Grants- Determination of Non Research Grants
Date: 1 February 1996
Procedure # :600.160
Written By: Ralph Earhart, Director, Financial Services
A. Act 651 of state law requires that non research and non student
aid indirect costs be remitted to the state's general fund (article 2-65-70).
Research is defined in article 2-65-15 as "an award of funds from the United
States government or another entity for the principal purpose of systematic
study or investigation to discover or establish facts or principles.
The principle purpose of a research grant is not to provide services to
the public or to the employees or clients thereof".
B. Each grant or contract needs to be reviewed and its purpose
documented prior to charging indirect costs in order to determine whether
the grant is for research or student aid (permitting the college to retain
the funds) or whether it be non research and the indirect cost recoveries
should be deposited into the state's general fund.
A. When a grant is placed on the accounting system, the grant
accountant will review the documentation received with the grant to determine
whether it is research or not. The final conclusion will be documented
and the Director, Financial Services will review and sign off on the determination.
B. When it is unclear whether the project might be research or
not, the following items will be reviewed and will be considered when making
the determination of whether the project is research or not:
1. The description of the appropriation supporting the
grant in the CFDA book may indicate whether the appropriation
is for research of not. This would be weighted heavily
in making the research/non research determination.
2. OMB A-21 definitions of research will be reviewed.
3. Most grants for non research do not permit full
indirect cost recovery. Federal statute generally does
not permit more than an administrative charge to be incurred.
A grant providing full indirect cost recovery would most likely
indicate a research grant. This factor would be considered
but not be weighed as heavily as other factors.
4. If the project is subcontracted from another entity,
that entity could be contacted to see if they have determined
the project to be research or not.
C. When there are no indications that indicate that a project
might be research, common sense will prevail. If the grant appears
to be research from what is occurring then the Director, Financial Services
will put the rationale for making that determination in writing.
The college will err on the side of conservatism. If there is a real
question of whether it is research or not, the project will generally be
considered as non research. The state auditors will generally review
the determinations of those projects considered as research.
D. If the project is considered as not being research or student
aid, or if the project does not include an award for indirect costs, the
determination need not be documented and placed in the gant folder.