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Research Foundation of SUNY Cortland
Project Director's Guide
TABLE OF CONTENTS


          Job Description
          Title
          Recruitment
          Employment Application
          Offers of Employment
          Letters of Appointment
          Appointment Types
          Exempt/Nonexempt
          Regular
          Summer
          Extra Service
          Income Fund Reimbursable           Policy
          Rates           New Employee Appointment
          I-9
          Employee Appointment Form
          Extra Service - SUNY Employee
          Tax Forms
          Update Employee's Record
          Change Form
          Fellowships or Stipends
          Academic Fellowship
          Participation Stipend
          Time Sheet
          Pay Schedule
          Holiday Schedule
          Leave Record/Exception Report
Employee
Independent Contractor
          Selection
          Advance Approval
          Encumbering Funds
          Letter of Agreement (Fee Plus Expenses Under $5,000)
          Contract (Fee Plus Expenses Over $5,000)
          Payment/Documentation Requirements
          Payment to SUNY-Cortland Employee
          Payment to SUNY Employee Not at Cortland
          Payment to R.F. Employee           Purchase Requisition
          SUNY-Cortland Central Services
          Purchase Order
          Placing the Order
          Purchase Contracts
          Receiving
          Payment
          Reimbursements
          Competitive Bidding Requirements
          Equipment Purchases over $10,000           Tax Exempt Status
          Sponsor Approval
          Foreign Travel
          Foreign Travel Insurance
          Travel Payment Request
          Receipts
          Conventions & Seminars
          Transportation
          Personal Automobile
          Use of College-Owned Vehicles
          Commercial Airline
          Train or Bus
          Rental Vehicles
          Other Transportation Costs
          Travel Agents
          Meals
          Non-Overnight Meals
          Overnight Travel
          Over-the-Maximum Lodging Rates
          Hotel & Motel Fire Safety Act
          Miscellaneous Travel Expenses
          Travel Advances
          Accompanying Dependents            Direct Costs
           Indirect Costs
           Initial Budget Distribution
           Allocation Revision
           Budget Amendment
           Worksheet             Account Expenditure Summary
            Final Financial Reports
            Technical Reports

           Title to Equipment
           Property Control System
           Property Reporting

            Documentation
            Report
            Personnel Service Cost Sharing
            PARS
            PAR Form
            Reporting Periods
            IFR Appointments
            Non-RF/SUNY Personnel Service Cost Sharing
            Other Cost Sharing
            Valuation of Costs
            SUNY Cost Sharing
            SUNY-Cortland Building Use
            SUNY-Cortland Equipment
            Costs That May Not be Included in Cost Sharing
            Third-Party Non-Cash Contributions             Acceptance of Gifts
            Substantiation of Cash Contributions
            Disclosure of Goods and Services
 

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Research Foundation Personnel
   SUNY Cortland




TITLE  NAME   EXT.
Operations Manager William E. Shaut 2211
Associate Vice President for Finance Mary K. Murphy 2303 
Assistant Vice President, 
Office of Research and Sponsored Programs
Amy Henderson-Harr 2511
Secretary, Office of Research and Sponsored Programs Pam Schroeder 2511 
Assistant Fiscal Officer John Beecher 2416
Calculations Clerk II Darleen Richardson 2423 

Human Resources Assistant

Brent Danega  2302
Benefits Administrator Michelle Congdon  2302
Affirmative Action Officer Wendy McAllister 2302
Property Control Officer  Christopher Tucker 2488
OFFICE LOCATION EXT. 
Office of Research and Sponsored Programs 402 Miller Building 2511
Research Foundation Fiscal Office 335 Miller Building 2416
Human Resources 301 Miller Building 2302
Operations Manager 409 Miller Building 2211

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STAFFING & APPOINTMENTS

The Project Director is responsible for the selection of project personnel, subject to the policies and procedures of the Research Foundation, the program sponsor, and the University.

The Research Foundation Human Resources Office is responsible for personnel matters and is available to assist in the employee recruitment process and in other transactions relating to R.F. employees.

Prior to recruiting staff, it is important to determine the appropriate title and salary level for the position and to review affirmative action procedures in order to ensure that applicable position posting and outreach requirements are fully met.

JOB DESCRIPTION

A job description must include the function and scope, duties, experience and/or education required for the position.  The job description prepared for a new position must be reviewed and approved by R.F. Human Resources.

A written job description for the position to which an employee is assigned must be on file.

TITLE

The position title which is chosen must reflect the work to be performed.  A complete list of all Research Foundation position titles, corresponding title codes, position standards (descriptions), and salary grades is available in the R.F. Human Resources Office.

RECRUITMENT

Advertising is necessary only for those positions which are full-time or 50% or more and that last more than eight (8) weeks.

The Project Director may compose the advertisement which must include the statement, "The Research Foundation of SUNY is an AA/EEO employer."  The Coordinator of Sponsored Programs will review the ad before it is finalized and published.

While there is no requirements for advertising positions of eight (8) weeks' duration or less, positions of less than half-time, and positions filled by students, in the interest of fairness the availability of the positions should be widely known and as many people as practicable given the opportunity to apply.

The type of search (national/regional/local) shall be determined by the Affirmative Action Officer, based on criteria in the Research Foundation Affirmative Action Plan.

Principles of equity, fairness, and openness should be observed in every instance of the recruitment and appointment process.  Discrimination on the basis of race, creed, sex, age, disability, marital status, Vietnam Veteran Status, or other inappropriate criteria is prohibited in every instance.

EMPLOYMENT APPLICATION

All applicants for a Research Foundation position must complete a Research Foundation Employment Application form before interviews are conducted.  The employment application provides information that can protect the Research Foundation from potential complaints.  The employment application also requires the applicant's signature which authorizes the investigation of, and certifies, all statements made on the employment application.

When a search is completed, all employment applications for the position must be forwarded to the Office of Human Resources as follows:

1.  All applications for individuals not hired should be forwarded together with a copy of the ad for employment (if applicable) or a note of the position.

2.  The application of the individual hired should accompany the R.F. Employee Appointment form.

OFFERS OF EMPLOYMENT

An offer of employment (verbal or written) with the Research Foundation must convey the following information:

- The employer is the Research Foundation of State University of New York, a private, nonprofit corporation.

- The title, effective date, and salary rate.

- The employment is contingent on proof of identity and employment eligibility.

- Employment at the Research Foundation of SUNY is terminable at will and subject to the availability of funds and program needs with no expressed or implied guarantee of employment  retention.  This may be stated as follows: "Your employment under this appointment may be terminated with or without cause or notice at any time at either your option or that of the Research Foundation."

- Fringe benefits are provided by the Research Foundation of SUNY under rules in effect on the date of appointment and are subject to change as approved by the Research Foundation Board of Directors.

- The extent to which leave credits will be earned under the terms of the appointment.

An offer of employment (verbal or written) should also provide instructions on where the employee is to report on the first day of work and should request that the employee bring proof of identity and proof of either United States citizenship or employment authorization.

In order to coordinate the various types of offers made by Project Directors of grants or contracts, the Research Foundation Human Resources office will provide the formal, written offer of employment.

LETTERS OF APPOINTMENT

The Human Resources Office will send a letter of appointment to an applicant who is offered and has accepted employment with the Research Foundation in order to ensure that the employee understands the terms and conditions relating to that appointment.

APPOINTMENT TYPES

EXEMPT/NONEXEMPT

An exempt position is one that satisfies the Fair Labor Standards Act tests for exemption from eligibility for overtime payment based on salary and position responsibilities.  A nonexempt position is one that does not satisfy the FLSA tests.

REGULAR

A regular R.F. appointment is a full- or part-time appointment which is not a summer or extra service appointment.  A regular appointment may cover a short period of time or may have an open-ended termination date.

SUMMER

An R.F. summer appointment is an appointment between May 1 and September 30 that does not exceed four months in duration.

For SUNY faculty members who have academic year obligations, SUNY policy limits summer employment to two months except when approved by the campus president, who may approve summer employment for up to three months, provided:

- the period of employment does not overlap any part of the academic year obligation, and
- grant or sponsor policy does not otherwise restrict or limit such appointment.
EXTRA SERVICE

Full-time R.F. employees in exempt positions who have regular appointments and full-time SUNY professional employees may be compensated by means of an extra service appointment when:

- the work performed is different from or in addition to the person's professional obligation,
- the payment conforms to R.F. and SUNY policy,
- the work is performed outside of regularly scheduled hours,
- the sponsor has formally approved the appointment, if required, and
- the payment is properly authorized under SUNY and R.F. policy.
INCOME FUND REIMBURSABLE

SUNY employees who perform services on Research Foundation-administered sponsored projects while remaining on the State payroll have their compensation costs reimbursed to SUNY through the Income Fund Reimbursable process.  When SUNY does not receive full reimbursement from the sponsored program, the unreimbursed effort represents cost sharing.  These SUNY employees are not considered R.F. employees.

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FRINGE BENEFITS

POLICY

All Research Foundation accounts funding employee salaries will be charged for the recovery of fringe benefit costs based on the current fiscal year's approved fringe benefit rates.

Fringe benefit costs may not be waived.

Employee salaries will be charged the regular employee fringe benefit rate unless the employee is a full-time SUNY student who meets the criteria for and is appointed to certain R.F. position titles.  SUNY students appointed to one of these positions will be charged the student fringe benefit rate.

RATES

The Research Foundation fringe benefit rates for the current fiscal year (July 1 to June 30) are available online.  The components of the fringe benefit rates are provided in Attachment A.

MORE INFORMATION

For information concerning the components of the fringe benefit rate, benefit coverage during a leave of absence, leave accrual, or the holiday schedule, call the R.F. Human Resources Office (ext. 2302).

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NEW EMPLOYEE APPOINTMENT

Before hiring any individuals, Project Directors are reminded to contact the Human Resource Office for information concerning hiring requirements, job classifications and wage scale.

I-9

An I-9 (Proof of Employment Eligibility) must be completed in the Human Resource Office.  Appropriate ID must be presented.

EMPLOYEE APPOINTMENT FORM:

Standard Work Week: EXTRA SERVICE - SUNY EMPLOYEE TAX FORMS: All employees must complete forms. Send completed Employee Appointment Form and tax forms to the R.F. Fiscal Office for processing.

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UPDATE EMPLOYEE'S RECORD

CHANGE FORM

Complete:

Fill in only the information needed for a change to be made: The codes for some fields are on the back of the form.

The employee needs to sign in APPROVALS section ONLY if terminating.

Send the completed form to the R.F. Fiscal Office for processing.

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FELLOWSHIPS OR STIPENDS

Fellowship and Participation Stipend appointments are used only when services are not required of the awardee.

In many cases, a Participation Stipend is paid in a summer outreach and enrichment program.  A person engaged in a program of this type may be paid a stipend based on hours of participation.

If the terms of the award require the recipient to provide a service, the person must be appointed to the Research Foundation payroll as an employee and paid a salary or wage for the service provided.

ACADEMIC FELLOWSHIP OR PARTICIPATION STIPEND FORM

The ADMINISTRATIVE DATA and APPROVALS sections are completed for all payments.  To determine the type of award, see the definitions on the back of the form.

A recipient of an ACADEMIC FELLOWSHIP is required to sign the DECLARATION.

There are no payroll taxes withheld from these payments, but the recipient may be liable for taxes.

Send the completed form to the R.F. Fiscal Office for processing.

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TIME SHEET

Time sheets are required for each two-week payroll period from all nonexempt employees, both biweekly and hourly. Time sheets are due in the Human Resources Office on the Tuesday after payday. 

INSTRUCTIONS FOR COMPLETING TIME SHEET

          - Enter the Grant Account Number and the Percentage of Effort.

          - The percentage of effort is always 100% unless the employee is working on more than one grant and then it is split
             accordingly.

          - Actual hours worked must be recorded for each day worked. Wages are based on hours worked in full quarter-hour
            increments:

            8:15 a.m. to 12:30 p.m. equals 4.25 hours
            8:20 a.m. to 12:30 p.m. equals 4.00 hours.

          - An employee may work up to six hours without a lunch break.  After six hours an employee must take at least an
             one-half hour lunch break.

          - Nonexempt employees hired for 37 1/2 hours per week will be paid for hours worked between 37 1/2 and 40 hours
            at their regular hourly rate.

          - Nonexempt employees working over 40 hours within a single work week must be paid overtime at a rate of at least
            one and a half times the employee's regular pay rate.   Each work week stands alone and cannot be averaged with two
            or more work weeks.

          - It is recommended that students work no more than eight (8) hours per day nor more than 20 hours per week during
             school sessions and 40 hours per week during school vacations.

          - The time sheet must be signed both by the employee and the supervisor, and by the Project Director, if the supervisor
             is not the Project Director.

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LEAVE RECORD/EXCEPTION REPORT

All exempt Research Foundation employees must complete either a Leave Record or an Exception Report for each calendar month.

Exempt employees who accrue leave must complete a Leave Record form each month. Daily exceptions must be recorded on the report so that appropriate adjustments can be made in leave accrual balances for employees who accrue leave.

Non-accruing exempt employees must complete an Exception Report each month.

The Leave Record (or Exception Report) is signed by the employee as certification that he or she has worked the anticipated schedule for the period specified with the exception of the dates listed on the report.  In addition, the employee's signature substantiates salary payment.

The supervisor or Project Director's signature on the Leave Record (or Exception Report) certifies that he or she is in agreement with the information reported by the employee on the form.

Because Leave Records and Exception Reports document the services performed by exempt employees and are used to determine payments to them, these documents must be submitted in a timely manner to the R.F. Human Resources Office.

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EMPLOYEE OR INDEPENDENT CONTRACTOR

Classifying a worker as an independent contractor rather than as an employee may appear to result in financial savings and less paperwork.  However, if the employee is misclassified as an independent contractor, these perceived advantages are offset by the potential penalties that will be assessed by the Internal Revenue Service or New York State Department of Labor, by potential workers' compensation or unemployment claims and by potential liability or malpractice suits.

The Research Foundation is legally obligated to properly classify workers even if a sponsor provides funds for independent contractors in an award.

The Internal Revenue Service provides a twenty-factor control test to determine whether the degree of control over the worker exercised by the Research Foundation is sufficient to establish an employer-employee relationship.  Each determination must be made on a case-by-case basis, and documentation must be retained to justify independent contractor status.

EMPLOYEE

An employer/employee relationship exists when the Research Foundation (through the Project Director) has the right to control and direct the person who performs the services, not only as to the result to be accomplished by the work, but also as to the details and means by which the result is accomplished.

An employee is subject to the control of the employer as to what work must be done and how the work must be done.  It is not necessary that the employer actually direct or control the manner in which the services are performed; it is enough that the employer has the right to do so.

An employee is compensated through salary or wage payments subject to fringe benefits and must be appointed to the Research Foundation's payroll.

INDEPENDENT CONTRACTOR

An independent contractor is a worker subject to the control and direction of the Research Foundation (through the Project Director) for which services are performed only as to the result of the work and not as to the means.  Among the most frequently used categories of independent contractors are:

 - Consultant: an individual or firm possessing expertise in a particular field that is engaged to give advice or perform a specific task in return for an established fee.

 - Lecturer: an individual having specialized knowledge on a particular subject who is engaged to convey this knowledge by discourse to an audience in return for an established fee.

 - Technical Service: an individual or firm rendering technical and professional service for a fee.

An independent contractor is compensated based on an established fee.  Payment is made through the Research Foundation's vendor payment system.

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CONSULTANTS

A consultant is a person or firm possessing expertise in a particular field who is engaged as an independent contractor for specific advice, evaluation, or other specific tasks in return for an established fee.

SELECTION

The requirements which apply to the selection of consultants include the following:

- each potential consultant must be provided with a copy of the Research Foundation  Conflict of Interest policy during the selection process,

- the service(s) to be provided are essential and cannot be provided by persons receiving R.F. salaries under the award or otherwise compensated for their services,

- the charge is appropriate considering the consultant's qualifications, his/her normal  charges, and the nature of the services to be rendered.

ADVANCE APPROVAL

The Project Director must submit a Independent Contractor Services form to the R.F. Fiscal Office.  A copy will be returned to the Project Director after the request is approved by the Fiscal Officer.

Prior approval for consultant services is a firm R.F. requirement.  I.R.S. regulations regarding employee vs. independent contractor status are stringent (Employee or Independent Contractor); employer violations carry extremely high monetary penalties.

ENCUMBERING FUNDS

A Purchase Requisition form must be completed and sent to R.F. Fiscal Office by the Project Director, after receiving advance approval, to encumber funds to pay the consultant.

LETTER OF AGREEMENT (FEE PLUS EXPENSES UNDER $10,000)

When the expected costs of the consultant's services are under $10,000, a formal contract is not required.  The consultant will receive a Letter of Agreement from the R.F. Fiscal Office specifying the nature of the work relationship to the Research Foundation.  The consultant should keep one copy of the letter for his or her records and sign and return the other copy within ten (10) working days to indicate that he or she has read, understands, and agrees with the terms.

When the fees and expenses are greater than $2,499.99, the letter must be signed by the consultant and returned to the R.F. Fiscal Office before payment can be processed.

CONTRACT (FEE PLUS EXPENSES OVER $10,000)

When the expected costs of the consultant are $10,000 and over, a formal contract between the consultant and the Research Foundation must be executed.

PAYMENT/DOCUMENTATION REQUIREMENTS

A completed Invoice for Consultant/Lecturer Services form is the minimum documentation for payment of consultant costs.  The form will be enclosed with the agreement letter mailed to the consultant.  The invoice must contain the following information:

- consultant's name, complete home address, and business affiliation
- consultant's Social Security or federal identification number
- purchase order number (if funds were encumbered)
- description of services rendered and required reports
- dates of performance
- computation of fee and related expenses
- Project Director's dated signature
The Project Director must also sign and return the gold copy of the purchase order to the R.F. Fiscal Office.

PAYMENT TO SUNY-CORTLAND EMPLOYEE

While SUNY policy does not allow SUNY academic or professional employees to charge a fee for consulting or lecturing services performed on any grant or contract administered at his/her home campus, a SUNY-Cortland employee may be paid for extra service as an employee through the R.F. payroll.

Fringe benefits must be paid on the extra service payment.

An Employee Appointment form must be completed along with an I-9 and payroll tax withholding forms W-4 and IT-2104.

A budget amendment may be required to move allocated funds from budget category code 2001 (Consultant Services) to 1100 (Salaries and Wages) and 1600 (Fringe Benefits).

PAYMENT TO SUNY EMPLOYEE NOT AT CORTLAND

SUNY policy does not allow SUNY academic or professional employees to charge a fee for consulting or lecturing services performed at other SUNY campuses.  However, SUNY policy does allow an honorarium payment not to exceed $100.00 a day plus expenses.

If payment exceeds honorarium limits, the SUNY employee must be paid for extra service as an employee through the R.F. payroll.

Fringe benefits must be paid on the extra service payment.

An Employee Appointment form must be completed along with an I-9and payroll tax withholding forms W-4 and IT-2104.

A budget amendment may be required to move allocated funds from budget category code 2001 (Consultant Services) to 1100 (Salaries and Wages) and 1600 (Fringe Benefits).

PAYMENT TO R.F. EMPLOYEE

R.F. employees providing consulting or lecturing services must be paid for extra service through the R.F. payroll service.

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ORDERING SERVICES, SUPPLIES & EQUIPMENT

PURCHASE REQUISITION

All purchasing of services, supplies and equipment is initiated by completing a Purchase Requisition form.  This form should include:

- grant number
- budget category code
- description of the item(s) or services desired
- delivery point
The form must be signed by the Project Director and sent to the R.F. Fiscal Office. The R.F. Fiscal Office will verify that the terms of the award, sponsor guidelines and regulations allow the purchase.

SUNY-CORTLAND CENTRAL SERVICES

The R.F. grant number must be identified when ordering supplies and/or services through SUNY-Cortland Central Services.

Purchase Requisitions must be completed for supplies and services obtained through SUNY-Cortland Central Services.  The Vendor section of the purchase requisition should include the appropriate SUNY account number as follows:

- Vehicle services:  SUNY Cortland--Account #900805
- Printing:  SUNY Cortland--Account #900815
- Postage:  SUNY Cortland--Account #900845
- Central Stores:  SUNY Cortland--Account #900865
- Telephone:  SUNY Cortland--Account #900875
PURCHASE ORDER

Data from the purchase requisition is input into the computer, which encumbers the amount and prints a Purchase Order.

The Project Director will receive a file copy (yellow) and a receiving copy (gold) of the purchase order once it has been approved by the R.F. Fiscal Officer.

PLACING THE ORDER

Orders for services, supplies, and equipment will be placed with the vendor and processed by the R.F. Fiscal Office.

Project Directors who wish to place a telephone order must complete a Purchase Requisition and obtain a Purchase Order Number from the R.F. Fiscal Office.  Telephone orders cannot be placed without a Purchase Order Number.

Project Directors should avoid making any commitments directly to vendors.  A purchase requisition indicating a "confirming order" request may not be approved by the R.F. Fiscal Officer.

While individual unofficial purchases involving PICK UP of goods valued at less than $100 will be permitted in certain cases (when a prior submission of a purchase requisition is not possible), under no circumstance shall an unauthorized purchase involving SHIPMENT of goods by the vendor be permitted.

PURCHASE CONTRACTS

In some cases, a purchase order alone is not sufficient for ordering goods or services.  For instance, a purchase order for:

- complex or specially fabricated items of equipment
- long-term (one year or more) equipment maintenance
- the use of hotel facilities for meetings/conferences
would not fully protect the interest of the Research Foundation, SUNY-Cortland, the sponsor, or the project's schedules and objectives.

To ensure that the exact requirements are fulfilled, a formal written contract with the vendor is required.  The contract should include specific and detailed terms and conditions (performance standards, delivery dates, payment schedules, guarantees of the Project Director in the development and review of contract specifications.

Both parties to the contract must agree to its terms before the work begins or the services are rendered.

Project Directors are not authorized to finalize any commitment directly to a vendor without the documented approval of the R.F. Fiscal Officer.

The contract must be forwarded to the R.F. Fiscal Office and will be included as an addendum to the purchase order.

RECEIVING

The receiving copy (gold) of the Purchase Order is to be signed by the Project Director and returned to the R.F. Fiscal Office when the ordered material has arrived, is complete and undamaged.

If the order is not complete or the material damaged, the R.F. Fiscal Office should be notified.

PAYMENT

When the R.F. Fiscal Office receives the receiving copy (gold) of the Purchase Order and the vendor's invoice, payment will be authorized and a check issued.

Partial payments can be made at the request of the Project Director.  The Project Director must indicate on the receiving copy (gold) of the purchase order which items are back ordered and return the receiving copy to the R.F. Fiscal Office with an invoice for the amount due at the time.

For pre-payments the R.F. Fiscal Office needs the gold receiving copy signed by the Project Director and an invoice indicating pre-payment is required.

REIMBURSEMENTS

Under certain circumstances individuals may be reimbursed for supplies purchased with the Project Director's approval for RF grant projects.  Such purchases follow the same purchase requisition/encumbrance/purchase order procedures previously described.

Sales tax will not be reimbursed. Sales tax exempt forms are available at the R.F. Fiscal Office and will be provided on request for each vendor.  Project Directors will not be supplied with tax exempt forms.   Receipts are required.

COMPETITIVE BIDDING REQUIREMENTS

Bids or proposals are not required for procurements of any amount made under state contracts or through campus central stores and service centers.  These procurements generally satisfy the objectives of open competition and price and cost analysis.

The requirements for seeking competition for services, supplies, and equipment to be charged against Research Foundation accounts conform with SUNY-Cortland Purchasing Procedures and become stricter as dollar value increases.  The following dollar limits apply.

Dollar Limit:                Requirement:

$0 - $2,500                No documented competitive bidding is required, but prices must be certified as reasonable and
                                   representing best value.

$2,501 - $5,000         Documentation of competitive bidding or written certification that the price is reasonable and represents
                                   best value is necessary.

$5,001 - $10,000       A minimum of three written bids/quotes from responsible vendors is required.

$10,001 - $20,000     A minimum of five written quotations or sealed bids is required.

$20,001 + over          Contact the R.F. Fiscal Office for instructions.

The Research Foundation often utilizes N.Y.S. term contracts negotiated by the Office of General Services.  Besides the usual price advantage gained through the power of volume purchasing and formal competition that N.Y.S. term contracts offer, competitive bidding and procurement opportunities requirements can be avoided, saving a great deal of time and effort.  Project Directors are encouraged to contact SUNY-Cortland Purchasing for advice and recommendations.

EQUIPMENT PURCHASES ABOVE $10,000

In addition to the documentation of bidding, all proposed equipment purchases with an estimated cost above $10,000 must be compared against property control records (both R.F. and SUNY Cortland) to determine if  similar equipment is not already available.  Sponsoring agencies frequently question and disallow the purchase of "unnecessary or duplicative items".

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RESEARCH FOUNDATION TRAVEL

A sponsor's travel policy takes precedence over the Research Foundation's travel policy only when the sponsor's policy is explicitly referenced in the award document (and the Research Foundation approves the terms of the award).  Neither the sponsor's guidelines mailed separately to the Project Director or Sponsored Program office nor a budget attached to the award document is sufficient.

The Project Director is responsible for ensuring that persons traveling at the expense of the project are directly participating in the work of the project and are aware of the applicable guidelines and limitations concerning their travel.

TAX EXEMPT STATUS

The Research Foundation (R.F.) is exempt from New York State and local sales and use taxes on goods and services.  R.F. form F980, "Exempt Organization Certification", can be obtained from the R. F. Fiscal Office and should be presented to transportation, lodging, and food vendors.

Travelers to New York City should use this same N.Y.S. "Exempt Organization Certification" to claim exemption from the N.Y.C. Hotel Room Tax.

If the vendor refuses to grant the exemption because payment is made with other than R.F. funds, N.Y.S. sales tax may be reimbursed if:

SPONSOR APPROVAL

Sponsor regulations may require prior approval for out-of-state and/or foreign travel; such approval must be obtained in writing and submitted to the R.F. Fiscal Office with any travel payment request.

FOREIGN TRAVEL

Foreign travel usually requires sponsor approval.  Most sponsors have restrictions concerning mode of travel, reimbursable rates, purposes of travel, etc.  Therefore, when foreign travel is contemplated, the Office of Sponsored Programs should be consulted well in advance to ensure that necessary approvals, advances and reservations are made in a timely manner.  Approval for foreign travel must be obtained in writing and submitted to the R.F. Fiscal Office with any travel payment request.

FOREIGN TRAVEL INSURANCE

Effective January 1, 2007 the Research Foundation will offer an emergency medical benefit program for overseas travelers in conjunction with our international emergency medical evacuation coverage through International SOS.  CIGNA will insure the program, called "Medical Benefits Abroad.”  The key advantage is that in most situations travelers will no longer need to pay up front for emergency medical services and then file a claim with their US-based plan for reimbursement. CIGNA is recognized worldwide and has agreements with hospitals and other health care providers in many international locations.  Best of all, this plan is offered on a blanket basis to all RF and SUNY employees traveling on RF business at no cost to the traveler.  The cost to the RF will be absorbed by the Fringe Benefit Pool. Simply provide the traveler with a CIGNA ID card and brochure before travel begins.  Travelers (and their dependents who travel with them) will then be covered once they leave the country for all travel of 90 or fewer consecutive days.

For travelers on longer-term assignments, The RF is offering a more comprehensive benefits program through CIGNA called "Global Health Advantage," which covers routine and emergency care worldwide, and is also offered at no cost to the traveler.

For further information about foreign travel insurance please contact Michelle Congdon.

TRAVEL PAYMENT REQUEST

R.F. form F307 Travel Payment Request is used for advance and reimbursement payments to travelers.

The Travel Payment Request form should be submitted within two (2) weeks after the conclusion of the trip.

RECEIPTS

Original receipts must be attached to the Travel Payment Request form for all expenses claimed.

CONVENTIONS AND SEMINARS

Attendance at seminars or conventions must be documented by attaching the brochure or program agenda to the Travel Payment Request.

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TRANSPORTATION

PERSONAL AUTOMOBILE

Personal car mileage must be reasonable and accurately recorded on the Statement of Automobile Travel and attached to the Travel Payment Request form.

The maximum mileage reimbursement rate is established by the Internal Revenue Service.  Mileage reimbursement may be limited by a rate established by the project sponsor.

The actual costs of tolls and parking are reimbursable.

USE OF COLLEGE-OWNED VEHICLES

In accordance with State University policy, College-owned vehicles may be used only for official University business.  Travel which is directly related to a sponsored grant administered by the Research Foundation is considered official University business.

Application for use of College-owned vehicles may be made through the College Motor Pool/Transportation Center with a driver designated and the R.F. grant number identified.  The relationship of the driver and passenger(s) to the grant activity must be verified.

If the driver and/or passengers are not N.Y.S. employees, a copy of a fully approved Travel Authorization Request must be attached to the Request for Vehicle form as a requirement for scheduling the vehicle.  The Travel Authorization Request must be signature approved by the appropriate Vice President certifying that the travel is official state (University) business.

The following restrictions apply:

- Drivers must hold a valid N.Y.S. driver's license.
- The duration of travel can not exceed three (3) days.
- Personal or other unrelated travel may not be combined with official business travel.
- Any passengers must be on official business.
- Student drivers or passengers must have College prior approval.
The current mileage rate for College-owned passenger sedans is $0.14 per mile.

COMMERCIAL AIRLINE

Travelers must fly coach or tourist class.

The passenger coupon of the airline ticket is required for reimbursement.  The actual cost of airline tickets is reimbursable.

TRAIN OR BUS

Rail or bus travel should be by coach if the one-way distance is 200 miles or less.  Rail travel in excess of 200 miles one-way may be first class.

Ticket stubs must be attached to the travel payment request form for reimbursement.  The actual cost of rail or bus travel is reimbursable.

RENTAL VEHICLES

Rental vehicles may be used when it is in the best interests of the project or the Research Foundation.  For example, renting a vehicle would be considered appropriate when it:

A written justification for the use of a rental vehicle is required when traveling within New York State to document cost benefit or reasonableness.

Vehicles must be rented in the name of the Research Foundation of SUNY.  This ensures that both the Research Foundation and the traveler are properly covered and eliminates any confusion regarding liability for coverage in the event of a claim.

Rental agencies may offer the following types of insurance:

Travelers should follow the Guidelines for Rental Vehicles for each type of insurance.

Tolls, parking fees, and fuel are reimbursable.  Original receipts are required.

The cost of Personal Accident Insurance (PAI) or Personal Effects Insurance (PEI) is not reimbursable.

The original rental invoice and an explanatory statement of the rental vehicle use must be attached to the Travel Payment Request form.

OTHER TRANSPORTATION COSTS

Expenses for the following types of related transportation are reimbursable:

- travel between residence or official station and local transportation terminal;
- travel between one transportation terminal to another transportation terminal;
- travel between transportation terminal and lodging at destination;
- travel between transportation terminal and work site at destination;
- travel between lodging and work site at destination.
The actual cost of taxicabs, bus or subway trips are reimbursable with receipts.

TRAVEL AGENTS

If transportation is arranged through a travel agent, use form F281 Purchase Requisition to initiate payment directly to the travel agent.

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MEALS AND LODGING

Meals and lodging are allowed when a person is in "official travel status" (at a distance greater than 35 miles from the person's official station or residence).

When the traveler is in travel status for less than a full day and incurs no lodging charges, an allowance or reimbursement for breakfast and dinner will be made according to the guidelines listed below:

MEALS

On the day of departure, the traveler is eligible for:

- breakfast, if departure occurs before 7:00 am.;
- dinner, if departure occurs before 6:00 pm.
On the day of return, the traveler is eligible for:
- breakfast, if return occurs after 8:00 am.;
- dinner, if return occurs after 7:00 pm.
With receipts meals will be reimbursed up to a maximum rate determined by the destination (R.F. Travel Rates - Domestic; R.F. Travel Rates - Foreign).

Without receipts a breakfast and/or dinner will be reimbursed according to Non-overnight Meal Payment Allowances.

No allowance or reimbursement will be made for lunch.

No reimbursement will be made for alcoholic beverages.

Foreign travel adjustments to meals and incidentals expenses are determined by Federal policy.

NON-OVERNIGHT MEALS

Payments to R.F. and SUNY employees for non-overnight meal expenses that do not meet the I.R.S.' business connection requirement will be included in the employees' paychecks as income (and therefore will be taxed).  Payments to non-employees for non-overnight meal expenses are also taxable and must be reported by R.F. to the I.R.S.

For payments for non-overnight meal expenses that do not meet the I.R.S.' business connection requirement:

- R.F. employees must use form F233 Taxable Meal Payment Request and Authorization Form.
- SUNY employees must request payment through SUNY Accounts Payable (R.F. will  reimburse SUNY), and
- Non-employees must use form F307 Travel Payment Request.
In order to be reimbursed for non-overnight meals that meet the I.R.S.' business connection requirement, the R.F. or SUNY employee must provide a written statement indicating that the meal was part of a specific Research Foundation business meeting.  The documentation should state the date, the parties involved, and describe the business transaction.

For payments for non-overnight meal expenses that meet the I.R.S.' business connection requirement, all individuals use form F307 Travel Payment Request.

Receipts are not required for allowances but are required for reimbursement of actual costs incurred.

OVERNIGHT TRAVEL

The destination determines the maximum allowance or reimbursement per diem rate (R.F. Travel Rates - Domestic; R.F. Travel Rates - Foreign).  The per diem rate includes an allowance for:

- lodging,
- meals (either breakfast and dinner, or dinner and breakfast, depending on the time of departure),and
- applicable taxes.
Receipts for lodging are mandatory and must contain the following information: If lodging is shared, the name(s) of the other employee(s) must be included on the Travel Payment Request form, and each employee must claim only their share of the actual lodging cost.  If lodging is shared with a non-employee (i.e., spouse), the employee must document that the rate claimed is the rate for single room occupancy.

Receipts are not required for meals when the traveler is in overnight travel status and eligible for a full meal allowance (a combination of one breakfast and one dinner).

On the day of return the traveler is no longer in overnight travel status; the traveler must present receipts when claiming meal expenses above Non-overnight Meal Payment Allowances.

OVER THE MAXIMUM LODGING RATES

The Research Foundation of SUNY extends to R.F. Operations Managers the authority to approve exceptions to standard travel rates when deemed appropriate and necessary.  On this campus, review for pre-approval of over-the-maximum requests is a firm requirement.

All such requests (including justification) must be submitted in writing to the Operations Manager BEFORE the trip.  A signature-approved copy of the request must be attached to the Travel Payment Request form.

HOTEL & MOTEL FIRE SAFETY ACT

The Hotel and Motel Fire Safety Act of 1990 requires that all conventions, conferences, and meetings which are sponsored by federal funds be held in places meeting the requirements of the Act.

Organizers of such conferences should be primarily responsible for compliance; however, all travelers under federal funding sponsorship should be aware of these requirements.

Project Directors involved in organizing an event connected in any way with federal funding should verify that the location is on the list of approved sites.  For information on approved sites, please contact the R.F. Fiscal Office.

MISCELLANEOUS TRAVEL EXPENSES

Necessary local and long distance telephone calls for business purposes are reimbursable when appropriately documented on the Travel Payment Request form.  Long distance telephone calls must be supported by listing on the form:  name of the party called, place called, date of call, and reason for call.  For local calls, only name of the party called and date of call are required.

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TRAVEL ADVANCES

Advances may be obtained using form F307 Travel Payment Request for amounts equal to 100% of common carrier transportation costs plus 80% of other anticipated transportation, meal and lodging costs.

Requests for travel advances must be submitted to the R.F. Fiscal Office ten (10) business days before the departure date.  Advance checks will be available at the R.F. Fiscal Office three (3) business days before the departure date.  The R.F. traveler must provide signature acknowledgment of check receipt.

There is a limit of one trip per travel advance.

If the trip is taken, the traveler completes the Actual Expenses section of a second Travel Payment Request form and submits it with receipts to the R.F. Fiscal Office within two (2) weeks.

If the trip was canceled, the funds are returned to the R.F. Fiscal Office within two (2) weeks.

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ACCOMPANYING DEPENDENTS

Travel costs for dependents accompanying the traveler are not reimbursable except when allowed by the sponsor.  Written evidence documenting sponsor approval must be attached to the travel payment form in all cases when such costs are claimed.

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GRANT ACCOUNT BUDGET/ALLOCATIONS

Once an award has been made and accepted, the Research Foundation establishes an account and posts expenditure categories based on budget information approved by the sponsor.

DIRECT COSTS

Direct costs are those specifically and clearly assignable to project activities and include, but are not limited to, salaries and wages, fringe benefits, equipment, supplies, travel, publication expenses, and so on.

Direct costs are incurred at the discretion of the Project Director, in accordance with project budgets, sponsor regulations, and SUNY-Cortland and Research Foundation policies and procedures.

INDIRECT COSTS

Indirect costs are support costs incurred through the use of SUNY-Cortland facilities and resources in the conduct of sponsored program activities and cannot be identified specifically with a particular sponsored program.  These costs include operation and maintenance of buildings and equipment, depreciation and use allowances, administrative expenses, and library costs.

Reimbursement of indirect costs to SUNY-Cortland is subject to the policies of the respective sponsor and is accomplished by applying an indirect cost rate, developed by Research Foundation, to the direct cost base.

INITIAL BUDGET DISTRIBUTION

It is the joint responsibility of the Project Director, Sponsored Programs and R.F. Fiscal staff to review the initial budget distribution to verify that the category codes assigned to budget line items are appropriate.

ALLOCATION REVISION

Allocation Revisions are any redistribution of category code allocations which are totally at the discretion of the campus and do not require sponsor approval or notification.  Generally Allocation Revisions are used to correct errors in the initial posting of the grant account or to maintain budget distributions reflective of spending plans allowed by the sponsor.

BUDGET AMENDMENT

A change in the scope or terms of the project contract requires sponsor notification and approval.  Budget amendments are initiated by the Project Director, reviewed by the R.F. Fiscal Office, and executed by the Sponsored Programs Office.

WORKSHEET

The use of the Grant Account Budget/Allocation Transaction worksheet is necessary for all phases of the budgetary process.  Proper and accurate category code distributions of funding consistent with sponsor intent is an essential part of project management.

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COST SHARING

Cost sharing occurs when SUNY, the Research Foundation, or a third party contributes unpaid personnel service effort or other than personnel service (OTPS) items, such as supplies, rental space, or indirect cost recovery at less than the applicable rate, towards the total direct or indirect costs of a project.

Cost sharing is considered required if:

- The award document specifically stipulates it.
- Sponsor general or specific terms stipulate it.
- Cost sharing is included in the application and the award document does not specifically note that it is not required.
DOCUMENTATION

The Project Director and the R.F. Fiscal Office must maintain data to substantiate cost sharing throughout the project to:

- include actual information in billing and financial reporting.
- be used in effort reporting.
- determine and document the project's total costs.
- be used in calculating indirect cost rates.
Neither SUNY-incurred costs nor third-party in-kind contributions count toward satisfying matching or cost-sharing requirements unless they can be verified by the project records.

REPORT

Form 286 Record of Estimated Effort for PARS Reporting and Other Cost Sharing or Matching Commitments must be completed by the Project Director for all federally funded accounts, whether cost sharing is voluntary or required by the sponsor as a condition  of the award.

For all nonfederally funded accounts, the form must be completed only when cost sharing is required by the sponsor.

Form 286 must be signed by the Project Director and the Fiscal Officer, certifying that the sponsor requirements are being met.

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PERSONNEL SERVICE COST SHARING

SUNY-Cortland is required to record the actual distribution of effort (between SUNY and  grant obligations) of all SUNY employees performing services on federally sponsored projects.  The records must reasonably reflect the activity for which the employee is compensated by SUNY-Cortland.

PARS

In order to comply, the Research Foundation uses the Personnel Activity Reporting System (PARS) that provides the sponsor with after-the-fact reports of the distribution of effort for which  and SUNY employees are compensated and obligated to perform.  Distribution of effort is reported on a percentage basis rather than on the basis of time.

If the personnel service cost sharing is not supported by properly completed PAR forms, a potential for after-the-fact disallowance exists.

PAR FORM

A PAR form is used to record and certify the effort of:

- Research Foundation professional employees
- Research Foundation non-professional employees
- SUNY professional employees
- SUNY nonprofessional employees
For each reporting period R.F. Central sends PAR forms to the Office of Sponsored Programs.   After an initial review by that office, the PAR forms are distributed to the Project Directors for final completion.

REPORTING PERIODS

R.F. and SUNY nonprofessionals report and certify effort at least monthly.

R.F. and SUNY professional employees report and certify effort for the following time periods:

    September 1 - December 31
    January 1 - May 31
    June 1 - August 31
IFR APPOINTMENTS

When a SUNY employee is appointed to a  project account through an IFR appointment, and the percent of effort the person will expend on the project does not equal the percent of the employee's salary paid by the sponsored project, the remaining unreimbursed effort represents cost sharing.

NON-/SUNY PERSONNEL SERVICE COST SHARING

Personnel service contributed by non-SUNY and non-R.F. sources may be documented by properly completed and certified PAR forms or an alternate form of documentation (such as a certified list of persons and the amount of effort contributed by each ch) after the effort has been contributed.

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OTHER COST SHARING

Other cost sharing (direct costs, such as supplies, equipment, rental space, etc.) should be documented by obtaining invoices, receipts, or other acceptable forms of documentation as the activity occurs throughout the project.

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VALUATION OF COSTS

SUNY COST SHARING

SUNY in-kind contributions are valued as any other SUNY cost in accordance with cost principles.

Whether or not they require a cash outlay, SUNY in-kind contributions must be an allowable cost to be counted toward the project.

SUNY-CORTLAND BUILDING USE

The value of college space (office, lab, etc.) is calculated from net square footage costs, provided by the SUNY-Cortland Business Office based on the physical space inventory maintained by the Office of Facilities Planning.

SUNY-Cortland building space used jointly by more than one function (as determined by the users of the space) will be allocated to the benefiting functions on the basis of the employee FTEs.

Building space may not be included in cost sharing if it is already included in the indirect cost rate.

SUNY-CORTLAND EQUIPMENT

SUNY-Cortland equipment usage may be counted towards cost sharing if the equipment is:

- properly allocable to the project (program specific), and
- not already included in the indirect cost rate.

Cost sharing of equipment will be computed by applying the straight-line depreciation method based on the acquisition cost of the equipment and its period of useful life (in accordance with I.R.S. guidelines outlined in Publication 946).

If equipment is used jointly for the sponsored project and other SUNY-Cortland work, the equipment will be allocated to the benefiting functions on the basis of employee FTEs.

COSTS THAT MAY NOT BE INCLUDED IN COST SHARING

Certain costs may not be included in cost sharing for grants using the federally negotiated indirect cost rate.  Examples include costs incurred for:

- equipment
- building space
- general and departmental administration
- general institutional services
Indirect costs that have been waived cannot be included in cost sharing unless preapproved by the sponsor.

THIRD-PARTY NON-CASH CONTRIBUTIONS

Third-party in-kind contributions must be:

- necessary to accomplish program activities, and
- allowable if SUNY were required to pay for them.
Valuation of third-party in-kind contributions is "what it would have cost if SUNY had paid for the item or service itself."  The R.F. Fiscal Office can assist in determining the value of third-party in-kind contributions.

All third-party in-kind contributions must be supported by documentation.

Records must be retained to show how valuation was calculated.

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REPORTS

ACCOUNT EXPENDITURE SUMMARY

The Account Expenditure Summary (AES) report is printed by R.F. Central on a monthly basis and provides a comparison of encumbrances and expenditures to budget by category.  These reports are distributed to Project Directors through the R.F. Fiscal Office. Apparent discrepancies should be reported to the R.F. Fiscal Office immediately.

The line item encumbrance and expenditure information presented on the AES is also available at any time through on-line inquiry at the R.F. Fiscal Office.

FINAL FINANCIAL REPORTS

Most sponsors have a deadline of 90 days after termination of the project for submission of final financial reports. The Research Foundation also applies this standard to the closing of R.F.-sponsored accounts and those funded by various donors or other private agencies which have not specified a submission date.  This provides a reasonable time frame to complete any necessary closing activity and reports on a timely basis.

The R.F. Fiscal office (in conjunction with the Project Director) will perform a review of each terminated account, in detail, to determine that all expenses and/or adjustments are made prior to closing the account.  This review would include (but not be limited to) personnel/payroll charges, open purchase orders pending receipt of invoices from the vendor, invoices in-house which are charged against the accounts, and final adjustments to be made for outstanding travel advances.

The R.F. Fiscal Office will review final adjustments to ensure compliance with sponsor, campus, and R.F. policies.  All adjustments should be processed as soon as possible so that the reporting deadline can be met.

Upon completion of all adjustments agreed to by the Project Director and the R.F. Fiscal Office, an Account Expenditure Summary printout reflecting final expenditures to be reported is signed by the Fiscal Officer and forwarded to R.F. Central in Albany.

Sponsoring agencies may require final reports with a detailed listing of expenditures.  The R.F. Fiscal Office maintains the information used to compile these detailed reports and, therefore, completes the required forms. Usually the sponsor sends these forms with the award to the Project Director. If the Project Director does not receive the forms, he/she should contact the program officer representing the sponsor immediately.  In either case the Project Director should forward the final expenditure report forms to the R.F. Fiscal Office as soon as possible.

Upon receipt of the authorized Account Expenditure Summary printout and the detailed expenditure report, if required, R.F. Central will initiate the documents needed to effect closing of the account.

Late filing of reports can result in sponsor action to withhold final payments or renewal awards and can impact future grant activity at SUNY-Cortland.

TECHNICAL REPORTS

The requirements for technical reports vary among sponsors and are set forth in grant and contract terms and conditions or related sponsor regulations.

The preparation of the technical report is the Project Director's responsibility.  The Office of Sponsored Programs must record technical report information on an account report system for the Research Foundation.  Project Directors, therefore, are required to send a copy of all technical reports, along with accompanying cover letters, to the Office of Sponsored Programs.

Delays in filing technical reports may have an adverse effect on applications for new funding or payments of amounts due on the account.

Because of the varying nature of technical report requirements of different sponsors, it is advisable to contact the program officer representing the sponsor and the Office of Sponsored Programs for information regarding technical report requirements.

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EQUIPMENT CONTROL

The Project Director is accountable for equipment purchased with grant and contract funds whether the title to the equipment is retained by the Research Foundation or by the sponsor.

Tags, which must be affixed to the equipment, indicate where title is vested and are issued by the SUNY-Cortland Property Control Officer for all items of equipment that cost or are valued at $500.00 or more and have a life expectancy of two or more years (New Equipment Information form).

TITLE TO EQUIPMENT

Title to equipment normally vests with the Research Foundation unless the sponsor retains the title.  Different sponsors have established varying cost levels for determining title retention.

PROPERTY CONTROL SYSTEM

Information about all equipment purchased or used on a sponsored project is maintained on SUNY's computerized Property Control System (PCS).  The PCS tracks purchased equipment as well as sponsor-furnished equipment.  Periodic physical inventories are required by Research Foundation to verify the location of items of equipment that are in the PCS.

PROPERTY REPORTING

The Project Director must notify the Property Control Officer if any Research Foundation is (Transfer/Disposal form; Off-campus Use form)

- physically relocated,
- transferred,
- traded in,
- permanently damaged,
- surplused/disposed of,
- lost/missing, or
- stolen.
If required by the sponsor, the Research Foundation will prepare a final property inventory when the project terminates.  The Project Director submits this inventory to the Sponsored Programs Office for certification before it is sent to the sponsor.

If equipment must be retained for use on another project, the Sponsored Programs Office must be informed. It may be necessary to request the sponsor's permission to use equipment after the project ends or to justify continued use on a programmatic basis.

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GIFTS, CONTRIBUTIONS AND FUND-RAISING

ACCEPTANCE OF GIFTS

The Operations Manager is authorized to accept on behalf of the Research Foundation gifts of money or personal property when the following conditions have been met:

1. The chief administrative officer has determined that the gift is acceptable.

2. The chief administrative officer agrees that SUNY-Cortland will be responsible for  any additional expenditures associated with the acceptance of the gift.

3. The donor has provided RF with:

  - an outside appraisal of the gift if the donor seeks a tax deduction, or
  - a statement of approximate market value, if the donor does not seek a tax deduction

4. The gift is unconditional.

SUBSTANTIATION OF CASH CONTRIBUTIONS

The Internal Revenue Service (IRS) requires that donors contributing $250 or more in cash or by check acquire written substantiation of their charitable contribution from the recipient organization.

In order to maintain good will on the part of donors and to avoid time consuming after-the-fact research, the Sponsored Programs Office will provide a written Contribution Acknowledgement to the donor as soon as the contribution is received.  The Operations Manager or delegate must sign the statement.

DISCLOSURE OF GOODS AND SERVICES

The IRS requires that organizations providing goods or services to a donor in exchange for a charitable contribution in excess of $75 in cash or by check must give to the donor a written statement (Contribution Acknowledgment) that:

1. Provides a good faith estimate of the normal cost of such goods or services, and

2. Informs the donor of the amount of the contribution that is deductible (that is, the contribution amount minus the value of the goods or services).

The disclosure statement must be made when the contribution is solicited or when it is received and must be provided in a manner that is reasonably likely to come to the attention of the donor (such as in a separate document).

The Operations Manager or delegate must sign the statement.

The disclosure of what goods or services are worth is not necessary if:

- the donor receives only token goods or services, such as a pen or coffee mug, or

- the transaction involved the purchase of goods or services at typical fair market cost including a normal profit margin.

If disclosures are not provided, Research Foundation is subject to IRS fines of $10 per contribution, up to a maximum fine of $5,000 per fund-raising event.

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