submission of a proposal or acceptance of an award. The below policy discusses this policy in greater detail. If your sponsor requires agreement acceptance via an online portal, please see "Acceptance of an Online Agreement Request" at the top of this webpage.

Sponsor-funded Equipment Disposal

An essential component of the administration of sponsored research at Seattle University is the responsible stewardship of assets used in support of the University’s research. The Controller’s Office, the Office of Sponsored Projects (OSP), the dean’s offices, and the principal investigator (PI) or the department/center must work cooperatively to assure that the University properly follows Federal administrative requirements, acquisition regulations and agency or sponsorspecific conditions governing the disposition of Federal property. 

If you need to dispose of sponsor-funded equipmnet, please review the below manual:

Subrecipient vs. Contractor

Is someone outside of SU necessary to complete your project? If so, are they a subrecipient or a contractor? Use the checklist below to determine and document your relationship with the third party, or simply review the characteristics for an informal assessment.

Characteristics of a:

  • Subrecipient:
    • Performance is measured in relation to whether objectives of project was met
    • Has responsibility for programmatic decision-making
  • Contractor:
    • Provides the goods or services within normal business operations
    • Provides similar goods or services to many different purchasers
    • Normally operates in a competitive environment
    • Provides goods or services that are ancillary to the sponsored program

If your third party is deemed a subrecipient, please contact OSP. All subaward agreements must be reviewed and executed by the OSP. Subawards are a
legally binding agreement between Seattle University and the subrecipient. Please be advised that Seattle University has limited signatory authority. Directors, Faculty, Staff, Deans, Project Directors, Principal Investigators, and/or other individuals are not authorized to enter into a legally binding agreement on behalf of Seattle University. That authority lies with the President, Provost, Associate Provosts, Executive Vice President, Vice President of Finance, Associate Vice President of Finance, and/or the Controller. Agreements for external funds must obtain review and permission/authorization from the OSP, University Counsel, and the Office of the Provost or the Office of the Executive Vice President. Please be advised that a subaward that is not reviewed and/or executed by the OSP may be deemed null and void upon  receipt.

  • Additionally, all subreceipients are subject to subrecipient monitoring guidelines:

Subrecipient Monitoring Guidelines

Seattle University acknowledges that in order to perform portions of externally funded research projects, it is imperative to have subrecipients in order to further the research endeavors of our faculty and staff member’s externally funded projects. To support our faculty and staff at Seattle University, the Office of Sponsored Projects (OSP) has established the following guidelines when conducting business with a subrecipient, as Seattle University is required to monitor the activities of all our subrecipients.

As a general rule, the Principal Investigator (PI) is ultimately responsible for the overall project goals and financial management of each project. The OSP is responsible for assisting faculty and staff in ensuring that the University’s subrecipient monitoring procedures are compliant with federal, state, and local regulations as well as sponsor requirements and university policy.

External auditors and/or prime sponsors may, at their discretion, request documentation on subrecipient monitoring. Therefore, we strongly encourage the PI to maintain all records of contact, reports, site visits, etc. The OSP will also maintain records on agreements, audits, etc.

Volunteer Research Assistants

Do you plan to have a volunteer (either SU student or external party) assist with your research project? If so, please complete the below agreement and submit to your dean's office prior to beginning their volunteer service. 

Whistleblower Protections

As a recipient of federal funds, Seattle University must comply with the latest whistleblower protection statutes that went into effect on July 1, 2013. This policy applies to all employees, subcontractors, and subgrantees on federal grants and contracts from July 1, 2013 to January 1, 2017.