I. Introduction The University of Detroit Mercy (hereafter referred to as “the University”) patent policy is intended to encourage a healthy atmosphere conducive to research and development through a system of rewards and incentives for the creation of intellectual property while at the same time giving proper consideration to the relative roles any individual employee’s efforts or the University or its resources may have played in the development of that intellectual property. The strength of the University lies in its employees. The University’s policies can provide invaluable assistance in bringing employee ideas to development and fruition within a framework of mutual trust and collegiality. This policy is intended to spell out the responsibilities of the University and its employees and establish a framework for ethical conduct when issues covered by this policy arise. While employees are encouraged to consider the potential market value of their inventions, they shall not be held liable for failing to recognize a potentially patentable invention. Employees of the University may create patentable discoveries during the course of their employment with the University. It is desirable in some cases to seek patent protection for these works and discoveries. Licensing the use of the property provides an opportunity for both income to the inventor and financial returns for the University. This patent policy applies to all University employees. For the purpose of this policy, “employee” shall be defined as any person who uses University resources and any intellectual property that involves use of those resources with the exception of student activities associated with coursework. For the purpose of this policy, the term of “employment” shall be defined by the time period when University resources are used for the development of any potentially patentable intellectual property. Upon termination of employment (as defined herein), the employee shall have a duty to disclose to the University all potentially patentable projects in which the University may have a property interest. This disclosure can be achieved through an employee exit interview, or by the employee’s self-disclosure. This paragraph is applicable to patent applications made within the first year after employment ends at Detroit Mercy. The University’s claims on patentable projects end 366 days after disclosure or the end of employment as defined herein, whichever is later. Technological change has made intellectual property issues increasingly complex. As a consequence, both faculty and the University must together develop, respect and enforce clear intellectual property policies to best achieve the University’s mission of instruction, research, and providing service to the community, professions, and disciplines, while remaining consistent with academic freedom, copyright law and tradition. Goals of the policy herein include protecting the interests of the faculty, adjunct faculty, students, and the University while encouraging implementation of technology in their courses and the development of innovative courseware and educational methods. This policy is applicable to anyone engaged in academic pursuit at the University. In the United States, these seven rights are recognized: 17 U.S.C. 106, 106A . II. Patent Committee On an as needed basis (given that Detroit Mercy is principally focused on teaching, this will most likely be on a case-by-case basis, though the University may form a standing committee if it so chooses), the University administration shall form a Patent Committee (hereafter referred to as “the Committee”) which shall serve as an advisory committee to the president on all University patent related matters. This Committee shall evaluate each intellectual property for potential commercial value and decide that the University either seek protection and commercialize that intellectual property or relinquish University rights to that property. The Committee reserves the right to employ outside consultants who possess the necessary expertise to evaluate the potential commercial value of a particular intellectual property submitted for review. All matters regarding specific intellectual property coming before the Committee shall be held confidential by all members of the Committee. The president and his/her designee shall determine the composition, tenure, and decision-making authority of the Committee. a) The creator(s) or inventor(s) may designate two Detroit Mercy faculty members to serve on the Committee. b) It is also recommended that the chair(s) and dean(s) of the creator(s) or inventor(s) be members of the Committee. Additional consideration should also be given to including individuals who have been involved in obtaining intellectual property protection on creative works and therefore familiar with the process. III. Policy Scope of Policy This policy applies to potentially patentable discoveries and trade secrets which are developed using University equipment, supplies, facilities, employee time, or trade secret information, or which relate directly to the University’s business, research, or development. The University will hold first right of refusal ownership in patents and other non-patentable intellectual products, except those covered by copyright policy, developed by its employees as a direct result of their research or employment. The University does not claim rights in an invention for which no equipment, supplies, facilities or trade secret information were used and which was developed entirely on the employee’s own time, unless the invention grows directly out of the business of the University or of the University’s actual or demonstrably anticipated research or development or unless the invention directly results from work performed by the employee for the University. OSPRA Where research has been sponsored by private industry or foundations, licensing of patents shall be negotiated between the sponsor and the University or its agent where appropriate. The University will strive to protect the financial interests of all and, when necessary, act to ensure that the traditions of self-governance and academic freedom are respected. The University, on behalf of its constituent colleges, schools, or departments, will not accept grants or enter into agreements for the support of instruction or research that confer upon an external party the power to censor, unduly delay, or exercise effective veto power over either the content of instruction or the publication of research. Parties entering into such agreements shall be hereby advised that publication of research findings may be temporarily delayed in order to protect patent rights or permit the research sponsor to review the proposed publication for the sole purpose of identifying proprietary information furnished by or belonging to the sponsor. Unless otherwise noted in writing, the University normally retains ownership of property developed under sponsorship agreements and will negotiate rights to license the property. The proprietary rights of the University and the University’s employees shall be subject to the agreement between the sponsor and the University. Determination of Ownership The Committee will determine whether the potentially patentable property is owned by the University, by the employee(s), by an outside sponsor, or jointly by some combination of these. Under the federal patent and trademark legislation of 1980 (35 U.S.C. 200 et seq.), the University has the right of first refusal to title in inventions made in the performance of federal grants and contracts. The University will assert title to and attempt to license inventions made with federal government funds so that the Congressional purpose of fostering the development of industry in the United States will be furthered. Patentable inventions not subject to a sponsorship agreement, or University ownership under the preceding paragraph, or the University provides a written waiver of ownership, will be the employee’s property. Unless contested by the University, the University will, on demand from the employee, issue a waiver of the University’s rights. If contested, the Committee will determine ownership. In cases where it would be unfair to determine that the property is wholly owned by either the University or the employee, the Committee may make a determination of equal ownership. If the University, through the Committee, chooses to release its rights, no additional conditions shall be placed on the release other than consideration to compensate for the continued use of facilities and materials beyond the release date. For patentable property only partially developed during the employee’s term of employment, the Patent Committee shall also have the authority to assign proportionality of property interest between the University and the “employee.” The procedure for determination of ownership shall be as follows: The Committee shall make its determination of ownership within 45 days of full disclosure of the invention by the inventor(s) to the Vice President for Academic Affairs and Provost. Full disclosure simply means that the disclosure must include all pertinent information which the inventor(s) have that is related to the subject invention. The employee will be notified of the decision of the Committee within five days of the Committee’s determination. If the Committee fails to notify the employee in writing of determination of ownership within 65 days of full disclosure, then any potential University’s rights shall automatically revert to the employee. It is acknowledged that the 65 day deadline includes 15 days beyond the timeline set for this process and thereby fully extinguishes the University’s right to any ownership. The employee shall have 30 days from the date of the mailing of the notice to appeal the Committee’s decision. The appeal shall be heard by the Vice President for Academic Affairs and Provost or his/her designee within 20 days of the notice of appeal. The decision on appeal shall be issued within 30 days of the deadline for submitting materials. The decision of the Vice President for Academic Affairs and Provost shall be final. Following this internal appeal process, the employee has recourse to settlement in the civil courts. Duty to Assign and Cooperate After the determination by the Committee and exhaustion of the employee’s right of internal and external appeal, the employee shall execute documents of assignment to convey to the University, or its assignee, all of the employee’s interest in the invention determined to be owned by the University and assist in obtaining, protecting, and maintaining patent rights. When discoveries are determined to be owned in part by the University and in part by the employee, the University and the employee shall enter into a written agreement apportioning 50 percent of the after-costs revenues from the invention to the inventor(s), and the remaining 50 percent to the University. Cost shall be defined as direct expenditures resulting solely from pursuit, prosecution and maintenance of intellectual property rights and commercialization of the invention plus, where appropriate, any extraordinary University resources such as outside legal, consulting, marketing and licensing organizations. Half of the University’s 50 percent of net revenues shall be apportioned to the creator(s)’ or inventor(s)’ Department to support further research and scholarly activity. In the event of multiple inventors, those involved must agree upon an appropriate apportioning of the 50 percent of revenues provided to the inventor; in the absence of any written agreement stating otherwise, the revenues shall be equally divided amongst the inventors. In the case of multiple inventors, the departmental share of revenues shall be apportioned in accordance with the same apportioning made to the inventors. Publication and Disclosure to Third Parties Premature publication, public use, or disclosure of an invention can sometimes jeopardize the rights of the employee, or the University or its assignee to secure patent protection. Therefore, unless the Committee has issued a waiver of University’s rights, the employee agrees that there shall be no publicity or disclosure concerning the invention until patent applications have been filed. Once an invention is identified as potentially patentable, all publicity, public reports, interviews, news releases, speeches, public disclosures or public demonstrations of the invention subsequent to the filing of the application shall have prior clearance in writing from the University or its assignee. This section shall not be applicable to sponsorship agreements that impose different obligations on disclosure. Costs and Royalties Following a decision by the Committee to pursue a patent for an invention deemed to be jointly owned by the inventor(s) and the University, the University shall, in a reasonably prompt manner, develop and file a patent application on the subject invention. All fees, legal and otherwise, associated with development of the invention and patent application shall be assumed by the University, but all such costs must be fully recovered by income generated by the invention before any net revenue accrues. Once costs defined elsewhere have been recovered, all additional income generated through licensing of the patent, sale of the patent or other commercialization of the invention shall be apportioned at the aforementioned percentages after a 5% administrative fee is deducted. Royalties allocated to inventor(s) continue throughout the revenue generation phase of the invention, regardless as to whether or not the inventor(s) remains employed at the University. If the University, at any time, no longer wishes to pursue further development of the intellectual property, the University will notify the inventor(s) and will execute the necessary documents assigning all rights to the inventor(s) unless precluded by prior written agreement. IV. Works Involving the Use of Extraordinary University Resources The University and the faculty members involved generally have a shared interest in the property rights of works involving the use of extraordinary University resources. Examples of “extraordinary University resources” may include institutional funding or grants in support of the work’s creation including but not limited to payments to a faculty-author in excess of such faculty-author’s ordinary salary, and a reduction in faculty workload specifically to facilitate creation of the work. The copyright to works involving the use of extraordinary University resources and all derivative works created by a faculty-author shall be owned by the University. Whether a particular work is created through use of extraordinary University resources shall be determined initially by the relevant dean, his/her designee, or the director of the unit of the University that is providing the extraordinary University resources prior to the commitment by the University of those resources. Final determination will be by mutual written agreement of the faculty author and the University. At the University’s discretion, it may grant to the relevant faculty-author a non-exclusive non-transferable license to use the work involving use of extraordinary University resources for external purposes; provided that if use of the work by the faculty-author generates income the license may provide that: The author shall reimburse the University for the substantial resources provided the author, or The author shall share income from such commercialization with the University. A Sponsored or Externally Contracted Work (Work) shall be any work developed using funds supplied under an Sponsored Research Agreement (SRA), contract, grant, or other arrangement between the University and a third party. Unless the relevant sponsorship agreement requires copyright ownership by the University or conveyance of rights to a third party, the author of a work shall own the copyright to such work. The University will own a work where the relevant agreement requires copyright ownership by the University or conveyance of rights to a third party, in which case the University will convey rights to the third party as required. In such cases the author of the work shall be required to report the work to the vice president for Academic Affairs and provost, using such forms and procedures as that office develops.

Policies & Procedures

UDM Regulatory Policies and Procedures for Grant, Subaward, Contracts, etc.

Policies & Procedures

Allegations of Scientific or Scholarly Misconduct Policy & Procedures

I. PREAMBLE

Although the instances of verifiable scientific or scholarly misconduct during the past ten years have remained small in number, they have been highly publicized. This has, understandably, led to increased concern regarding this issue within the scientific community, academic institutions, federal agencies and the general public. As a result, federal agencies have mandated that those institutions engaged in federally funded research and related activities initiate formal policies and procedures for dealing with allegations of misconduct.

University of Detroit Mercy has, therefore, developed the following policy and procedures for inquiry and investigation of allegations of scientific or scholarly misconduct pertaining to all members of the University community, and to advise the University of Detroit Mercy scientific community of their responsibilities regarding scientific or scholarly misconduct.

II. DEFINITIONS

A. Scientific/Scholarly Misconduct

The fabrication, falsification, plagiarism, deception or practices that seriously deviate from those that are commonly accepted within the scientific or scholarly community for proposing, conducting or reporting research. It does not include honest error or honest differences in interpretation or judgments of data.

Those faculty members who supervise research associates, staff employees or students in research or related activities for which they have been identified as the principal investigator are deemed responsible for overseeing those individuals’ scientific or scholarly conduct. Gross negligence in exercising that supervisory responsibility may itself be chargeable as scientific or scholarly misconduct.

B. Inquiry

An information-gathering and initial fact-finding to determine whether an allegation or apparent instance of scientific or scholarly misconduct warrants an investigation.

C. Investigation

A formal examination and evaluation of all relevant facts to determine if an instance of scientific/scholarly misconduct has occurred. If scientific/scholarly misconduct is confirmed, the institution’s investigation should determine the seriousness of the offense and the extent of any adverse effects resulting from the scientific/scholarly misconduct.

D. Misconduct Policy Officer (MPO)

The Director for Sponsored Projects and Research Activities shall serve as the MPO, and in this role he or she will be the primary recipient of all information concerning possible scientific/scholarly misconduct. When any other individual receives information concerning possible scientific/scholarly misconduct, he or she shall immediately relay the allegation in writing to the MPO.

The responsibilities of the MPO shall include:

The initial contact with all parties to an allegation of scientific or scholarly misconduct.
To maintain records of all complaints and institutional responses.
To serve ex officio (without vote) on the Inquiry Committee and Investigative Committee.
To disseminate information regarding the University’s policy and procedures for scientific or scholarly misconduct to the University community and to inform the University community of the importance of compliance with those policies and procedures.
To advise on a yearly basis the National Science Foundation, Public Health Service, or any other Federal agency which funds research at University of Detroit Mercy of the existence of the University’s administrative process for inquiry and investigation of scientific or scholarly misconduct.

III. PROCEDURES

A. Allegation Phase

Anyone having information that leads him/her to believe that a faculty or staff member has committed scientific/scholarly misconduct, should report the matters to the MPO in writing. The MPO shall establish the precise nature of the allegation and rule out the possibility that the allegation is either frivolous or malicious. The accused shall immediately thereafter be informed of the nature of the accusation against him/her. Also, the provisions of policy and procedures contained in this document shall be provided and explained to both parties.
During this phase and throughout any subsequent phases, every effort shall be made by all parties to discover all relevant facts and to take whatever steps are necessary and appropriate to remedy improprieties. No part of these procedures shall, however, be interpreted to preempt either the right of an individual alleging scientific/scholarly misconduct to withdraw that allegation or the right of an individual accused of scientific/scholarly misconduct to concede that misconduct and to propose appropriate remedies. Any such informal resolution must be approved by the MPO, representing the legitimate interests of the institution and those of any external funding agency or agencies involved before the matter is considered closed.
If the MPO determines that there are no grounds for proceeding further, he or she shall so inform both parties in writing.
Where practicable, such preliminary discussions should be completed within ten (10) working days of the initial allegation having been lodged with the MPO.
Throughout this phase, the privacy of all individuals involved shall be carefully protected. Information concerning any inquiry will be made available only to those individuals who need to know. Every effort will be made to keep the inquiry confidential until results are established with reasonable certainty.
In case of research supported by the National Science Foundation, Public Health Service, or any other Federal agency, the Agency will be notified of the alleged scientific/scholarly misconduct prior to the inquiry, or at any time during the investigatory stage if facts are discovered which show that any of the following conditions exist:

- The seriousness of the apparent misconduct warrants disclosure.
- An immediate health hazard is involved.
- There is an immediate need to protect Federal funds, equipment, resources, reputation, or other important interests.
- There is an immediate need to protect the interests of the person(s) making the allegations or of the individual(s) who is the subject of the allegations as well as his/her co-investigators and associates, if any.
- It is probable that the alleged incident is going to be reported publicly.
- If there is a reasonable indication of possible criminal violation, the University will notify the agency’s appropriate office within 24 hours.

B. Inquiry Phase

The inquiry phase shall be initiated in the following two instances
- The MPO determines that the allegation merits further investigation; or,
- The person alleging scientific/scholarly misconduct bypasses the MPO’s decision not to pursue the matter further. The bypass of the MPO’s decision can be made by informing the provost and vice president for Academic Affairs in writing within five (5) working days of receiving notification of that decision, that the decision is disputed. In either case, the MPO shall obtain a written and signed statement of the allegation(s), by the individual(s) alleging scientific/scholarly misconduct. The accused shall be notified in writing by the MPO that a formal allegation has been received and that an Inquiry Committee shall be formed.
The provost and vice president of Academic Affairs shall appoint an Inquiry Committee within ten (10) working days where practicable. The Inquiry Committee shall be composed of three (3) members of the University faculty, at least one of whom shall belong to the faculty of a college or school other than that in which the scientific/scholarly misconduct is alleged to have occurred. The MPO shall be and ex officio member (without vote) of the Inquiry Committee.
The MPO shall notify the following persons that an inquiry is being initiated: any University of Detroit Mercy faculty member directly responsible for supervising the individual against whom the allegation has been made; the appropriate department chairperson and dean; the provost and vice president for Academic Affairs; and the provost and vice president of Academic Affairs designation of University general counsel. The preceding individuals shall be notified because it has been determined that they are parties who “need to know ” about the inquiry.
The Inquiry Committee shall separately meet with the accuser and the accused and shall review all necessary and reasonable documentation to determine if an investigation should be recommended.
Refusal on the part of the accused to allow the Inquiry Committee to review necessary documents shall be grounds for a recommendation for an investigation.
The Inquiry Committee shall take no more than sixty (60) days to conduct its inquiry and determine whether an investigation is warranted. The Inquiry Committee shall make a formal written report of inquiry consisting of the complaint, the evidence reviewed, a summary of relevant interviews, the Inquiry Committee’s findings, and a recommendation on future actions. The individual(s) against whom the allegation(s) was made shall be given a copy of the report of inquiry. If they comment on the report, their comments may be made part of the record. The report shall recommend that either:
- The inquiry be terminated if it is determined that the allegation was frivolous or malicious and/or that insufficient evidence was produced to warrant further proceedings. In the case of this finding, diligent efforts shall be undertaken to restore the reputation of the accused. Any and all parties that had been notified of the inquiry shall be notified of the lack of merit therein and instructed to disregard the inquiry.
- A formal investigation should be conducted, because evidence sufficient to support further proceedings has been discovered through the inquiry phase.
The Inquiry Committee report shall be submitted to the MPO and forwarded by her or him to the provost and vice president of Academic Affairs. The provost and vice president for Academic Affairs shall maintain sufficiently detailed documentation of inquiries to permit a latter assessment of the reasons for determining that an investigation was not warranted, if necessary. Such records shall be maintained in a secure manner for a period of at least seven years after the termination of the inquiry, and shall, upon request, be provided to authorized Federal agency personnel.
If the Inquiry Committee recommends that a formal investigation should be conducted, the MPO shall immediately, in writing, so inform the person who made the initial allegation; the individual against whom scientific/scholarly misconduct has been alleged; his/her immediate University of Detroit Mercy supervisor; the appropriate chairperson and dean; the provost and vice president of Academic Affairs; and the Office of the University General Counsel. The proceeding individuals shall be notified because it has been determined that they are parties who ” need to know ” about the inquiry.
In the case of research supported by a Federal agency, the awarding agency shall also be notified on or before the date the investigation is to begin that an inquiry has been completed with the alleged scientific/scholarly misconduct having been judged worthy of further investigation, and that such an investigation is being undertaken.
During the inquiry and throughout any further proceedings, the University will protect the rights, the reputation and the professional and the institutional standing of all individuals against whom scientific/scholarly misconduct has been alleged by affording them confidential treatment ( as described elsewhere in this document and except as provided by law ), a prompt and thorough inquiry and the opportunity to comment on the allegations against them and all related findings.
From the initial reporting of the alleged scientific/scholarly misconduct, the University will also protect the rights, the reputation and the professional and institutional standing of those who have reported the scientific/scholarly misconduct insofar as this is consonant with the conduct of a fair and thorough inquiry as defined elsewhere in this document.
When an allegation may involve immediate danger to humans or animals, the MPO shall alert the provost and vice president of Academic Affairs who will take appropriate actions to protect those at risk, including notification of the chairperson(s) of the Institutional Review Board and /or the Animal Welfare and Use Committee as indicated.

C. Investigative Phase

If the Inquiry Committee recommends a formal investigation, the provost and vice president for Academic Affairs, in consultation with the members of that committee, shall appoint such additional members as (s)he and they deem necessary to ensure the availability of expertise appropriate to the nature of the allegation. The expanded Investigation Committee shall in any case include not less than four members of the full-time University of Detroit Mercy faculty. At least one additional member shall be appointed to this committee who is not affiliated with University of Detroit Mercy. The MPO shall remain as an ex officio (nonvoting) member of the Investigation Committee. The undertaking of the investigation shall begin within thirty (30) days of the completion of the inquiry.
The Investigation Committee shall be charged with undertaking a thorough and appropriately detailed review of the evidence. The investigation normally will include examination of all documentation, including but not necessarily limited to relevant research data and proposals, publications, correspondence, and memoranda of telephone calls. Whenever possible, interviews shall be conducted of all individuals involved either in making the allegation or against whom the allegation is made, as well as other individuals who might have information regarding key aspects of the allegations. Complete summaries of these interviews shall be prepared and provided to the interviewed party for comment or revision. These summaries will then be included as part of the investigatory file. The provost and vice president of Academic Affairs and University general counsel shall be consulted regarding additional procedures that meet judicial standards and review for a private university. These procedures shall be provided in writing to all parties involved at the earliest opportunity.
The Investigation Committee shall submit a written report to the provost and vice president of Academic Affairs at the conclusion of the investigation. This report shall contain: the statement of the allegation; the committee’s findings as to the facts of the case; the accused’s written comments on the allegations; and (if appropriate) the committee’s recommendations as to remedies for any improprieties they determine to have occurred. The investigation phase, which includes the investigation and preparation of the written report should normally be completed within 120 days. *NOTE: In the case of research sponsored by certain agencies of the U.S. government, additional deadlines and reporting requirements may be stipulated. The MPO shall be responsible for informing the committee of all relevant regulatory restrictions on their work. In almost all cases, the agency will expect to receive a copy of the committee’s final report.
The Investigation Committee’s final report and all other records of the investigation shall be retained by the provost and vice president of Academic Affairs.

D. Post Investigative Actions

If an allegation of scientific/scholarly misconduct is not sustained by a preponderance of proof, all proceedings shall be discontinued. The investigative file shall be closed and no reference to it shall appear in the individual’s personnel file. Additionally, this finding shall be made known to all those who had previously been informed of the allegation. Diligent efforts shall be undertaken to restore the reputation of the accused.
If scientific/scholarly misconduct is determined to have occurred, appropriate action up to and including suspension, restitution and discharge will be undertaken by the provost and vice president for Academic Affairs. Additionally, all pending abstracts and papers emanating from the fraudulent research will be withdrawn and editors of journals in which previous abstracts and papers appeared will be notified. Institutions and sponsoring agencies with which the individual has been affiliated will also be notified. If the individual against whom allegations has been made disagrees with the operation of this policy, he or she may avail himself or herself of the appropriate grievance procedures. In the case of faculty belonging to the University of Detroit Mercy Professors’ Union these procedures can be found in the University of Detroit Mercy and the University of Detroit Mercy Processors’ Union Collective Bargaining Agreement.
In the case of federally funded research, the awarding agency or agencies will be notified. It should be noted that a funding agency may invoke the right to impose sanctions of its own on the individual researcher, on some school or division of the University, or on the University as a whole.

If you suspect suspicious activity such as fraud, misuse, misappropriation, etc., please submit your concerns via the anonymous tips form*.

*The tip form is emailed to the directly to the Office of Sponsored Programs and Research Activity (OSPRA). Your e-mail address is not visible anywhere unless you choose to include it.

Charging Salaries to Grants Policy

These policies are in compliance with federal Uniform Guidance regulations, which went into effect on December 26, 2014.

Here is a link to the Title 2 | Code of Federal Regulations

I. Academic Year Effort
Charges for work performed on Federal awards by faculty members during the academic year are allowable at the Institution Base Salary (IBS) rate. Except in rare instances, charges to Federal awards cannot exceed the proportionate share of the IBS for the period that the faculty member worked on the award. In general, if work is being performed on a federal project during the academic year, the project should fit within the faculty member’s full-time schedule. If grant funds are used to pay salary during the academic year, the normal workload should be adjusted accordingly. Release time to work on sponsored projects is arranged between the faculty member and the college Dean.

Any faculty or staff member whose salary is charged 100% to a sponsored project for any period must be exclusively engaged on the sponsored project to which their salary is allocated for the entire period. If work is performed on other projects, effort must be reduced and only the proportionate share of funding will be allocated to the sponsored project.

II. Overload
Intra-institution of Higher Education (IHE) consulting is collaboration, cooperation and consulting among Detroit Mercy employees by faculty and is assumed to be undertaken as an IHE obligation requiring no compensation in addition to IBS. However, in unusual circumstances, overload may be authorized under the following conditions:

The faculty member serves on a strictly limited basis as a consultant on a research or training project for which another faculty member in another college has principal responsibility or the work involves a separate or remote operation.
The work will be conducted in addition to the faculty member’s regular departmental load.
This arrangement is specifically provided for in the Federal award or approved in writing by the Federal awarding agency.

III. Compensation for 12-month Faculty, Administrators and Staff
Twelve-month employees performing work on sponsored projects are generally not eligible to receive pay beyond their regular compensation. In rare instances supplemental pay may be allowed if work meets the federal criteria for IHE consulting, is clearly distinct from their normal duties and occurs outside of their normal work hours or during a period for which the individual has used accrued leave during the period which supplemental pay is requested.

IV. Summer Salaries
Charges to sponsored projects for summer research must be consistent with the level of effort devoted to each project for the period and with the funding provided. Charges for work performed during the summer months or other periods not included in the base salary period will be determined at a rate not to exceed the IBS rate divided by the period to which it relates.

Federal guidelines require that for faculty that request 100% effort in a given month, 100% of the faculty’s time and effort must be spent on activities covered by the award(s) for the specified period of time that they are receiving summer salary. Faculty would have to forego teaching, proposal preparation, administrative work, vacation and any travel that is unrelated to the grant-funded project. It is recommended that summer salary should be requested at no more than 83.33% effort (2.5 months).
Exceptions must be approved by the Provost and Vice President of Academic Affairs, Dean and Director of OSPRA unless otherwise restricted by sponsor guidelines.
It is not allowable to charge summer salary as a means of compensating faculty for their effort on sponsored projects during the academic year.

V. Administrative and Clerical
Administrative support charges are normally considered Facilities and Administrative costs (F&A) or indirect costs. Direct charges for administrative or clerical positions may be allowable if all of the following conditions are met:

The administrative or clerical services are integral to a project or activity
Individuals involved can be specifically identified with the project or activity
Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency
The costs are not also recovered as indirect costs

VI. Hiring Grant-Funded Staff
The Uniform Guidance as well as IRS regulations dictate that an employee of the University, whether full-time or part-time, cannot also be paid as a consultant. Adjunct faculty and other part-time employees of the University should be listed as employees on grant proposal budgets. The Affordable Care Act requires that part-time employees be assigned an hourly rate and number of hours. Please also see the document entitled, Process for Hiring Personnel on Grants.

VII. Effort Reporting
All faculty and staff working on sponsored projects are required to certify that the percentage of their salary charged to sponsored projects reasonably reflects their level of effort on that project. (Also see Effort Reporting Policy)

VIII. Supplanting (NEW)
A college or unit of the University may reduce funds allocated for an activity specifically because federal, state, corporate, foundation or other funds are available (or expected to be available) to fund that same activity. When supplanting is not permitted, awarded funds must be used for program activities and may not replace state or local funds that have been appropriated or allocated for the same purpose. Additionally, federal funding may not replace state or local funding that is required by law.

Conflict of Interest | Personal and Financial (COI, SFI, FCOI) Policy & Procedures

The Department of Health and Human Services published Subpart F—Promoting Objectivity in Research to establish standards that provide a reasonable expectation that the design, conduct and reporting of research funded under Public Health Service (PHS) grants or cooperative agreements will be free from bias resulting from investigator financial conflicts of interest (FCOI) or significant financial interests (SFI). University of Detroit Mercy has revised its policy on financial conflicts of interest in accordance with the new regulations as of December 1, 2020. Detroit Mercy’s policy will be extended to all externally sponsored projects. The full notice can be found by visiting: Title 42 | Code of Federal Regulations | Part 50

While the investigators of University of Detroit Mercy recognize that their primary professional obligation is to University of Detroit Mercy, they must be alert to the possibility that outside arrangements, whether they be financial interests or employment relationships, may compromise their objectivity as teachers, researchers, clinicians and administrators. This rule pertains to both full-time and part-time investigators. To avoid any such possible conflict of interest, or the appearance of a conflict of interest, in the conduct of grant or contract activities, the safeguards outlined in this document are hereby established, as mandated by federal law.

The areas of potential conflict may be divided into two categories. Conflicts of interest are defined as situations in which investigators may have the opportunity to influence the University’s business decisions in ways that could lead to personal gain or give improper advantage to the investigator or members of their family or to associates. Conflicts of commitment are defined as situations in which investigators’ external activities interfere, or appear to interfere, with their paramount obligations to their students, colleagues and the University.

What is required?

Federal regulations require institutions to have policies and procedures in place to ensure that investigators disclose any significant financial interest that may present a conflict of interest in relationship to externally sponsored projects. Such disclosures must be made prior to the submission of a proposal for funding, and institutions must develop specific mechanisms by which conflicts of interest will be satisfactorily managed, reduced or eliminated prior to award or acceptance of an award. The director of the Office for Sponsored Programs and Research Activities (OSPRA) will manage this process, assure adherence to the policy and act as a liaison between federal agencies and the PI(s).

NOTE: If a new reportable significant conflict of interest arises at any time during the period after the submission of the proposal through the dates of the award, the filing of a disclosure is required to be submitted to OSPRA within 30 days and reported to the federal agency within 60 days with plan for management of any conflicts.

Who is covered?

“Investigator” means the principal investigator/project director, co-principal investigators and any other person at the University who is responsible for the design, conduct or reporting of research or educational activities funded, or proposed for funding, by an external sponsor. This includes subrecipient Investigator(s), students and consultants, if applicable. In this context, the term “investigator” extends to the investigator’s spouse and dependent children as well.

What must be disclosed?

Each investigator shall disclose all significant financial interests:

That would reasonably appear to be affected by the research or educational activities funded, or proposed for funding, by an external sponsor; or
In entities whose financial interests would reasonably appear to be affected by such activities.

What is covered?

” Significant financial interests” means anything of monetary value, including but not limited to:

With regard to any publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the 12 months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000. For purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); Equity interest includes any stock, stock option or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value.
With regard to any non-publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the 12 months preceding the disclosure, when aggregated, exceeds $5,000, or when the investigator (or the investigator’s spouse or dependent children) holds any equity interest (e.g., stock, stock option or other ownership interest).
Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.
Investigators also must disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the investigator and not reimbursed to the investigator so that the exact monetary value may not be readily available), related to their institutional responsibilities, provided, however, that this disclosure requirement does not apply to travel that is reimbursed or sponsored by excluded sources provided in regulation. The investigator is not required to disclose travel that is reimbursed or sponsored by a federal, state or local government agency, an institution of higher education, an academic teaching hospital, a medical center or a research institute that is affiliated with an institution of higher education.
The investigator is an officer, director, partner, trustee, employee, advisory board member or agent of an external organization or corporation either funding a sponsored project or providing goods and services under a sponsored project on which the investigator is participating in any capacity.

The term does not include:

Salary, royalties or other remuneration from University of Detroit Mercy; Intellectual property rights assigned to the Institution and agreements to share in royalties related to such rights. Any ownership interest in the Institution held by the investigator, if the Institution is a commercial or for-profit organization.
Income from investment vehicles, such as mutual funds and retirement accounts, as long as the investigator does not directly control the investment decisions made in these vehicles.
Income from seminars, lectures or teaching engagements sponsored by a federal, state or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center or a research institute that is affiliated with an institution of higher education.
Income from service on advisory committees or review panels for a federal, state or local government agency, institution of higher education as defied at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center or a research institute that is affiliated with an institution of higher education.

How do I disclosure my interests?

All investigators must disclose their significant financial interests during the Cayuse Sponsored Projects setup, where PI’s will also upload all required supporting documentation.
In accordance with federal regulations, a complete disclosure must be made by investigator(s) prior to the submission of the proposal.
Management Plans for potential conflicts of interest will be incorporated into a signed agreement that is executed between the investigator(s), provost and vice president of Academic Affairs, director of OSPRA, dean or unit leader and vice president for Finance (CFO) prior to making any expenditures of sponsored project funds.
NSF only requires the University to report conflicts which cannot be satisfactorily managed or eliminated.

What if a bias is discovered in the design, conduct or reporting of funded research?

Contact the director of OSPRA, who will promptly notify the federal agency (NIH, HHS, DoE, NSF, etc.) of the nature of the bias and its impact on funded research.
A mitigation report will be submitted to the federal agency within 120 days of notification to be signed by the provost and vice president of Academic Affairs, director of OSPRA, dean or unit leader and vice president for Finance (CFO) prior to making any expenditures of sponsored project funds.
The Conflict of Financial Interest Committee will meet within 60 days to determine if any disciplinary action is necessary, establish a ruling and set forth a corrective action plan which will then be reported to the sponsor within 120 days, in accordance with policy 42 CFR 50.605(a)(3).
Any researcher involved in a finding of non-compliance with the FCOI policy, especially where it involves evaluation of the safety of a drug, medical device or treatment; the PI will retroactively request an addendum to any published research or presentations on such research. The PI must also make the FCOI clear in any dissemination of research findings going forward.
The Conflict of Interest Review Committee (CIRC) is the committee appointed by the provost and vice president for Academic Affairs to implement this policy. It shall be made up of the director of the Office for Sponsored Projects and Research Activities and three to five members of Detroit Mercy faculty, from different disciplines, who are experienced in conducting sponsored research (at least one of whom has been a principal investigator involved in a sponsored project in the last five years) or in managing potential conflicts of interest. The committee shall select its own chairperson and be the body which investigates any suspected FCOI of SFI and/or deliberates on whether such a conflict exists. Its findings are final.
The PHS requires the University to report to the PHS Awarding Component the following:
- Project director/Principal investigator
- Grant/Contract number
- Name of investigator with the Financial Conflict of Interest (FCOI)
- Whether the FCOI was managed, reduced, or eliminated
- Name of the entity with which the investigator has a FCOI
- Nature of FCOI (e.g. equity, consulting fees, travel reimbursement, honoraria)
The University shall follow federal regulations regarding the notification of the sponsoring agency in the event an investigator has failed to comply with this policy. The sponsor may take its own action as it deems appropriate, including the suspension of funding for the investigator until the matter is resolved.
PHS requires that the institution notify the PHS Awarding Component promptly and submit a report to the PHS Awarding Component in cases where bias is found. The report will address the impact of the bias on the research project and the actions the institution has taken, or will take, to eliminate or mitigate the effect of the bias.

What is the role of the Conflict of Interest Review Committee (CIRC) and when are they involved?

If the director of the Office for Sponsored Projects and Research Activities, or his/her designee, determines that the potential for more than a remote or minimal conflict of interest may exist, he or she shall schedule a meeting of the CIRC to review the proposal and the disclosures. The investigator shall be informed that the CIRC will review the proposal and will be invited to attend the meeting for the purpose of presenting his or her position and answering any questions the committee may have. A potential conflict of interest will not delay processing of the proposal or its submission to the sponsoring agency. The Significant Financial Interest Disclosure and supporting documentation will not be conveyed beyond OSPRA.

In its review, the CIRC will reach one of two conclusions:

That the potential conflict of interest is not proximate or significant enough to cause a concern for objectivity or integrity; or
That the potential conflict of interest is such that a significant financial interest could directly and significantly affect the design, conduct or reporting of the proposed project. In reviewing these disclosures, the Conflict of Interest Review Committee will act in a timely manner so as not to delay unduly the conduct of the project.

1. If the CIRC reaches the first conclusion, it shall document its determination, and no further action shall be required.

2. If the CIRC reaches the second conclusion, it shall discuss with the investigator possible ways of reducing, managing or eliminating the potential conflict of interest. The investigator shall be informed that a Management Plan will need to be developed and approved prior to the expenditure of any award funds.

3. OSPRA will work with the investigator to develop and present to the CIRC a Management Plan that details proposed steps that will be taken to reduce or eliminate the potential conflict of interest. Methods adopted in the plan may include one or more of the following:

Public disclosure of significant financial interests
Review of research protocol by independent reviewers
Monitoring of research by independent reviewers
Modification of the research plan
Disqualification from participation in all or a portion of the research funded
Divestiture of significant financial interests
Severance of relationships that create actual or potential conflicts of interest

4. The CIRC shall review the resolution plan. The CIRC may modify the plan, including adding conditions or restrictions, before it approves the plan.

5. If the investigator is dissatisfied with the CIRC’S conclusion, the investigator may appeal to the provost and vice president for Academic Affairs who will consult with the Investigator and CIRC as the provost and vice president for Academic Affairs deems necessary and appropriate to the particular circumstance. The decision of the provost and vice president for Academic Affairs shall be final.

6. Violations of this policy or the terms of the Management Plan, such as willful concealment of financial interests, may result in sanctions being imposed upon the violating individual. If the violation results in a collateral proceeding under the institution’s policies regarding misconduct in science, then the CIRC shall defer a decision on sanctions until the misconduct in science process is completed. The CIRC will review allegations of violations and will make recommendations regarding the imposition of sanctions to the provost and vice president for Academic Affairs. The decision of the provost and vice president for Academic Affairs with regard to the imposition of sanctions shall be final subject to any rights the investigator may have under the grievance procedure contained in the Detroit Mercy-UDMPU Collective Bargaining Agreement. Retrospective reviews will be completed and documented within 120 days.

How are records maintained, publicized and for how long?

1. OSPRA will maintain all records regarding FCOI for federal and State of Michigan grants for a period of seven years past the end date of any award in a secure file backed up on Detroit Mercy’s server daily.

2. This includes other dates as specified in 45 CFR 75.361, where applicable.

3. Reports will also be kept for a period of 10 years past the submission of a final expenditure report of any NIH-funded project, or upon the resolution of any government action involving those records, whichever comes first.

4. Information on the policy and Management Plans enacted as a result of a finding of an FCOI will be publicly available on the website and via request within five-days.

5. OSPRA will also submit annual reports to NIH and request annual disclosures from faculty and subrecipients to be included in these reports.

What if a subrecipient is included in my grant budget?

1. All subrecipients are required to submit their institution’s policy on FCOI at the time an application is submitted, providing it meets the NIH standard. If it does not fully comply, Detroit Mercy’s form may be used.

2. A memorandum signed by the institution’s AOR will be submitted as a cover letter to the policy describing which policy shall be followed and why.

3. All subrecipients must report discovery of a FCOI to Detroit Mercy as the prime within 30 days. PHS requires that all subcontractors, including commercial firms, follow the above guidelines.

What do I need to fill out prior to submitting my grant?

1. All investigators must disclose their significant financial interests during the Cayuse Sponsored Projects setup, where PI’s will also upload all required supporting documentation.

2. Each investigator must complete training prior to engaging in research related to any PHS-funded grant or contract and at least every four years, and immediately when a PHS-funded investigator is new to Detroit Mercy.

3. Detroit Mercy uses CITI Program for its FCOI training. Any investigator applying for PHS funding must complete the training prior to award acceptance.

NIH policies related to SFI and FCOI

Cost Sharing or Matching Policy

I. Introduction
Cost-sharing or “matching” is when sponsors require that the University allocates some of its own resources (cash, time, goods) as a condition of receiving a grant award. For a number of reasons, such as statutory requirements, demonstration of institutional buy-in, or to limit the number of proposal submissions, sponsors may require that this be included in the budget up-front. This practice is less employed today due to IRS restrictions regarding what applies as match.

Under Federal research proposals, voluntary committed cost sharing is not expected. It cannot be used as a factor during the merit review of applications or proposals, but may be considered if it is both in accordance with Federal awarding agency regulations and specified in a notice of funding opportunity. Criteria for considering voluntary committed cost sharing and any other program policy factors that may be used to determine who may receive a Federal award must be explicitly described in the notice of funding opportunity. Furthermore, only mandatory cost sharing or cost sharing specifically committed in the project budget must be included in the organized research base for computing the indirect (F&A) cost rate or reflected in any allocation of indirect costs.

II. Policy
Cost sharing or matching unless specifically required by the sponsor is strongly discouraged.

III. Federal Guidance
In order to qualify as cost sharing under a federal award, the non-federal contribution must meet the requirements of the Uniform Guidance (also 2 CFR 200.306). For all Federal awards, any shared costs or matching funds and all contributions, including cash and third party in-kind contributions, must be accepted as part of the non-Federal entity’s cost sharing or matching when such contributions meet all of the following criteria:

Are verifiable from the non-Federal entity’s records
Are not included as contributions for any other Federal award
Are necessary and reasonable for accomplishment of project or program objectives
Are allowable under Subpart E—Cost Principles of this part
Are not paid by the Federal government under another Federal award, except where the Federal statute authorizing a program specifically provides that Federal funds made available for such program can be applied to matching or cost-sharing requirements of other Federal programs
Are provided for in the approved budget when required by the Federal awarding agency
Conform to other provisions of this part, as applicable
*Unrecovered indirect costs, including indirect costs on cost sharing or matching, may be included as part of cost sharing or matching only with the prior approval of the Federal awarding agency. Unrecovered indirect cost means the difference between the amount charged to the Federal award and the amount that could have been to the Federal award under the non-Federal entity’s approved negotiated indirect cost rate.

Cost Transfer Policy for Sponsored Programs

Goods and services should be charged correctly to sponsored projects at the time of the original purchase whenever possible to avoid unnecessary cost transfers.

I. Introduction
Frequent, late, and inadequately explained cost transfers are viewed by sponsors and auditors as evidence of poor internal controls. Cost transfers must be supported by documentation which contains a complete explanation of how the error occurred and an explanation of how the expense is necessary to achieve project goals. Explanations such as “to correct an error” or “to transfer to correct project” are insufficient.

II. Policy
Transfers of costs to any sponsored project account are allowable only where there is direct benefit to the project, when the request is adequately documented, and when the request is made within 90 days from the end of the calendar month from which the transaction was posted. A completed Cost Transfer Request Form must be submitted and approved prior to transferring costs to a sponsored project.

III. Examples of circumstances where cost transfers are typically allowable

Transfer of pre-award costs
Correction of a clerical error (such as transposed or mistyped characters)
Reallocation of costs when charged to a central administrative purpose/fund in error

IV. Examples of circumstances in which cost transfers are typically unallowable

Reallocation of expenses only in order to spend down grant funds
Transfers which do not explain why the error occurred and how the expense is appropriate to the project
Transfer of an expense that was previously transferred off the grant
Charge to another grant or fund to expedite an order

V. Cost Transfers after 90 Days
Stronger justification and higher-level approvals are needed for cost transfers after 90 days. The PI or designated staff should regularly review grant expenditures to detect errors in a timely manner.

Determining the Allowability of Costs to Grants Policy

Costs charged to a grant must conform to any limitations or exclusions set forth in the Uniform Guidance, the award’s terms and conditions, and University policy. The University must consistently treat costs as direct or indirect costs to grants, whether public or private. Costs allowable under the award’s terms and conditions and federal regulations must also comply with University of Detroit Mercy policies.

I. Introduction
As a recipient of federal grants, University of Detroit Mercy must be compliant with Uniform Guidance in order to remain eligible to receive awards. The policy outlines the applicable criteria for determining the allowability of a cost. Internal processes and procedures for grant-cost allowability will be updated, as needed, in order to comply with the Uniform Guidance standards.

II. Definitions

Grant: For the purpose of this policy, a grant is an external award supporting research, public service, equipment, training, scholarships, or scholarly activity at the University that has a defined scope of work and set of objectives that provide a basis for accountability and sponsor explanations.
Direct Costs: Direct costs are those that can be specifically and easily identified with a particular project or activity and are allowable under the sponsoring organizations guidelines.
Indirect or F&A Costs: Facilities and administrative costs represent project/grant/contract expenses that the University incurs (equipment, buildings, IT support, administrators, lab space, maintenance, utilities, libraries, etc.) during the course of doing business, that cannot be easily tied to any specific sponsored project. These costs are commonly referred to as “overhead.” Administrative staff support includes payroll, purchasing, IT, OSPRA services, post award grant and contract administrative services, and general clerical support. This is why the University has a pre-negotiated rate with the federal government to pay for some of these costs. You cannot therefore, charge this off to a specific grant.
Pre-Award Costs: Obligations and expenditures to cover costs prior to the effective date of a new or continuation of award or executed contract. Pre-award costs will be charged to an appropriate unrestricted account until the grant or contract has been executed. The recoupment of pre-award costs is not always possible, so it is advised to incur costs within the specified grant period.
Travel Status: As established in the University of Detroit Mercy Expense Reimbursement Policy, a Travel Request form (TR) preauthorizes an employee’s travel. Approved travel forms serve as documentation for travel status.
Uniform Guidance (UG): A set of regulations that consolidates federal guidelines impacting research administration. Per the OMB website, this guidance consolidates, streamlines, and supersedes the eight existing OMB Circulars, including Circulars A-21, A-110, and A-133. CFR Title 2, Part 200.

III. Policy
The applicable criteria for determining allowability are:

The cost must not be expressly disallowable by the institution, both under federal and sponsor regulations, AND under the terms of a specific project.
The cost must be allocable, i.e., the project which pays the expense must directly benefit from the expense or costs incurred.
The cost must be reasonable, i.e., it must reflect the action a prudent person would have taken under the circumstances prevailing at the time the decision to incur the cost was made. All documentation requirements must be met as outlined below. Written documentation is necessary for grant file support of the charges.
The project team is responsible for submitting a written justification and cost summary of any direct charges typically treated by Detroit Mercy as indirect charges (such as general office supplies or administrative support); expenses listed in parts IV and V below; and to request an exemption. The justification must address the allocability and reasonableness of the requested expense. This documentation must be reviewed and approved by the Office of Post Award Grants and Contracts Administration prior to being charged to a sponsored project. Examples of specific charges:

- When costs are for travel, all reasonable efforts must be taken for advance planning to secure the most competitive prices.
- Federal regulations only allow food/meals if they meet certain criteria. For instance, the event or food/meals should not be perceived as entertainment, hospitality or otherwise unnecessary to achievement of project goals. The food/meal costs must also be integral to the delivery of project goals. Please review the agency guidelines and contact the OSPRA if you plan to include these costs in your budget.
- Food/meal costs per person should not exceed per diem rates and must follow all established University of Detroit Mercy policies.
- Food/meals for events or workshops can be allowable if there are speakers/attendees from other employers/institutions. Participants/employees should not be solely University of Detroit Mercy employees.
- Charges made to grants which do not follow the established criteria will be recharged to the appropriate non-grant fund.
- Grant charges for personnel must comply with the policy entitled “Policy for Charging Salaries to Grants,” which can be found on the OSPRA website.

IV. Costs Generally Unallowable on Federal Awards
The following list is for general purposes only. All costs applied to sponsored research projects should pass the test of being allowable, allocable, reasonable and consistently treated.

Advertising and public relations costs (except in the case of recruitment for a position necessitated by the grant, program outreach, or public promotion of the grant activities).
Alcoholic beverages
Alumni activities
Bad debt
Capital expenditures >$5,000 not pre-approved by the federal awarding agency (may become allowable through a request submitted to agency)
Commencement and convocation costs
Contingency provisions
Contributions or donations, including cash, property, or services
Costs incurred in connection with any criminal, civil, or administrative proceedings
Entertainment costs
Fines and penalties
Fund raising and investment costs
Goods or services for personal use
Housing and personal living expenses
Institutionally furnished automobiles or other vehicles
Lobbying costs, at any level of government
Losses on other sponsored agreements or contracts
Payroll for University employees not engaged in grant activity
Payroll in disproportionate amounts to the work performed on the grant (example: research assistant working half of their time on a research project may not receive more than 50% of her pay from that award)
Postage (included in F&A, exception can be made if large mailing is necessitated by the grant)
Proposal preparation

V. Quick Reference to Treatment of Direct and Indirect Cost Expenses
Please refer to Detroit Mercy Policy for Facilities and Administrative Costs/Indirect Costs for additional information about indirect cost charges.

Direct Costs (Allowable as Grant charges)	Indirect Costs (Not Allowable as grant charges)
Salaries/Wages & Fringe Benefits: Faculty, other professionals, technicians, post doc associates, research associates, graduate and undergraduate students, background checks	Salaries/Wages & Fringe Benefits: Clerical and administrative assistants, fiscal manager, secretaries, and department directors
Materials and Supplies: Project related research and scientific supplies or any equipment or software that does not qualify under the equipment definition	Office Supplies/ Office Furniture/Books & Journals: Pens, pencils, paper, staples, toner cartridges, printer paper, general use software and computers, filing cabinets, office furniture, journal subscriptions
Equipment: Equipment used for scientific, technical, and research purposes that costs greater than $5,000 and has a useful life of at least one year	Equipment: General office equipment such as copiers, printers, office computers, and fax machines
Facilities: Project specific space or equipment rental for off-campus facilities from a third party	Facilities: Utilities, building use, grounds maintenance, renovations, and alterations of University property whether on- or off-campus
Travel: Transportation, lodging, subsistence, and related items incurred by employees who are on travel status on official business of the University related to the project	Travel: Costs of entertainment, and any costs directly associated with such costs (such as tickets to shows or sports events, meals, lodging, alcohol, rentals, transportation, and gratuities)
Telephone: Long distance calls, phone surveys or calls to project participants	Telephone: Local calls, cell phones, installation and maintenance
Maintenance & Repairs: Requires justification that the expenditures are required and directly related to the specific award	Maintenance & Repairs: Maintenance and repairs to general purpose equipment, buildings, and grounds
Advertising: Recruitment of research subjects or for job openings approved for a specific project	Advertising: Public relations to promote unit/department/college/program
Printing/Publications: Copying charges must be project related and only included when charges can be tracked; poster printing costs used for the dissemination of project-related outcomes	Printing/Publications: General printing and copying
Memberships, Subscriptions and Professional Activity: Membership in business, technical, and professional organizations; directly related to and supportive of the project All membership expenses must be justified and receive prior approval	Memberships, Subscriptions and Professional Activity: Membership in any civic or community organization; Membership in any country club or social/dining club or organization; Subscriptions to business, professional, and technical periodicals related to and supportive of project; Personal memberships to business, technical, and professional organizations
Shipping and Postage: Justification required that cost needed to transport project material in a timely way	Shipping and Postage: Routine or internal courier
Consulting: Project specific	Consulting: General, management, financial
Miscellaneous Costs: Subcontract costs, recharge center charges, and training costs, speaker fees, pre-award costs (justification and approval required)	Miscellaneous Costs: Computer network charges, lobbying, insurance, depreciation, legal services, interest, postage, honoraria, and utilities
Research, Trainee or Project Participant Incentives: Research or project participant support is allowable at the discretion of the sponsor and only when included as part of an approved University of Detroit Mercy IRB protocol Trainee participant support is allowable at the discretion of the sponsor and when necessary to meet the project outcomes Justification and prior approval is required for participant support

VI. Exceptions

Please refer to Section III of this document for instructions on how to request approval to charge specific costs to a restricted grant fund. Costs incurred without prior approval from the Office of Post-Award Grants and Contracts Administration will be charged to a non-grant fund and may have general operating budget implications.

Export Controls for Sponsored Programs Policy

It is the Principal Investigator’s responsibility to identify where export control may apply. OSPRA can help with not only making this determination, but assuring federal guidelines are met.

I. Introduction
Export Controls are federal laws that govern how technology, technical data, technical assistance, and items or materials (from software to satellites and more) are physically or electronically exported, shipped, transmitted, transferred, or shared from the U.S. to foreign countries, persons, or entities. These laws protect national security and U.S. foreign policy interests, prevent terrorism and the proliferation of weapons of mass destruction, and preserve U.S. economic competitiveness. Penalties for violating these laws can be severe, both for the individual researcher and the university.
Your research may be subject to export controls oversight when:

The items, materials, technology or technical data used in the research are identified on U.S. export control lists
Working with (formally or informally), or providing technical assistance to, foreign nationals from countries currently sanctioned (e.g., for trade, travel, or terrorism) by the U.S
A research agreement (e.g., contract, award, non-disclosure agreement) limits publication of results or participation in the design, conduct, or reporting of the research based on citizenship

II. Policy
Detroit Mercy’s OSPRA adheres to multiple federal agencies’ export controls regulations. The three main regulations are:

International Traffic in Arms Regulations (ITAR)(link is external) from the U.S. Department of State (Directorate of Defense Trade Controls) which covers items and services related to military/defense applications, including spacecraft and satellites
Export Administration Regulations (EAR)(link is external) from the U.S. Department of Commerce (Bureau of Industry and Security) which covers “dual use” civilian/military items and technology
Office of Foreign Assets Control (OFAC)(link is external) from the U.S. Department of the Treasury, which covers restrictions due to foreign trade embargoes and economic sanctions

III. OSPRA’s Role in Assisting Principal Investigator’s with Compliance

Evaluating research activity (e.g., sponsored project, technology transfer, international travel) for export controls conditions in coordination with other university units
Assisting in the creation of a Technology Control Plan (TCP), if export controls apply to the research activity
Obtaining appropriate federal licenses and other approvals for the export controlled research activity
Advising on, and monitoring the completion of, required export controls training

Faculty and Staff Compensation from Sponsored Projects Policy

These policies are in compliance with federal Uniform Guidance regulations, which went into effect on December 26, 2014. Here is a link to the Title 2 | Code of Federal Regulations

I. Academic Year Effort
Charges for work performed on Federal awards by faculty members during the academic year are allowable at the Institution Base Salary (IBS) rate (your salary before any income from taking on additional assignments such as department chair activities) . Except in rare instances, charges to Federal awards cannot exceed the proportionate share of the IBS for the period that the faculty member worked on the award. In general, if work is being performed on a federal project during the academic year, the project should fit within the faculty member’s full-time schedule. If grant funds are used to pay salary during the academic year, the normal workload should be adjusted accordingly. Release time to work on sponsored projects is arranged between the faculty member and the college dean.

The faculty member serves on a strictly limited basis as a consultant on a research or training project for which another faculty member in another college has principal responsibility or the work involves a separate or remote operation;
The work will be conducted in addition to the faculty member’s regular departmental load;
This arrangement is specifically provided for in the Federal award or approved in writing by the Federal awarding agency.

Federal guidelines require that for faculty that request 100% effort in a given month, 100% of the faculty’s time and effort must be spent on activities covered by the award(s) for the specified period of time that they are receiving summer salary. Faculty would have to forego teaching, proposal preparation, administrative work, vacation and any travel that is unrelated to the grant-funded project. It is recommended that summer salary should be requested at no more than 83.33% effort (2.5 months).

Exceptions must be approved by the Academic Vice President unless otherwise restricted by sponsor guidelines.

It is not allowable to charge summer salary as a means of compensating faculty for their effort on sponsored projects during the academic year.

The administrative or clerical services are integral to a project or activity;
Individuals involved can be specifically identified with the project or activity;
Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and
The costs are not also recovered as indirect costs.

VI. Hiring Grant-Funded Staff
The Uniform Guidance, as well as IRS regulations, dictate that an employee of the University, whether full-time or part-time, cannot also be paid as a consultant. The University’s adjunct faculty and other part-time employees should be listed as employees on grant proposal budgets. The Affordable Care Act requires that part-time employees be assigned an hourly rate and number of hours. Please also see the document entitled, Process for Hiring Personnel on Grants.

Indirect Costs (IDC): Recovery and Allocation Policy

Indirect costs (also known as IDC, overhead, Facilities & Administrative costs or F&A) are real costs of University operations that are not readily or uniquely assignable to a funded project. The importance of recovering IDC as part of the full cost of a sponsored project cannot be overstated. Indirect costs help make it possible to conduct research and programming by providing funds for expenses like heat, light, custodial, library services, occupational safety, human resources, telecommunications, and many other supports available to the UDM community. Indirect cost rates are negotiated with the federal government under the guidelines of Title 2, Part 200 of the Code of Federal Regulations once every several years and are recovered by the University as a percentage of salaries and wages (per the current agreement). Indirect cost rates apply to all sponsored projects, and it is University policy that every sponsored project recovers the full IDC rate whenever possible.

Principal Investigators (PI’s) and their project teams may not negotiate IDC rates with sponsors. Should there be a need to negotiate the IDC rate of a specific project, PI’s should notify the Director of the Office of Sponsored Projects and Research Activities (OSPRA) as soon as possible so that authorized University officials (General Counsel, Chief Financial Officer, Provost and Vice President of Academic Affairs), may proceed with negotiation.

I. Introduction

The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Chapter I, Chapter II, Part 200, also known as the “Uniform Guidance”) include principles for determining costs applicable to grants, contracts, and other agreements between the Federal Government and non-federal entities, including institutes of higher education (IHE’s). The Uniform Guidance defines criteria for determining both direct and F&A costs. In addition, the Uniform Guidance establishes a mechanism for higher education institutions to calculate, negotiate, and recover F&A costs from Federal and other sponsors.

II. Definitions

Grant: For the purposes of this policy, a grant is an external award supporting research, public service, equipment, training, scholarships or scholarly activity at the University that has a defined scope of work and set of objectives that provide a basis for meeting sponsor expectations.
Direct Costs: Direct costs are those that can be specifically and easily identified with a particular project or activity and are allowable under the sponsoring organizations guidelines.
Indirect or F&A Costs: Facilities and administrative costs represent project/grant/contract/sub-award expenses that the University incurs (equipment, buildings, IT support, administrators, lab space, maintenance, utilities, libraries, etc.) while doing business, that cannot be easily tied to any specific sponsored project. These costs are commonly referred to as “overhead.” Administrative staff support includes payroll, purchasing, IT, OSPRA services, post award grant and contract administrative services, and general clerical support. This is why the University has a pre-negotiated rate with the federal government to pay for some of these costs.
Modified Total Direct Costs (MTDC): Federal agencies can limit indirect costs and apply an MTDC base. Most commonly, it is 8% and often used for training grants where a substantial part of the budget is allocated to scholarships. The MTDC base includes salaries and wages, fringe benefits, materials and supplies, consultants, services, travel, animal costs, sub-awards, and subcontracts up to the first $25,000 of each sub-award or subcontract. Specifically excluded from the MTDC base are equipment, capital expenditures, charges for patient care, tuition remission, rental costs of off-site facilities, scholarships, and fellowships.
Non-Federal Indirect Cost Rates: It is the policy of the University to request full indirect costs (IDCs) on all grants, contracts, and sub-awards. This includes corporate, foundation, and other non-federal entities. See the following link for the University’s current IDC rate: https://www.udmercy.edu/academics/academic-affairs/ospra/fact-sheet.php
De minimis rate: The de minimis rate is 10% of the grant budget that can be used by non-governmental entities who do not have a negotiated Indirect Cost Agreement with a federal agency. Corporate and professional foundations will often allow this amount without a detailed cost justification. The de minimis rate is applied on a case-by-case basis.
Off-campus Rate: The University does not have a federally negotiated off-campus IDC rate. Therefore, the full amount applies.
Not-for-Profit Sponsors: Many professional foundations and corporations do not have a published rate. In these cases, the University will take the de minimis rate of 10% or require communication (email is sufficient) from the sponsor that they do not allow for F&A costs. Often the University can still recover some overhead costs by justifying that they are direct project costs.
Facilities & Administrative (IDC) Cost Waiver: If a PI, project lead or unit believes that the standard rate cannot be applied, they can apply to OSPRA for a waiver. The waiver request will need to be approved before routing in Cayuse. The Director of OSPRA will confer with the Dean/unit head, and the Provost and Vice President of Academic Affairs to approve the waiver. In some cases, the Chief Financial Officer, Post Awards Grants & Contracts Administrator and/or General Counsel will be consulted.
Uniform Guidance (UG): A set of regulations that consolidates federal guidelines impacting research administration. Per the OMB website, this guidance consolidates, streamlines, and supersedes the eight existing OMB Circulars, including Circulars A-21, A-110, and A-133. CFR Title 2, Part 200.

III. Policy University of Detroit Mercy’s policy is to apply the negotiated indirect (F&A) cost rate to all externally sponsored projects.

1. General Provisions

The fiscal management of sponsored projects, within budget and funding limitations, is the responsibility of the PI with support from the Post Awards Grants & Contracts Administrator and OSPRA.
In certain circumstances, the Provost and Vice President of Academic Affairs (the Authorized Organizational Representative) may approve full or partial waivers of the IDC.
For foundations, the University requires clearance through the Corporate and Foundation Relations office prior to submission of any proposal.
In the case of non-profits based outside the United States or those established as an arm of a for-profit organization, indirect cost waivers will not be pre-approved; such requests will be considered only on a case-by-case basis. In these cases, care must be taken to determine the sponsor’s non-profit status.
Indirect (F&A) costs will not typically be waived solely because a non-profit has expressed a desire to limit the use of its funds for a particular award. Unless the program solicitation includes such a limitation for all recipients or the non-profit has an official written and publicly disclosed policy, a waiver will not be pre-approved. In such cases, a case-by-case waiver may be requested.

2. Case-by-Case Exceptions

OSPRA will advance other requests for indirect (F&A) cost waivers only in very limited circumstances.
Special requests must be approved by the Provost and Vice President of Academic Affairs. The following will be taken into consideration:

1. The equity of granting the waiver when other faculty carry full overhead.
2. Likelihood that an award would be seriously jeopardized without a waiver and the potential effect of the loss on the faculty member’s overall research program.
3. Benefit of the waiver to new or junior faculty members or in support of research efforts in new directions that otherwise might need to be sufficiently developed to attract significant awards.
4. The waiver is to increase direct costs available for student support.
5. The proposed budget recoups enough revenue to offset the reduction in IDC recovery.

IV. IDC Recovery Allocation Post-Award

Once the University captures indirect costs, they will be allocated on the following basis:

60% to the University (i.e., operation and maintenance of buildings, capital depreciation, departmental and central administration which cannot be readily and specifically attributed to any single sponsored project.
Here is a link to the Title 2 | Code of Federal Regulations | Subpart E
4.7% to Detroit Mercy Libraries
35.3% to the College/Department (The college has some discretion to allocate this as they see fit).

Intellectual Property & Copyright Policy

The following policies, related to Intellectual Property, are taken from the Agreement between Detroit Mercy and the University of Detroit Mercy Professors’ Union, covering the time period between May 16, 2021 and May 15, 2026. For additional information, please refer to: UDMPU Contract

I. Introduction
Technological change has made intellectual property issues increasingly complex. As a consequence, both faculty and the University must together develop, respect and enforce clear intellectual property policies to best achieve the University’s mission of instruction, research, and providing service to the community, professions, and disciplines, while remaining consistent with academic freedom, copyright law and tradition. Goals of the policy herein include protecting the interests of the faculty, adjunct faculty, students, and the University while encouraging implementation of technology in their courses and the development of innovative courseware and educational methods. This policy is applicable to anyone engaged in academic pursuit at the University. In the United States, these seven rights are recognized: 17 U.S.C. 106, 106A

The reproductive right: the right to reproduce the work in copies.
The adaptive right: the right to produce derivative works based on the copyrighted work.
The distribution right: the right to distribute copies of the work.
The performance right: the right to perform the copyrighted work publicly.
The display right: the right to display the copyrighted work publicly.
The attribution right (sometimes called the paternity right): the right of the author to claim authorship of the work and to prevent the use of his or her name as the author of a work he or she did not create.
The integrity right: the right of an author to prevent the use of his or her name as the author of a distorted version of the work, to prevent intentional distortion of the work, and to prevent destruction of the work.

II. Works Involving the Use of Ordinary University Resources
Each faculty member is the exclusive copyright owner of works created at the initiative of the faculty member with ordinary University resources, including ordinary resources used during a research leave, and which are intended to disseminate knowledge for traditional academic purposes. The faculty member has the right to license such material, and such license agreement must be done in writing (with the exception being subsection A8 below). Faculty are encouraged to mark all their copyrighted work with the typical copyright symbol, but copyright protection is in place with or without such markings.

Examples of “ordinary University resources” are those commonly made available to similarly situated faculty include but are not limited to the ordinary use of libraries, online learning management systems (such as the University’s current Blackboard system), office supplies, faculty office space and equipment, University laboratory space and equipment, administrative and technical support staff, telephones, computers and University computer facilities, and other informational resources. Works developed as part of a research leave are considered to have used ordinary resources.
Examples of such works created by faculty with ordinary University resources include but are not limited to books, articles, theses, papers, lectures, syllabi, novels, poems, musical composition, visual works of art, transparencies, CD-ROMs, video tapes, DVDs and computer software.
Except as noted in section B below, the faculty member’s exclusive copyright ownership extends to material created for the content of any instructional technology intended to disseminate knowledge for traditional academic purposes, regardless of the specific medium through which this material is produced or disseminated, and regardless of whether or not this material is archived in any format by the University.
Where the authorship of a work created with ordinary University resources cannot be attributed to one or a discrete number of authors but instead result from simultaneous/sequential contributions over time by multiple authors, the copyright shall be jointly owned by all participating authors.
If the University assists in commercializing a work created with ordinary University resources, the author shall, through written agreement, assign or exclusively license the work to the University and establish a mechanism for the sharing of commercial proceeds with the author.
The University may, with the written agreement of the faculty member, initiate copyright protection of the faculty member’s work.
In the event a faculty member becomes unable, due to factors beyond his or her control, to complete the teaching of a course after the course has begun, permission to use any course materials owned by the faculty member which are essential to the University’s ability to arrange for completion of the course shall be deemed granted by the faculty member for the duration of and exclusive use for the course.

III. Works Involving the Use of Extraordinary University Resources
The University and the faculty members involved generally have a shared interest in the property rights of works involving the use of extraordinary University resources.

Examples of “extraordinary University resources” may include institutional funding or grants in support of the work’s creation including but not limited to payments to a faculty-author in excess of such faculty-author’s ordinary salary, and a reduction in faculty workload specifically to facilitate creation of the work.
The copyright to works involving the use of extraordinary University resources and all derivative works created by a faculty-author shall be owned by the University. Whether a particular work is created through use of extraordinary University resources shall be determined initially by the relevant dean, his/her designee, or the director of the unit of the University that is providing the extraordinary University resources prior to the commitment by the University of those resources. Final determination will be by mutual written agreement of the faculty author and the University. At the University’s discretion, it may grant to the relevant faculty-author a non-exclusive non-transferable license to use the work involving use of extraordinary University resources for external purposes; provided that if use of the work by the faculty-author generates income the license may provide that:
a) The author shall reimburse the University for the substantial resources provided the author, or
b) The author shall share income from such commercialization with the University.
A Sponsored or Externally Contracted Work (Work) shall be any work developed using funds supplied under an Sponsored Research Agreement (SRA), contract, grant, or other arrangement between the University and a third party.
a) Unless the relevant sponsorship agreement requires copyright ownership by the University or conveyance of rights to a third party, the author of a work shall own the copyright to such work.
b) The University will own a work where the relevant agreement requires copyright ownership by the University or conveyance of rights to a third party, in which case the University will convey rights to the third party as required. In such cases the author of the work shall be required to report the work to the vice president for Academic Affairs and provost, using such forms and procedures as that office develops.

IV. Fair Practice
The University covenants that during the term of employment of any given faculty author, the University will not authorize non-author faculty to use instructional works created by the faculty-author, without the prior, written approval of the faculty-author, unless ownership of such works has been assigned to or is vested in the University as stated in the foregoing paragraph.

V. UDMPU Oversight and Approval of Agreements Involving UDMPU Members
All agreements between a UDMPU member and the University that involve separate compensation and copyright or patent ownership must be in writing, and the UDMPU must sign off on all such agreements in a timely manner.

Patents Policy

I. Introduction
The University of Detroit Mercy (hereafter referred to as “the University”) patent policy is intended to encourage a healthy atmosphere conducive to research and development through a system of rewards and incentives for the creation of intellectual property while at the same time giving proper consideration to the relative roles any individual employee’s efforts or the University or its resources may have played in the development of that intellectual property.

The strength of the University lies in its employees. The University’s policies can provide invaluable assistance in bringing employee ideas to development and fruition within a framework of mutual trust and collegiality.

This policy is intended to spell out the responsibilities of the University and its employees and establish a framework for ethical conduct when issues covered by this policy arise. While employees are encouraged to consider the potential market value of their inventions, they shall not be held liable for failing to recognize a potentially patentable invention.

Employees of the University may create patentable discoveries during the course of their employment with the University. It is desirable in some cases to seek patent protection for these works and discoveries. Licensing the use of the property provides an opportunity for both income to the inventor and financial returns for the University. This patent policy applies to all University employees. For the purpose of this policy, “employee” shall be defined as any person who uses University resources and any intellectual property that involves use of those resources with the exception of student activities associated with coursework. For the purpose of this policy, the term of “employment” shall be defined by the time period when University resources are used for the development of any potentially patentable intellectual property. Upon termination of employment (as defined herein), the employee shall have a duty to disclose to the University all potentially patentable projects in which the University may have a property interest. This disclosure can be achieved through an employee exit interview, or by the employee’s self-disclosure. This paragraph is applicable to patent applications made within the first year after employment ends at Detroit Mercy. The University’s claims on patentable projects end 366 days after disclosure or the end of employment as defined herein, whichever is later.

Technological change has made intellectual property issues increasingly complex. As a consequence, both faculty and the University must together develop, respect and enforce clear intellectual property policies to best achieve the University’s mission of instruction, research, and providing service to the community, professions, and disciplines, while remaining consistent with academic freedom, copyright law and tradition. Goals of the policy herein include protecting the interests of the faculty, adjunct faculty, students, and the University while encouraging implementation of technology in their courses and the development of innovative courseware and educational methods. This policy is applicable to anyone engaged in academic pursuit at the University. In the United States, these seven rights are recognized: 17 U.S.C. 106, 106A.

II. Patent Committee

On an as needed basis (given that Detroit Mercy is principally focused on teaching, this will most likely be on a case-by-case basis, though the University may form a standing committee if it so chooses), the University administration shall form a Patent Committee (hereafter referred to as “the Committee”) which shall serve as an advisory committee to the president on all University patent related matters.
This Committee shall evaluate each intellectual property for potential commercial value and decide that the University either seek protection and commercialize that intellectual property or relinquish University rights to that property. The Committee reserves the right to employ outside consultants who possess the necessary expertise to evaluate the potential commercial value of a particular intellectual property submitted for review.
All matters regarding specific intellectual property coming before the Committee shall be held confidential by all members of the Committee.
The president and his/her designee shall determine the composition, tenure, and decision-making authority of the Committee.
a) The creator(s) or inventor(s) may designate two Detroit Mercy faculty members to serve on the Committee.
b) It is also recommended that the chair(s) and dean(s) of the creator(s) or inventor(s) be members of the Committee. Additional consideration should also be given to including individuals who have been involved in obtaining intellectual property protection on creative works and therefore familiar with the process.

III. Policy

Scope of Policy
- This policy applies to potentially patentable discoveries and trade secrets which are developed using University equipment, supplies, facilities, employee time, or trade secret information, or which relate directly to the University’s business, research, or development.
- The University will hold first right of refusal ownership in patents and other non-patentable intellectual products, except those covered by copyright policy, developed by its employees as a direct result of their research or employment.
- The University does not claim rights in an invention for which no equipment, supplies, facilities or trade secret information were used and which was developed entirely on the employee’s own time, unless the invention grows directly out of the business of the University or of the University’s actual or demonstrably anticipated research or development or unless the invention directly results from work performed by the employee for the University.
OSPRA
- Where research has been sponsored by private industry or foundations, licensing of patents shall be negotiated between the sponsor and the University or its agent where appropriate.
- The University will strive to protect the financial interests of all and, when necessary, act to ensure that the traditions of self-governance and academic freedom are respected.
- The University, on behalf of its constituent colleges, schools, or departments, will not accept grants or enter into agreements for the support of instruction or research that confer upon an external party the power to censor, unduly delay, or exercise effective veto power over either the content of instruction or the publication of research.
- Parties entering into such agreements shall be hereby advised that publication of research findings may be temporarily delayed in order to protect patent rights or permit the research sponsor to review the proposed publication for the sole purpose of identifying proprietary information furnished by or belonging to the sponsor.
- Unless otherwise noted in writing, the University normally retains ownership of property developed under sponsorship agreements and will negotiate rights to license the property.
- The proprietary rights of the University and the University’s employees shall be subject to the agreement between the sponsor and the University.
Determination of Ownership
- The Committee will determine whether the potentially patentable property is owned by the University, by the employee(s), by an outside sponsor, or jointly by some combination of these.
- Under the federal patent and trademark legislation of 1980 (35 U.S.C. 200 et seq.), the University has the right of first refusal to title in inventions made in the performance of federal grants and contracts. The University will assert title to and attempt to license inventions made with federal government funds so that the Congressional purpose of fostering the development of industry in the United States will be furthered.
- Patentable inventions not subject to a sponsorship agreement, or University ownership under the preceding paragraph, or the University provides a written waiver of ownership, will be the employee’s property. Unless contested by the University, the University will, on demand from the employee, issue a waiver of the University’s rights. If contested, the Committee will determine ownership.
- In cases where it would be unfair to determine that the property is wholly owned by either the University or the employee, the Committee may make a determination of equal ownership.
  - If the University, through the Committee, chooses to release its rights, no additional conditions shall be placed on the release other than consideration to compensate for the continued use of facilities and materials beyond the release date.
  - For patentable property only partially developed during the employee’s term of employment, the Patent Committee shall also have the authority to assign proportionality of property interest between the University and the “employee.”
  - The procedure for determination of ownership shall be as follows:
    - The Committee shall make its determination of ownership within 45 days of full disclosure of the invention by the inventor(s) to the Vice President for Academic Affairs and Provost. Full disclosure simply means that the disclosure must include all pertinent information which the inventor(s) have that is related to the subject invention.
    - The employee will be notified of the decision of the Committee within five days of the Committee’s determination.
    - If the Committee fails to notify the employee in writing of determination of ownership within 65 days of full disclosure, then any potential University’s rights shall automatically revert to the employee.
    - It is acknowledged that the 65 day deadline includes 15 days beyond the timeline set for this process and thereby fully extinguishes the University’s right to any ownership.
    - The employee shall have 30 days from the date of the mailing of the notice to appeal the Committee’s decision. The appeal shall be heard by the Vice President for Academic Affairs and Provost or his/her designee within 20 days of the notice of appeal. The decision on appeal shall be issued within 30 days of the deadline for submitting materials. The decision of the Vice President for Academic Affairs and Provost shall be final.
    - Following this internal appeal process, the employee has recourse to settlement in the civil courts.
Duty to Assign and Cooperate
- After the determination by the Committee and exhaustion of the employee’s right of internal and external appeal, the employee shall execute documents of assignment to convey to the University, or its assignee, all of the employee’s interest in the invention determined to be owned by the University and assist in obtaining, protecting, and maintaining patent rights.
- When discoveries are determined to be owned in part by the University and in part by the employee, the University and the employee shall enter into a written agreement apportioning 50 percent of the after-costs revenues from the invention to the inventor(s), and the remaining 50 percent to the University.
  - Cost shall be defined as direct expenditures resulting solely from pursuit, prosecution and maintenance of intellectual property rights and commercialization of the invention plus, where appropriate, any extraordinary University resources such as outside legal, consulting, marketing and licensing organizations.
  - Half of the University’s 50 percent of net revenues shall be apportioned to the creator(s)’ or inventor(s)’ Department to support further research and scholarly activity.
  - In the event of multiple inventors, those involved must agree upon an appropriate apportioning of the 50 percent of revenues provided to the inventor; in the absence of any written agreement stating otherwise, the revenues shall be equally divided amongst the inventors.
  - In the case of multiple inventors, the departmental share of revenues shall be apportioned in accordance with the same apportioning made to the inventors.
Publication and Disclosure to Third Parties
- Premature publication, public use, or disclosure of an invention can sometimes jeopardize the rights of the employee, or the University or its assignee to secure patent protection.
- Therefore, unless the Committee has issued a waiver of University’s rights, the employee agrees that there shall be no publicity or disclosure concerning the invention until patent applications have been filed.
- Once an invention is identified as potentially patentable, all publicity, public reports, interviews, news releases, speeches, public disclosures or public demonstrations of the invention subsequent to the filing of the application shall have prior clearance in writing from the University or its assignee.
- This section shall not be applicable to sponsorship agreements that impose different obligations on disclosure.
Costs and Royalties
- Following a decision by the Committee to pursue a patent for an invention deemed to be jointly owned by the inventor(s) and the University, the University shall, in a reasonably prompt manner, develop and file a patent application on the subject invention.
- All fees, legal and otherwise, associated with development of the invention and patent application shall be assumed by the University, but all such costs must be fully recovered by income generated by the invention before any net revenue accrues.
- Once costs defined elsewhere have been recovered, all additional income generated through licensing of the patent, sale of the patent or other commercialization of the invention shall be apportioned at the aforementioned percentages after a 5% administrative fee is deducted.
- Royalties allocated to inventor(s) continue throughout the revenue generation phase of the invention, regardless as to whether or not the inventor(s) remains employed at the University.
- If the University, at any time, no longer wishes to pursue further development of the intellectual property, the University will notify the inventor(s) and will execute the necessary documents assigning all rights to the inventor(s) unless precluded by prior written agreement.

IV. Works Involving the Use of Extraordinary University Resources
The University and the faculty members involved generally have a shared interest in the property rights of works involving the use of extraordinary University resources.

Examples of “extraordinary University resources” may include institutional funding or grants in support of the work’s creation including but not limited to payments to a faculty-author in excess of such faculty-author’s ordinary salary, and a reduction in faculty workload specifically to facilitate creation of the work.
The copyright to works involving the use of extraordinary University resources and all derivative works created by a faculty-author shall be owned by the University. Whether a particular work is created through use of extraordinary University resources shall be determined initially by the relevant dean, his/her designee, or the director of the unit of the University that is providing the extraordinary University resources prior to the commitment by the University of those resources. Final determination will be by mutual written agreement of the faculty author and the University. At the University’s discretion, it may grant to the relevant faculty-author a non-exclusive non-transferable license to use the work involving use of extraordinary University resources for external purposes; provided that if use of the work by the faculty-author generates income the license may provide that:
- The author shall reimburse the University for the substantial resources provided the author, or
- The author shall share income from such commercialization with the University.
A Sponsored or Externally Contracted Work (Work) shall be any work developed using funds supplied under an Sponsored Research Agreement (SRA), contract, grant, or other arrangement between the University and a third party.
- Unless the relevant sponsorship agreement requires copyright ownership by the University or conveyance of rights to a third party, the author of a work shall own the copyright to such work.
- The University will own a work where the relevant agreement requires copyright ownership by the University or conveyance of rights to a third party, in which case the University will convey rights to the third party as required. In such cases the author of the work shall be required to report the work to the vice president for Academic Affairs and provost, using such forms and procedures as that office develops.

Principal Investigator Eligibility Requirements Policy

I. Eligible Personnel
Only members of the tenured and tenure track University Faculty (faculty) and non-professorial academic research positions of similar stature listed below may routinely serve as Principal Investigators (PI), Co-Principal Investigator (Co-PI) or Project Director (PD) on sponsored projects.

Professor, tenured/tenure track (all ranks)
University Librarian
Deans

II. Responsibilities of PIs, Co-PIs, and PDs
PIs, Co-PIs, and PDs are responsible for the conduct of a sponsored project, including intellectual direction, resource allocation and fiscal stewardship, representing the project to the sponsor, administrative and personnel oversight, adherence to relevant policies and regulations, and meeting the terms of the award. Faculty have the responsibility and authority to set the direction of future research, outreach, and extension; make decisions on critical administrative matters, such as allocation of human, financial, and facility resources under their control; and to direct the activities necessary to meet sponsor obligations.

III. Criteria and Approval Process for PI Eligibility by Exception
The designation of PI, Co-PI or PD for individuals who are not listed above is limited to certain titles under limited circumstances. Individuals must meet the requirements for eligibility by exception for their specific title. Documentation that eligibility criteria have been met and will continue to be met for the duration of the individual’s appointment and/or sponsored project, must be kept on file in the unit. Confirmation is provided via signature by the Department Chair/Director/Dean, Director of OSPRA, Provost and the Vice President of Academic Affairs or President if in an administrative unit, and where applicable the Associate/Assistant Dean for Research. This signature cannot be delegated.

Individuals in this class of titles may be authorized to serve as PI, Co-PI or PD within the limitations determined by the Department, Center, Administrative Unit or College and under the conditions stated below.

Professor of Practice (all ranks)
Clinical Professor (all ranks)
Senior Research Associate
Lecturer/Adjunct Faculty
Directors
Emeritus Faculty
Postdoctoral Associates/Postdoctoral Fellows

IV. Considerations for Approval of Administrators and Staff
Full-time regular exempt non-academic staff with management or leadership responsibilities may serve by exception as PI, Co-PI or PD on a project aligned with their administrative responsibilities. The administrative department director and the VP to which the department reports must approve the request and assure that the individual has the necessary experience and qualifications to independently and successfully direct the project. The administrative unit must provide the facility, financial, supervisory, and administrative support infrastructure and resources necessary for the scientific or managerial conduct of the project and to assure adherence to relevant regulations, sponsor terms, and Detroit Mercy policy.

V. Procedure to Obtain Approval for Waiver
A letter requesting a waiver to the policy, plus the curriculum vitae of the proposed PI or project director, is to be addressed to the Director of OSPRA. The letter must include a justification as to why the waiver should be granted, and must document commitment of the department and/or school to provide the appropriate space and resources to the project(s) and/or to the individual requesting the waiver. The responsibility to ensure that any extramurally funded projects covered by this waiver are satisfactorily completed will be assumed by the department and/or school.

Process for Negotiating Non-Federal Contracts, MOUs and Sub-Awards Policy

I. Purpose
Requests for all agreements related to grant awards are to be routed through OSPRA. This includes requests for Material Transfer Agreements (MTA), Memorandum of Understanding (MOU), contracts, sub-contracts and sub-awards.

II. Negotiating and Accepting Agreements
Authority to review, negotiate, and endorse sponsored agreements has been delegated to the OSPRA. Sponsored research negotiates a range of agreements and agreement terms with potential collaborators. Each agreement – and associated negotiation – is tailored to the scope and nature of the work, the type of organization sponsoring the work, and the individual investigators and research programs involved. If information is received directly from the sponsor at the unit, school, or Principal Investigator level, communicate with OSPRA in order to expedite the negotiation and endorsement process which includes review by General Counsel. The status of document approval can be reviewed in Dynamic Forms.

III. Endorsements
An agreement must be signed, or institutionally endorsed, by the Provost and Vice President of Academic Affairs, Director of OSPRA, General Counsel and/or the President (if appropriate) for the agreement to be formally recognized by and be binding upon the University. Individual faculty members, including chairs and deans, are NOT authorized representatives of Detroit Mercy and may not negotiate or endorse sponsored agreements on behalf of the University. Many sponsors issue unilateral agreements that do not require institutional counter signatures. In these cases, OSPRA is expected to notify the sponsor if there are terms and conditions that are not acceptable to the institution or the investigator. Some sponsors issue bilateral agreements, requiring an institutional countersignature. For these agreements, OSPRA must negotiate changes to sponsor terms and conditions related to intellectual property rights, rights to publish, confidentiality, termination, and indemnification language in order to ensure appropriate protections for the investigator and the University.

Procurement Guidelines for Federal Awards Policy

Procurement guidelines have been established in adherence to CFR Title 2, Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Effective July 1, 2018, all goods and services acquired with federal funding must adhere to the following procurement guidelines.

I. Introduction
As a recipient of federal grants, University of Detroit Mercy must be compliant with Uniform Guidance in order to remain eligible to receive federal awards. Five threshold levels have been defined under sections 200.317-200.326 of 2 CFR 200 for procurement purchases made using federal funds. The policy outlines the five threshold levels for purchases and purchase requirements for each level as established by Detroit Mercy. Internal processes and procedures for obtaining goods and services will be updated, as needed, in order to comply with the Uniform Guidance standards.

II. Definitions

Aggregate dollar amount: Maximum dollar amount.
Code of Federal Regulations (CFR): The codification of the general and permanent rules published in the Federal Register by the departments and agencies of the Federal Government.
E-CFR: The electronic version of the Code of Federal Regulations
Fixed Price: Lump sum.
Micro-Purchase Threshold: The maximum dollar amount set by the federal government for allowable purchases made without competitive quotations. The current threshold is published in 2 CFR 200 section 200.67. This amount is periodically adjusted for inflation.
Office of Management and Budget (OMB): This office is responsible for overseeing and meeting federal policy, budget, management, and regulatory objectives and to fulfill the agency’s statutory responsibilities.
Qualified supplier/Qualified source/Qualified vendor: A supplier of goods, services or other tangible goods who has not been debarred (prohibited) from doing business with the Federal Government. Written documentation is required for purchases covered under the Simplified Acquisition Threshold. This documentation can be obtained from the List of Parties Excluded From Federal Procurement or Non-procurement Programs, issued by the General Services Administration and located on the System for Award Management (SAM).
Simplified Acquisition Threshold: The maximum dollar amount set by the federal government for allowable use of informal purchasing methods. The current threshold is $250,000 and is published in 2 CFR 200 section 200.88. This amount is periodically adjusted for inflation.
Uniform Guidance (UG): A set of regulations that consolidates federal guidelines impacting research administration. Per the OMB website, this guidance consolidates, streamlines, and supersedes the eight existing OMB Circulars, including Circulars A-21, A-110, and A-133. CFR Title 2, Part 200.

III. Policy

Micro-purchases ($1-$10,000): Procurement by micro-purchase is the acquisition of supplies or services, to the aggregate dollar amount of which does not exceed the micro-purchase threshold. To the extent practicable, micro-purchases must be distributed equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive quotations if the price is determined to be reasonable.
Small Purchases ($10,001-$250,000): Small purchase acquisition is the purchase of services, goods, or other property in a simple and informal manner where the aggregate dollar amount does not exceed the Simplified Acquisition Threshold. Each small purchase must include price or rate quotations from three (3) qualified sources.
Sealed Bids (>$250,000): This procurement method is used for purchases over the Simplified Acquisition Threshold. Formal solicitation is required under this purchasing method, and the fixed price is awarded to the responsible bidder who conformed to all material items and is the lowest in price. This method is the most common procurement method for construction contracts.
In order for sealed bidding to be feasible, the following conditions should be present:
- A complete, adequate, and realistic specification or purchase description is available.
- Two or more responsible bidders are willing and able to compete effectively for the business, and
- The procurement lends itself to a firm fixed-price contract and the selection of the successful bidder can be made principally on the basis of the price.
Competitive Proposals (>$250,000): Used for purchases over the Simplified Acquisition Threshold. This procurement method requires formal solicitation, fixed-price or cost-reimbursement contracts, and is used when sealed bids are not feasible. The contract should be awarded to the responsible firm whose proposal is most advantageous to the program, with price being one of the various factors.
Sole Source (Non-competitive proposals): Sole source, non-competitive procurement is appropriate only when one or more of the following circumstances apply:
- The item is available only from a single source.
- A public emergency for the requirement will not permit a delay resulting from competitive solicitation.
- The federal awarding agency or pass-through entity expressly authorizes non-competitive proposals.
- After the solicitation of a number of sources, competition is determined inadequate.
- Sole source procurements require a Bid Waiver Request Form justifying why a competitive method was not used.

IV. Additional Contract Requirements
Procurement-related contracts are subject to additional contract requirements as found in 2 CFR 200 Appendix II to Part 200: Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.

V. Conflict of Interest
University of Detroit Mercy Conflict of Interest and Code of Ethics apply to procurement transactions. No employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a federal award if he or she has a real or apparent conflict of interest. Such a conflict of interest would arise when the employee, officer, or agent, any immediate family member, partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract. The officers, employees, and agents may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to subcontracts.

VI. Exceptions
No exceptions to this policy will be made.

Subrecipient Monitoring Policy

The University of Detroit Mercy is responsible for administering subawards consistent with the requirements of Office of Management and Budget (OMB) federal regulation 2 CFR part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, and in accordance with University policies, the applicable sponsor regulations, and the terms and conditions of the Prime Award. The following policy applies to all subawards issued under sponsored awards made to the University of Detroit Mercy.

I. Introduction
As the Prime Recipient, the University remains responsible for management of funds and meeting performance goals when issuing Subawards.

II. Definitions

Contractor: For the purpose of this policy, a contract provides goods or services as part of normal business; the goods or services are ancillary to programmatic activities; the contractor operates in a competitive environment and provides similar goods or services to different purchasers.
Pass-through Entity: The direct recipient of sponsored project funds.
Pre-Award: Occurring prior to the execution of a subrecipient contract.
Prime Award: The award mechanism for the direct recipient of sponsored project funds.
Subrecipient: The recipient of sponsored project funds from a Pass-through Entity. A subrecipient has programmatic decision-making responsibilities, and performance is measured against program objectives. A subrecipient is responsible for federal compliance requirements. A subrecipient uses funds to achieve a program’s goals and objectives vs. providing goods or services.
Subrecipient Monitoring: This includes the oversight activities performed by a prime recipient that provide reasonable assurance that subawards made are being administered in compliance with applicable laws, regulations, and the provisions of the grant or contract agreement.
Uniform Guidance (UG): A set of regulations that consolidates federal guidelines impacting research administration. Per the OMB website, this guidance consolidates, streamlines, and supersedes the eight existing OMB Circulars, including Circulars A-21, A-110, and A-133. CFR Title 2, Part 200. See: https://www.govinfo.gov/content/pkg/CFR-2014-title2-vol1/pdf/CFR-2014-title2-vol1-sec200-306.pdf

III. Policy
Subrecipient monitoring encompasses the entire grant lifecycle and includes:

Pre -Award Due Diligence and Risk Assessment:
- Confirming that the agreement should be structured as a subrecipient agreement versus a contractor agreement.
- Confirming that the subrecipients are not debarred or suspended and are eligible to receive federal funds.
- Perform and document a risk assessment of the organization prior to issuing the sub-award documents. Risk assessment may include:
  - Subaward total value
  - Subaward budget size relative to total budget size/percentage passed through
  - Award size relative to the subrecipient’s sponsored research portfolio
  - Prior experience with subrecipient
  - Performance of an audit in accordance with 2 CFR 200 Subpart F
  - Prior findings from audits performed in accordance with 2 CFR 200 Subpart F
  - Location/Economic environment of the subrecipient
  - Entity type (commercial; higher ed.)
  - Yearly expenditures with subrecipient
  - Type of financial systems used to manage sponsored funding
Establishing Controls:
Controls will be established to assist in ongoing monitoring of the subrecipient site. Federal regulations which encompass subrecipient monitoring are summarized in 2 CFR 200.300-342. The Uniform Guidance, Appendix XI- Compliance Supplement, also discusses controls designed to ensure compliance with subrecipient monitoring. Requirements may include:
1. Modification of terms and conditions of subaward template based upon risk assessment.
2. Advising subrecipients of all applicable federal laws and regulations, and all appropriate flow-down provisions from the prime agreement.
3. Routine receipt and review of technical performance reports.
4. Routine review of invoices and budget-to-actual expenses.
5. Periodic performance of on-site visits, or regular contact, if necessary.
6. Option to perform audits if necessary.
7. Review of audit reports performed in accordance with 2 CFR 200 Subpart F and filed by subrecipients, as well as investigation of any audit findings.
8. Review of corrective actions cited by subrecipients in response to the documented audit findings of external auditors.
9. Consideration of sanction on subrecipients in case of continued inability or unwillingness to have required audits or to correct non-compliant actions.
Subrecipient Contract:
A subrecipient contract will be developed and routed for approval using a Contract Approval Signature Form and in accordance to the Contract Signing Policy prior to forwarding the contract documents to the subrecipient site for execution.
Periodic Monitoring:
1. Annual risk assessment review.
2. Requesting, when necessary, additional documentation to ensure allowability of costs. Documentation may include, but is not limited to, payroll records, effort certification, copies of paid invoices, descriptions of services performed, and travel documentation.
3. Obtain and review of annual audit reports and modification of subrecipient contracts based on significant findings, if any.
Closeout:
1. Verification that closeout invoice is marked “FINAL” and all supporting documentation has been received.
2. Verification that cost share obligations have been met.
3. Principal Investigator approval that technical reporting requirements have been met.

Suspended and Debarred Parties for Grant Awards Policy

The policy for suspended and debarred parties on grant awards has been established in adherence to CFR Title 2, Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. The University will not engage with suspended or debarred parties on grant awards. All expenses charged to grant funds must adhere to the following guidelines. I. Introduction As a recipient of federal grant awards, University of Detroit Mercy must be compliant with Uniform Guidance in order to remain eligible to receive federal awards. OMB guidance has been established for suspension and debarment as defined section 200.212 of 2 CFR 200. II. Definitions

Code of Federal Regulations (CFR): The codification of the general and permanent rules published in the Federal Register by the departments and agencies of the Federal Government.
Debarment: Exclusion from financial assistance from grant awards. Assistance can be in the form of procurement or non-procurement benefits. Debarment is determined by the Federal government against individuals or organizations who have committed fraud or a criminal offense in violation of federal law.
E-CFR: The electronic version of the Code of Federal Regulations
Non-procurement Benefits: Include but not limited to salary & wages, stipends, tuition assistance, speaker fees, and contractual payments.
Office of Management and Budget (OMB): This office is responsible for overseeing and meeting federal policy, budget, management, and regulatory objectives and to fulfill the agency’s statutory responsibilities.
Parties: Include but not limited to key personnel, grant staff, students, fellows, sub-recipients, contractors, individuals or organizations supplying goods, services or other tangible goods.
Suspension: Exclusion from financial assistance from grant awards. Assistance can be in the form of procurement or non-procurement benefits. Suspension is determined by the Federal government against individuals or organizations who have committed fraud or a criminal offense in violation of federal law.
System for Award Management (SAM.gov): Approved website used for verification of party eligibility.
Uniform Guidance (UG): A set of regulations that consolidates federal guidelines impacting research administration. Per the OMB website, this guidance consolidates, streamlines, and supersedes the eight existing OMB Circulars, including Circulars A-21, A-110, and A-133. CFR Title 2, Part 200.

III. Policy In accordance with federal regulations, financial transactions between the University of Detroit Mercy and parties who have been suspended, debarred or otherwise excluded by the federal government for procurement or non-procurement assistance will not be charged to grant awards. IV. Process

Requisitions, purchase orders, check requests, payroll authorizations, tuition assistance remission forms will route through normal channels.
When such documents are submitted for budget approval, a vendor check will be initiated on Sam.gov to determine if the payee has been flagged by the federal government as suspended, debarred or excluded.
A PDF copy of the Sam.gov will be obtained as documentation.
A list of all vendors paid using grant funds will be generated on a semi-annual basis and updated Sam.gov checks will occur.
If a vendor on this list is found to be suspended or debarred, a journal voucher will be initiated to move the expense off the grant fund.

V. Exceptions No exceptions to this policy will be made.

Travel Policy for Sponsored Programs

Executive Summary

Travel expenses incurred under sponsored programs can only be incurred when they directly benefit the purpose of the federal award. Travel expenses must also comply with University and funding agency policy, as well as all applicable federal and state laws.

I. Introduction

There may be time when PIs and other personnel will be required to travel as part of the scope of a federal award. When this is the case, the employees of the University need to ensure they are complying with the University and funding agency travel policy as well as 2 CFR 200.475 “Travel Costs” in order for the costs to be considered allowable.

II. Policy

Travel expenses on sponsored project accounts are allowable only where there is direct benefit to the project, when the request is adequately documented, and when the guidelines laid out in 2 CFR 200.475 are followed. A completed Travel Request Form must be submitted and approved prior to incurring travel related expenses on a sponsored project.

III. Examples of circumstances where travel expenses are typically allowable

The travel falls within the scope and benefit of the federal award.
Express consent was given by the funding agency allowing the travel.

IV. Examples of circumstances in which travel expenses are typically unallowable

Travel not in compliance with the University’s written travel policy.
.Travel not in the scope of the federally sponsored program, unless express written consent of the sponsoring agency is obtained.

V. Cost requirements on federally sponsored travel

When using funds from a federally sponsored program, care must be taken to ensure the costs would be considered reasonable under the circumstances. The following should be considered when making travel plans:

When flying by commercial airfare, the least expensive viable option should be selected. This would typically be considered “economy” under most airlines. Any selection other than this will be disallowed.
Air travel by any carrier other than a commercial carrier is expressly prohibited.
Employees will be paid a per diem for meals incurred while travelling in accordance with the University’s expense reimbursement policy.
Lodging should be made following the guidelines laid out in the University’s expense reimbursement policy.

VI. Link to University Policy

https://www.udmercy.edu/faculty-staff/procurement-services/policies.php

Get the Funding Conversation Started

Ann Serra, Dir. OSPRA
serraam@udmercy.edu
(313) 993-1469

Quick Links

CAYUSE SUPPORT
Michele Favoretto
favoremi@udmercy.edu
(313) 993-1428

Forms

Required Forms/Templates

Helpful Links

Working with OSPRA from project concept through award has significantly increased my awareness and understanding of the processes and UDM policies.

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