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Division of Title III Administration and Sponsored Programs
Copyright Policy

Work Under Grants

Unless otherwise provided by the terms of the grant, when copyrightable material is developed in the course or under a grant, the grantee is free to copyright the material or permit others to do so.

Work Under Sub Grants

Unless otherwise provided by the terms of the grant or sub grant, when copyrightable material is developed in the course of or under a sub grant, the sub grantee is free to copyright the material or permit others to do so. The federal awarding agency reserves a royalty-free, nonexclusive, and irrevocable license to reproduce, publish, or otherwise use, and to authorize others to use, for Federal Government purposes: (1) The copyright in any work developed under a grant, sub grant, or contract under a grant or sub grant; and (2) Any rights of copyright to which a grantee, sub grantee, or a contractor purchases ownership with grant support.


Universities and colleges are discovering that there is profit in patents; patents offer the University a return on it research investment. Changes in the federal patents/ownership rules make patents further attractive. The current patent law give universities and nonprofit organizations a first right of refusal to title inventions made in performance of federal grants and contracts. OMB bulletins update patent information and offer detailed information on title rights, subcontracts, inventions, etc.

Conflict of Interest

In compliance with OMB Circular A-110, Virginia Union University maintains the following standards of conduct governing officers, employees, or agents engaged in the award of administration of contracts using federal funds. No employee, officer or agent will participate in the selection, award administration, or contract in which federal funds are used, where to his/her knowledge, any of the following has financial interest in the contract:

  • The employee, officer or agent;
  • Any member of his or her immediate family;
  • His or her partner;
  • An organization in which any of the above is an officer, director, or employee; and
  • A person or organization with whom any of the above individual is negotiating or has any arrangement concerning perspective employment.

Employees, officers or agents may not solicit or accept gratuities, favors or anything of monetary value from contractors or potential contractors. Violations of - or requests for exceptions to this policy will be reviewed by the President. If violations to these
standards are found, officers, employees or agents will be subject to disciplinary actions as recommended.

Human Subjects, Laboratory Animals, Recombinant DNA, Hazardous Materials
and Radioisotopes

If a proposal is to involve any of the items listed above, there are procedures to follow and approvals to be obtained. The OSP can assist with information on these. Persons should check on these items early in the proposal development because they all require
committee approval.

Drug-Free Workplace

Many granting agencies require an “Assurance Statement” that the grantee will provide a drug-free workplace for grant activities. Check with the OSP.

Policy on Indirect Costs

Indirect cost is money provided to institutions to cover overhead cost for supporting grant operations. It costs money for a grant to operate on a campus, and it should be understood that the indirect cost belongs to the institution to help defray these costs. Virginia Union University permits a percentage of indirect costs to be returned to the PI and/or the department of origin. These monies cannot be used to increase salaries. It is hoped that they will be used in a manner that would further enhance research and
development efforts on campus.

Policy on Faculty Release Time

All release time associated with externally funded projects during the academic year must be fully paid for by the sponsoring agency. Therefore, proposal budgets must reflect the full cost of release time (salary, fringe benefits, indirect costs) to the funding agency. Chairpersons may not award release time to a faculty member at the University’s expense in order to carry out activities associated with an externally funded project. Faculty who have release time for the academic year may not defer that time in order to gain more release time in any one semester. For example, faculty may not combine two semesters of release time into one. Any exception will require recommendation of the Dean, the Vice President for Academic Affairs, and the President.


Employment Compensation on Research and Sponsored Program Activities

A portion of a faculty’s salary, consistent with time and effort on the project, can be charged to the grant. The total distribution of one’s time cannot exceed 100%. Additionally, grant funds cannot be used to increase one’s base salary. Nine-month
persons can be compensated during the summer months consistent with Virginia Union University’s policy on summer employment.

Salary Supplements

Faculty can be compensated up to an additional 33% over their base pay for work performed under outside funding. Several conditions must be met. (1) The supplement cannot accompany release time from teaching; it is intended to handle the overtime
situation that occurs when teaching and research are performed during the same semester. Some situations involving large or multiple contracts may justify a combination of release time and supplementary pay. (2) The outside funding must cover the supplement and its associated indirect cost. When funds do not permit a full 25%, application may be made for a smaller supplement. (3) Application must be made and approved in advance each semester. Forms are available in the Office of Academic Affairs.

Federal and State Grant Expenditures

All expenditures including the employment of personnel on federal and state grants must be cleared through the OSP.

Transfer of Principal Investigator to Another Institution

If the PI transfers from Virginia Union University to another institution, the grant, because it was awarded to Virginia Union University and not to the individual investigator, remains with the University, unless in petitioning to the Special Assistant to the President/Title III Administrator, it is released. All equipment purchased with grant funds also remains with Virginia Union University unless the P.I. requests, in writing, and is granted permission from the Special Assistant to the President/Title III Administrator. The granting agency must also approve the proposed change of institution.