UW-Extension uses designated appropriations for the extramural project grant or project grants, see (Appendix 2). Coding is based on state statute that links extramural funds to federal or non-federal sponsors. Federal funds are those that are received directly or indirectly from the federal government. All other funds are non-federal, by definition.

133 - Non-Federal Gifts, Grants, Contracts/Agreements

Extramural funds received from a non-federal source that do not involve flow-through federal funds may be financially administered within a Fund 133 account. Fund 133 awards are presented monthly to the UW Board of Regents by UW System Administration.

144 - Federal Gifts, Grants, Contracts/Agreements

Extramural funds received from agencies, and flow-through federal funds from other agencies should be financially administered within a Fund 144 account unless:

1. They involve federal Smith Lever funding (assigned to Fund 143).
2. They clearly meet a formally established criterion that permits deposit into another fund (see 104 PR section).

Fund 144 awards are presented monthly to the UW Board of Regents by UW System Administration

143 - Federal Smith Lever Funds

Federal Smith Lever funds, whether received directly from USDA or indirectly from another institution, should be financially administered within a Fund 143 project grant. Fund 143 awards are not presented to UW Board of Regents.

104 - Program Revenue (PR)

Departments with a PR (Fund 132) requirement included as part of their Fund 104 "general purpose operation (GPO) pool" may deposit extramural support monies as PR. If the funding source is federal, generally a Fund 144 account should be assigned. The fund 104/132 appropriations can be used for the expenditure and receipt of federal funds only if:

1. The federal funds are received for payment of fees to attend a UWEX sponsored program.
2. The federal flow-through funds (not to exceed $5,000) are received by a UWEX non-service department from another UW institution.
3. The federal funds are received as a non-renewable, fixed-price purchase order with no contractual signature required and no required segregation of funds.

104 - General Purpose Revenue (GPR)

Occasionally, UWEX departments funded primarily with GPR funds that do not have a PR requirement may receive a fee for incidental services provided to an external agency. Under these circumstances, the fee income can be deposited as an external sales credit against the department's 104 GPR fund.

161/162 - Trust Funds

Many gifts can be placed in either a Fund 133 gift account or a Fund 161/162 trust fund. If placed in a trust fund, the department will benefit from the income earned while the earnings on Fund 133 gift funds are retained by the State of Wisconsin. In order to be deposited into a trust fund, gifts must meet all the following criteria:



• Funds shall be in excess of $2,500.
  
  
• Funds will be on deposit for at least one year.

Trust funds can also be used for temporary depositing of Fund 133 receipts that do not meet the "gift" criteria, under the following circumstances:

• The amount must exceed $50,000.
  
  
• The expenditure of the 133 funds is not expected to begin for at least six months after the initial receipts are recorded.

The Wisconsin Public Radio/Television annual Community Service Grants received from the Corporation for Public Broadcasting (CPB) are examples of this procedure. Receipts from CPB are received approximately one year before expenditures against them begin. The temporary deposit of these receipts in Fund 161/162 trust funds allows the investment income to be retained by Wisconsin Public Radio/Television.

128 - Auxiliary Enterprises (Special Service Units)

Generally, funds received for goods/services provided to an external agency by UWEX unit budgeted primarily under Fund 128 should be deposited as program revenue to the appropriate Fund 128 coding. Likewise, receipts for services provided to other UW departments should generally be deposited as an internal sales credit. A Fund 133 or 144 account should be established only if the award requires the establishment of a segregated account.

Each Divisional Business Office is responsible for reviewing proposal budgets for accuracy. An important part of the process is helping the PDs in their budget preparation. This involves: making sure the proposal format meets the sponsoring agencies' format; the budget includes the correct indirect costs and fringe rates; cost sharing requirements are met; sub-recipients/sub-contractors are clearly delineated; and for federally sponsored projects, the budget scheme is selected.

Proposal Format

When the funding agency does not provide a specific format, the following is a suggested outline:

• Cover page
• Background - Provide a brief description of your organization and department. The purpose of this section is to inform the granting agency of your particular expertise in the area. Basically, you are "selling" your institution and making it evident that you are the best qualified.
• Client Group - Identify the individuals, agencies, organizations, or institutions the project will be working with. Explain how the clientele have been involved in the development of the proposal. Letters from the clientele indicating support of the problem, the program, and the objectives are very helpful and should be included in the appendices whenever possible.
• Objectives - The specific goals of the project should be spelled out in detail and should relate directly to the problem indicated and the client group described above. It is important that you limit your objectives to those which are tangible and measurable within the resources and time period of the proposal.
• Procedures - Indicate very specifically what you are going to do. Your work plan should be detailed and in a chronological sequence. A timetable is also recommended. Staffing needs should be indicated. Be sure to allow sufficient start-up time to enable recruiting for new positions. Explain the involvement of other organizations cooperating on the project.
• Evaluation - Explain carefully how you plan to evaluate the results to determine the effectiveness of the project. It is important that this section be fully developed so that you may establish the necessary record keeping providing the information needed for proper evaluation.
• Supporting Documentation - Include any documentation which may support your proposal such as:
  
  
  • Vita (resumes) of key personnel involved.
  • Support letters from the proposed clientele or organizations.
  • Support letters from cooperating individuals or agencies.
  • A brochure or statement explaining the qualifications or facilities of your department or University of Wisconsin-Extension in general which are unique and/or necessary for the successful implementation of the proposal.
  • If the project is large and complex, an organizational and/or functional chart may be included.
  • A job description for the various staffing positions may also be included as an appendix.
    
    
• Budget - After the above steps have been completed in draft form, a draft budget should also be prepared by the PD and sent with the narrative to the respective Division office.

General Comments on Proposal Preparation:

• Double spacing normally allows for easier and quicker reading.
• Number and date all pages for easy reference.
• On large proposals, an index or table of contents is helpful.
• Elaborate artwork, photographs, binders, etc., are discouraged unless absolutely necessary in the proposal.
• Cost sharing or matching costs should not be included in the proposal unless required by the funding source. If costs sharing is required, it is important that the PD work with the Divisional office in developing the total budget.

Proposal Budget

The proposal budget is developed with the help of the PD's Divisional Budget Office. The PD should submit a budget that will meet the needs of the project scope. It is the responsibility of the Divisional Budget office to ensure that the budget does not have any mathematical errors. For projects that are sponsored by federal or federal flow through funds, the budget format must be in a form that fits into one of the Extension budget schemes. The various budget schemes may be found in the divisional budget offices. This will enable computer terminal on-line comparison of expenditures to budget by budget categories, and report generation. If the proposed budget contains salaries, coordinate salary and fringe benefit rates with your Division Personnel Office.

The draft budget should be detailed and categorized as follows:

PERSONNEL:
Salaries and Wages
Faculty & Academic Staff (by name/title)	XXX
Classified Staff	XXX
LTE's	XXX
Research Assistants, Pre-Doctoral Fellows & Trainees	XXX
Project, Program & Teaching Asst & Research Assoc	XXX
Post-Doctoral Fellows & Trainees	XXX
Ad Hoc Program Specialists & Undergrad Assts	XXX
Student Hourly	XXX
Subtotal Salaries and Wages			XXX
Fringe Benefits
Faculty & Academic Staff (by name/title)	XXX
Classified Staff	XXX
LTE's	XXX
Research Assistants, Pre-Doctoral Fellows & Trainees	XXX
Project, Program & Teaching Asst & Research Assoc	XXX
Post-Doctoral Fellows & Trainees	XXX
Ad Hoc Program Specialists & Undergrad Assts	XXX
Student Hourly	XXX
Subtotal Fringe Benefits		XXX
Total Personnel		XXX
CONSULTANT/CONTRACTUAL FEES:		XXX
TRAVEL:
Transportation	XXX
Meals & Lodging	XXX
Total Travel		XXX
EQUIPMENT (ITEMS OVER $5,000):		XXX
SUPPLIES AND SERVICES:		XXX
SUB CONTRACTS:		XXX
TOTAL DIRECT COSTS:			XXX
INDIRECT COSTS:			XXX
TOTAL BUDGET:			XXX

Fringe Benefits Rates

Wisconsin Statutes Section 20.865 requires the fringe benefits applicable to salaries paid for extramural funds shall be charged to such funds. Thus, all budgets submitted for extramural support must contain an item for all associated fringe benefit costs of the University. (See current rates on OES web site at http://www.uwex.edu/gea/business-services/extramural/).

The Fringe benefit rates are provided by UW-System on an annual basis. These rates are based on actual fringe benefit packages that include the University's contribution to retirement, health and life insurance, social security, unemployment and worker's compensation insurance, and income continuation insurance. Different fringe rates exist for different classes of employees depending on the level of the University's contribution. Rates are adjusted annually to reflect adjustments in charges and changes in benefits. Therefore, care should be taken to determine you are using the current rates.

A fringe benefit rate will be charged to each project grant automatically and will be based on the present rate and the actual salaries paid in a given month. If the salary amount is increased, the amount of fringe benefits will be increased as well.

Cost Sharing/Matching

When a sponsoring agency requires cost sharing/matching be provided by UWEX it is important that:

• UWEX does not exceed the required cost sharing/matching amount (exceptions require justification) and
  
  
• Cost elements identified as cost sharing/matching can be readily documented on official University financial records.
  
  
• All cost elements identified as cost sharing/matching and third party cost sharing/matching (in-kind) can be readily documented as provided and expended within the project period of the award.
  
  

Whenever possible, staff salaries charged to non-Federal funds, associated fringe benefits, related indirect costs and unreimbursed indirect costs should be used to meet cost sharing/matching requirements. The use of salary costs for cost sharing/matching is desirable due to the ease of certification/documentation provided by the university PAR System.

Third party cost sharing/matching (in-kind) can be used if acceptable to the sponsoring agency and the contributed costs are necessary and allowable under UWEX guidelines to accomplish program activities. It is important that a contractual officer from the third party will provides written assurance as to the amount and type of contributions that the third party will donate. In addition, the third party should ensure that its contributions are supported by the same record keeping requirements that the third party would use to certify cost sharing/matching against federal grants received directly.

Indirect Costs

Indirect costs are real costs that provide reimbursement for actual institutional expenses that support extramural activities but cannot be directly charged to a grant or contract. The indirect cost results from shared services such as libraries, physical plant operation and maintenance, utility costs, general departmental and sponsored project administrative expenses, and depreciation or use allowance for buildings and equipment. Wherever possible, indirect costs must be recovered. The Divisional Budget Office must instruct the PD, which rate to apply according to the Extension Policy on Indirect Cost Recovery (Appendix 1). Exceptions must be justified by the PD, approved by the Dean and Chancellor or Chancellor's designee.

Gifts

Extramural support that qualifies as a gift (meets all gift criteria) is not subject to the assessment of indirect costs.

Federal Agencies

All grant and contract application to and awards from federal agencies (except as provided otherwise by federal regulations) must include indirect costs at the agreed upon rate set forth in the University/Federal Cognizant Audit Agency (DHHS) negotiation agreement. A reduced indirect cost rate can be accepted if a particular federal program has a regulatory-imposed restriction on indirect cost recovery. Written documentation should be provided in this instance.

Federal "Pass Through" Funds

Federal "pass-through" funds from Wisconsin State agencies, counties, municipalities, or local governmental units should include indirect costs budgeted at the appropriate rates (Appendix 1).

A footnote should be included that states:

"If funded from state GPR funds or other non-Federal funds that do not provide for indirect cost reimbursement, indirect costs should be excluded from the award."

Federal "pass-through" funds from all other agencies require indirect cost reimbursement at the fully negotiated rate unless:

• The sponsoring agency has a published lower rate; and
• The lower rate is consistently applied as an agency-wide policy.

NonFederal Funds

Non-Federal funds from Wisconsin State Agencies, counties, municipalities, or local governmental units are subject to their established indirect cost rate. The indirect cost recovery is not required under the following circumstances:

• The grants/contracts are funded by state GPR funds.
  
  
• The grants/contracts are funded by non-Federal funds received from Wisconsin Counties in partnership with Cooperative Extension or received from the Educational Communication Board in partnership with Wisconsin Public Radio/Television.
  
  

  Non-Federal funds from other nonprofit agencies require indirect cost reimbursement at the fully negotiated rate unless:

• The agency has a published lower rate, and
  
  
• The lower rate is consistently applied as an agency-wide policy.

RSP maintains a Nonfederal Indirect Cost Exceptions index of sponsors and rates that are approved. The current list is available on the RSP Web site at http//www.wisc.edu/grad/gs/services/indcost/.

Non-Federal funds from sanctioned support groups are exempt from indirect cost reimbursement. The following organizations qualify as sanctioned support groups:

1. County-based support organizations (i.e. 4-H Foundations)
   
   
2. Wisconsin Public Broadcasting Foundation
   
   
3. Friends of WHA-TV, Inc.
   
   
4. Wisconsin Public Radio Association
   
   
5. University of Wisconsin Foundation
   
   
6. Wisconsin Rural Leadership Program

Private Sector (For-Profit Entities)

Extramural support received from a for-profit entity but does not qualify as a gift requires indirect cost reimbursement at the fully negotiated rate. Exceptions to this policy must be approved by the UWEX Chancellor or his/her authorized designee. Normally consultation, special training programs, etc. performed by UWEX staff for direct benefits of the private sector should not be subsidized by other UWEX funds. Reimbursement rates should reflect this requirement.

Fees for Tuition, Royalties, or Incidental Services

Fees charged for tuition, royalties or incidental services do not normally involve indirect cost reimbursement.

Tuition Remission is a true cost which the hiring unit has the responsibility to pay.

The inclusion or exclusion of indirect costs cannot be used as a bargaining point to gain a competitive advantage to secure extramural support. When joint projects are anticipated by several institutions of the UW System, indirect costs should be included and reimbursed at each institution's appropriate negotiated rate. When one institution receives extramural support and then subcontracts to or purchases services from a second, the first shall reimburse the second's indirect costs at the rate received by the first or the negotiated rate of the second whichever is less monetarily.

Exceptions to any of the above policies require the approval of the UWEX Chancellor or his/her authorized designee.

Sub-Contracts

Some proposals are submitted with a collaborative effort with another institution or organization. It is understood that this entity will perform a portion of the scope of the project and a subcontract must be used to transfer funds. A subcontract is broadly defined as a grant from one institution to another institution or individual in support of a project in which the programmatic activity is carried out through a cooperative arrangement between or among the grantee institution (UW-Extension) and one or more other institutions or individuals which are separate legal entities, administratively independent from the grantee. The involvement of the non-grantee institution or individual is that of actually performing a portion of the scope of work as opposed to simply providing a routine service or consulting activity.

In order to satisfy the requirements of the State Bureau of Procurement for exemption of subcontracts from the procurement process the PD must identify subcontractor by name in their extramural grant applications. The total cost should be included in the University's budget as a line item under the appropriate budget category, customarily identified as either "Subcontracts", "Contractual Services", or "Other Direct Costs". The institutionally approved subcontractor's scope of work and detailed budget is to be appended to the University's budget.

The Divisional Budget Office should review the budget of the sub-contractor for mathematical errors and appropriateness of budgeted items. When the award is made, the Divisional Budget and Finance Office will set up the sub-contract and process it through appropriate channels.

Shared Grants

The Shared Grant Transfer of Extramural Funds applies only when the transfer of funds is related to joint participation by two or more UW Institutions in the "Scope of Work" of an extramural project. A Shared Grant relationship may be determined at the time the formal grant proposal is submitted (preferred), or subsequent to the award being issued. In either instance, both institutions should have knowledge of the transaction.

For Shared Grant transactions the following applies:

• Both institutions should establish a 144 or 133 account as appropriate;
• The institution named as the primary recipient is responsible for all reporting requirements of the granting agency and for reporting the full amount of the award to the Board of Regents;
• The primary recipient shall reimburse the subrecipient's indirect costs at the subrecipient's negotiated rate. If the shared grant was not contemplated at the time the proposal was submitted, and the primary recipient's indirect cost rate is lower than that of the subrecipient, the subrecipient must determine if they will accept the project at the rate received by the primary recipient;
• To ensure that revenues and expenditures are not double counted with respect to the UW System as a whole, class code 3301 (Legacy) or account code 3910 (Shared Financial System) should be used by the primary recipient institution to process payment to the subrecipient. The subrecipient should deposit the payment using revenue code 9910. It is important to follow these procedures so offsetting amounts can be identified by UW-System Administration.
• An "Agreement to Transfer Extramural Funds Between UW Institutions" (Appendix 14) should be completed by the primary recipient institution.

  or

• A "Modification to Agreement to Transfer Extramural Funds Between UW Institutions" (Appendix 15) should be completed by the primary recipient institution.

Transfers of Extramural Funds that do not involve "Scope of Work" transactions should use one of the other Inter-Institutional Financial Transactions Categories covered by this Policy Paper. The Institutions will not set up a 144 or 133 account and there will normally be no pass-through of indirect cost reimbursement. The Institutions should account for the receipt as a sale or sales credit in accordance with FAP - Internal Services Chargeback (F24) depending on the appropriation from which services are being provided. This will ensure that there is no double counting of revenues and expenditures with respect to the UW System as a whole except as appropriate under generally accepted accounting principles for colleges and universities.

Normally the distinction between joint participation in a sponsored project and a sales transaction should be clear. In all cases, the nature of the agreement and not the amount involved should be the determining factor. However, in cases where the distinction may not be clear, the amount involved may be a weighing factor as follows:

• Agreements involving more than $5,000 should be examined with particular care to ensure that joint projects are not inadvertently treated as sales and that the administrative requirements imposed by the extramural sponsor are met by all parties to the agreement.
• If the amount of the agreement is less than $5,000, the additional administrative cost associated with administering joint projects may weight the classification decision in favor of a sales treatment.

SUBMISSION OF PROPOSALS & AWARDS

Preparation, Review & Routing of Transmittal Form

All UWEX proposals for Extramural Support must be processed for appropriate internal administration review and approvals with a Transmittal Form (Appendix 3). The Transmittal Form is an internal document used to obtain these approvals. The transmittal form is used as the basic source document for fund set up and monthly reporting to the Board of Regents through the ESIS system. Information on the Transmittal Form is also used in the review of proposals and when considering institution issues such as space requirements.

Transmittal Forms and their attached proposals, contracts, agreements are reviewed at the institutional level. Beyond the technical review of the detail contained in proposals, proposals are looked at to note issues of institutional concern. Proposals occasionally may raise issues of institutional mission; the investment of state funds when cost sharing is involved, cross-divisional program coordination, competition with the private sector and appropriateness. When such issues are noted proposals are discussed with divisional representatives.

The Review Process

The responsibilities in the preparation, review and submission of all extramural proposals and agreements involving UWEX are:

The department/unit chair shall:

1. Review the proposal for mission-relatedness.
   
   
2. Review the proposal for form, the use of the correct signature blocks, to assure that faculty, academic staff and support staff time commitments are reasonable and compatible with department workloads, present and planned.
   
   
3. Determine that the percentages of time and salaries are accurate.
   
   
4. Agree that the space, facility, and service requirements are within department's present or planned resources capability.
   
   
5. Identify new FTE requirements and approvals.
   
   
6. Check to insure that the Catalog of Federal Domestic Assistance(CFDA) number is provided for all Federal/Federal pass through agency proposals/awards unless exempted in writing by the Federal agency. http://whitehouse.gov/omb/grants/index.html
   
   
7. Assure that the proper number of copies is provided to the Dean's office for further processing.
   
   
8. Assure that the proposal is in compliance with Federal Financial Disclosure Regulations per UW-Extension Business Services Policy & Procedures Document #12 (Appendix 9).

After review the department/unit chair will sign the transmittal form and forward to the division dean or director.

The division dean, director or authorized designee shall review the proposal for completeness, compatibility with mission and intent. The following areas should be considered in the review process:

1. Facilities and equipment availability should be confirmed or needs outlined. Requirements for modification, reassignment, rental, remodeling or addition of facilities and equipment should be coordinated with the facilities management representative.
   
   
2. The budget should be complete, accurate and compatible with the narrative. Minimally the budget should break out salary, fringe benefit, supply and expense, and capital lines. The salary lines should be highly descriptive with entries for names, titles, project time, rates of pay and totals.
   
   
3. Unless waived or exempt, indirect costs must be stated. The divisional budget office should verify the policy applicable to the project.
   
   
4. Source of funds (federal or non-federal).
   
   
5. Cost sharing or matching monies are available if required. Their sources should be identified.
   
   
6. The proposal should fit with annual and long-range plans.
   
   
7. The Transmittal Form should be accurate and complete. The PD identified on the Transmittal Form should actually be the person who is going to be directly responsible for the project and meet the standards previously outlined in the document.
   
   
8. The number of proposal copies sent to the UWEX Budget Office should be sufficient to meet sponsoring agency's requirements plus one for Extension's Office of Extramural Support.

After review the department/unit chair will sign the transmittal form and send to the UWEX Office of Extramural Support.

The UWEX Office of Extramural Support will:

1. Review the proposal for completeness and for compatibility with appropriate UWEX plans, policies and regulations.
   
   
2. Check budgets for correctness.
   
   
3. Ensure all contract language is acceptable to the Board of Regents/UW-Extension.
   
   
4. Ensure that all required signatures have been obtained before signing the transmittal form for UWEX and the Division will receive a copy.

Timely processing of extramural support proposals is important. In general, extramural proposals must provide time for the full review and approval of proposals before their due date at the funding agency. Divisions should allow 10 working days for institutional review and for submittal and turn-around by the Office of Extramural support. The Dean's/Director's office should sign the Transmittal Forms being submitted.

All proposals are to be submitted on behalf of the Board of Regents of the University of Wisconsin System. The Chancellor's Office and/or authorized designee are the only offices authorized to sign on behalf of the Board of Regents of the University of Wisconsin System.

The Office of Extramural Support with a standard transmittal letter will submit the proposal to the funding agency via first class mail service unless otherwise requested.

Informal Proposal Submission

If an agency deadline does not allow sufficient time for formal submission of a proposal, the following steps can be taken:

• Check with the funding agency on their policy regarding the acceptance of informal proposals.
• Secure the approval of the Divisional Business Office.
• Contact the Divisional Business Office before finalizing the proposal and provide their staff with a draft of the budget and other related materials for review.
• Send the proposal directly to the funding agency with a cover letter (cc: the Divisional Business Office) which stipulates that formal submission of the proposal will be forthcoming.
• Submit at least three copies of the proposal through UWEX administrative channels with a Transmittal Form.

It should be understood that direct submission of proposals to the funding agency by staff should not be followed as a standard operating procedure.

Proposals submitted directly by staff who do not follow the steps outlined above may require changes and modifications which result in the funding agency receiving two different proposals for the same project. This could lead to a great deal of confusion and place the department or staff member in an embarrassing position.

Special Handling Issues

Items that require special handling include:

• Proposals that will involve other campuses of the University of Wisconsin System and for which UWEX is the proposed prime grantee must have written endorsement from an authorized official of the other campus.
• In proposals that involve staff members from university campuses, it should be determined whether the staff members will be on a part-of-load basis or an overload basis. Again, this should be cleared with the campus involved.
• It is strongly recommended that the proposed subcontractor be identified by name in the proposal. If possible, the subcontractor's scope of work and detailed budget should be appended to the proposal budget. Following these steps provide clarification that the services to be performed by the named subcontractor are being provided on a sole source (non-competitive) basis and therefore is exempt from the procurement process.

Project/Grant Number in Advance of Award

Occasionally a project/grant number is needed before receipt of a fully executed award document (Appendix 4). It should be used:

• Instead of charging costs to another source of funding which will have to be cost-transferred later; (note: cost transfers in the Shared Financial System are to be kept at the absolute minimum due to the complexity of the process).
  
  
• When there is an absolute need for the project to begin prior to receipt of an award document; and
  
  
• There are assurances from the sponsoring agency that the award start date will cover any costs charged to the project/grant.

It may not be used to establish Multiple Donor, UW Foundation or any other discretionary gift account; exceptions require extensive justification and approval of the UW Extension Chancellor or designee. A Transmittal Form, all pre-award clearances and cost sharing associated with the project (if applicable) must be on file at The Office of Extramural Support before an project/grant number can be assigned. The Project/Grant Number in Advance of Award form needs to be routed through the Dean's/Director's Office or designee and then to the UWEX Office of Extramural Support.

ACCEPTANCE OF AWARDS

All award documents (gifts, grants, contracts, agreements, etc.) require formal processing within the University of Wisconsin System. Awards, received directly by UW-Extension departments that are not in response to a formal proposal submission, must be processed through regular administrative channels with a completed UW-Extension Transmittal form (Appendix 3). Generally, sponsoring agencies will send awards resulting from formal proposals (i.e. submitted with a Transmittal form) directly to the UW Extension Office of Extramural Support. The primary responsibility for administrative and fiscal review of all awards rests with the UW Extension Office of Extramural Support staff.

Review of Terms and Conditions

Review of program content or program deliverable subject matter is the primary responsibility of the PD. Staff with an appropriate level of expertise in this area must review fiscal and administrative terms and conditions of all awards. Of primary concern are provisions concerning the following areas:

• Publication Restrictions
• Patents/Copyrights
• Liability and Insurance Requirements
• Disputes and Applicable Law
• Termination
• Budgets
• Invoice Submission and Reporting Requirements

  Publication Restrictions

  Any restrictions on University staff rights to release information or to publish any data, writings, or material resulting from extramurally funded projects is generally unacceptable. As a public institution UW-Extension has to protect it's right to publish knowledge gained from extramurally funded activity. the following is an example of acceptable wording:

  "As a public institution, the University and its employees have the right, at their discretion, to release information or to publish any data, writings, or material resulting from extramurally funded projects. The University will furnish the SPONSOR with a copy of any proposed publication in advance of the proposed publication date and grant the SPONSOR thirty (30) days for review and comment. Within this period, the SPONSOR may request the University, in writing, to delay such publication for a maximum of an additional sixty (60) days. However, the University does have a responsibility to maintain confidentiality over any proprietary information designated in writing by the SPONSOR."

  Patents and Copyrights

  The University requires participants in extramurally supported projects to comply with the provisions of any award received from an external sponsor. Furthermore, staff must cooperate in assuring that the sponsor's rights in intellectual property are fully protected.

  Federal law allows the University to have ownership in any copyrights and patents resulting from federally funded activity. Generally the federal sponsoring agency will reserve a royalty-free, nonexclusive and irrevocable right to reproduce and authorize others to use the work for Government purposes.

  Federal

  Federal law allows the University to have ownership in any copyrights and patents resulting from federally funded activity. Generally the federal sponsoring agency will reserve a royalty-free, nonexclusive and irrevocable right to reproduce others to use the work for Government purposes.

  UW-Extension proposed policies require project staff, when funded by federal funds, to turn over rights to intellectual property to the WiSys Technology Foundation (WiSys). Under WiSys policies/procedures a percentage of income generated by patents/copyrights intellectual property is shared within the UW-Extension community, i.e. Project Directors, Departments, etc.

  Non-Federal

  Intellectual Property resulting from any non-federal extramural funding is subject to the provisions of any agreement between the University and the sponsor regarding the rights in inventions, patents and copyrights. Absent any sponsor restrictions, project staff have complete rights to any intellectual property resulting from non-federal extramural funding.

  The following is an example of acceptable wording for awards received from non-federal sponsors:

  "The University and the SPONSOR each warrant that all materials each has furnished under this agreement are its own material or material which they have obtained the patent/copyright or permission to use the patent/copyright for the purpose of this agreement. Written copies of patent/copyright clearances may be required by either party."

  Related information can be found in UW System GAPP No. 27 "Ownership, Use and Control of Copyrightable Instructional Materials."

  Intellectual Property resulting from any non-federal extramural funding sponsor (a "Sponsor") and federal funding is intermixed with that Sponsor funding, the federal rules govern, and the intellectual property must be taken to WiSys.

  Liability and Insurance Requirements

  The State of Wisconsin and consequently the University as an agency of the State is self-funded for liability (both public and property). Since this is statutory indemnification, there is no liability policy as such that can extend protection to the sponsor of extramural funds. Therefore, any sponsor requirements that the University maintains specific insurance coverage, add the sponsor as an additional insured, etc. must be deleted. In addition, the University cannot accept any clause that requires the University to indemnify or defend the sponsor. The following is acceptable alternative wording:

  "The Board of Regents of the University of Wisconsin System agrees to hold harmless (insert sponsor), its officers, agents and employees from any and all liability, including claims, demands, losses, costs, damages and expenses of every kind and description (including death), or damages to persons or property arising out of or in connection with or occurring during the course of this agreement where such liability is founded upon and grows out of the acts or omissions of any of the officers, employees or agents of the University of Wisconsin System while acting within the scope of their employment where protection is afforded by sec. 893.82 and 89546(1), Wis. Stats."

  Under certain circumstances, it is necessary for the University to negotiate mutually acceptable liability wording with officials of the sponsoring agency.

  Disputes and Applicable Law

  For most awards the laws of the State of Wisconsin should be substituted for any other state. If a sponsor will not accept changing to the laws of the State of Wisconsin there is substitute wording that the University can offer.

  Termination

  Contracts and agreements generally should contain a termination clause providing the process to be followed if either party desires to end their contractual arrangement. The following is an example of acceptable termination wording:

  "This contract/agreement may be terminated in whole or in part in writing by either party provided that no such termination may be effected unless the other party is given not less than thirty (30) days written notice of intent to terminate, and an opportunity for consultation with the terminating party prior to termination. Final payment will be adjusted to reflect actual work completed plus non-cancelable commitments incurred in the performance of the project and not yet paid for."

  Budgets

  Budgets specified in award documents should be reviewed by the Office of Extramural Support in cooperation with the Divisional Business Office and Project Director to determine if they are adequate to support the requirements of the program/project and are formatted in an acceptable budget scheme. If the award is in response to a proposal, the award budget should be checked for responsiveness to the proposal budget.

  Invoice Submission and Reporting Requirements

  Invoice and financial reporting requirements imposed by the sponsoring agency should be reviewed by the Divisional Office to determine if they are realistic and do not impose a significant administrative burden on the University. Otherwise, The Office of Extramural Support determines the invoicing frequency.

  Invoicing should be frequent enough to allow a reasonable cash flow to the University, but not so frequent that it causes an undue administrative burden. Quarterly (three months) invoicing is fairly standard and is generally sufficient for University requirements. For projects with very large budgets, invoicing should be allowed on a more frequent basis. Awards received directly from Federal agencies usually have an electronic cash draw down procedure that can be used to meet University cash needs as they arise.

  For non-Federal agencies, financial reporting is usually included as part of the invoice. Federal agencies generally require invoicing/electronic draws and the submission of financial reports to be separate processes.

  Invoicing and/or financial reporting requirements should also be reviewed to assure that they do not contain any unusual or special features. It is standard University policy to report expenditures by major budget category. Detailed expenditure reporting by line item or a requirement to provide copies of source documents (invoices, payroll registers, etc.) is not acceptable.

  Award subject matter related to program deliverables, i.e. narrative reports, should be reviewed and approved by the PD.

Negotiations with Sponsoring Agency

If it becomes necessary to negotiate administrative or fiscal terms and conditions of an award document, this should be negotiated by the staff in Office of Extramural Support.

Negotiations that involve program content and or program deliverables are the responsibility of the PD or appropriate department or divisional staff.

Cost Sharing Information Forms

Federal award budgets must be reviewed to determine whether UW-Extension is required to document project expenditures. It is University policy, that whenever possible, institutional cost sharing should be documented, by assigning a portion of the salaries of staff who will be involved in the project, to non-federal funding sources. This is accomplished by completing a Cost-Sharing Information Sheet (Appendix 5) for each staff member who will be providing effort towards the project funded by institutional non-federal funds. This data is entered into ESIS. During the project, PARS will be generated to document non-federal (cost sharing) effort in support of the federally funded project. The actual cost sharing consists of the staff member's PAR certified salary plus related fringe benefits and indirect costs.

Although documentation of salary effort is the preferred method for providing mandatory cost sharing, special arrangements may occasionally be necessary. Before the federal award can be formally accepted, the method for documenting non-salary cost sharing must be clarified. If a portion of the cost sharing is to be provided by another UW institution or external organization, clear evidence of their acceptance of this responsibility must be on record.

Signature Authority

All award documents (grants, contracts, agreements, etc.) that require a University signature must be signed by a University official authorized to sign on behalf of the Board of Regents of the University of Wisconsin System. Awards received directly by departments that are not in response to a formally processed proposal must be processed with a completed UW-Extension Extramural Support Transmittal form.

POST AWARD ADMINISTRATION

University policies and procedures governing expenditures of State operating funds are also applicable to gift and grant, and contract monies. Please follow the approved budget when processing expenditures against your project. The following information may be useful in the fiscal administration of your project.

Financial Reports/Invoices to Funding Agency

Financial reports for projects assigned to 133 or 144 funds are prepared by the Office of Extramural Support. If the financial report is in a format that is inconsistent with the budget schemes that are available for the accounting reports, the Division may be required to prepare the financial report. The Divisional Business Office will forward the report through the UWEX Office of Extramural Support, which will review the report. Copies of all Financial reports, statements and supporting schedules need to be in compliance with GAAP, University policies and procedures, federal and state requirements as well as specific agreements and OMB Circulars A-21 (cost principles), A-110 (administrative circular), and A-133 (audit requirements). The OMB Circulars are available on the RSP web site (http://whitehouse.gov/omb/grants/index.html).

Generally UWEX Office of Extramural Support will prepare all