In accordance with NIH policy, individuals who have joint University and Department of Veterans Affairs (VA) appointments are required to disclose the nature and extent of their joint appointment when being included as personnel on an application submitted by the University to the National Institutes of Health. Disclosure should also be included in applications/proposals with all federal agencies. As specified in the instructions to the PHS 398, individuals with joint appointments, should do the following:
- Type of Appointment/Months
List the number of months per year reflected in the University appointment. (In most cases at UC Denver this should be 12 months per year - as compared to an academic year and summer basis). Identify the existence of a joint appointment with an asterisk (*) next to the value you place in the Type of Appointment/Months section. At the end of the personnel section make a note that the asterisk (*) indicates a Joint University/VA appointment.
- Percent of Effort on Project
List the percentage of the University appointment that is to be devoted to this project. For those cases in which a portion of the VA appointment will also be devoted to the project, complete the type of appointment and the percent of VA effort on a separate line. Do NOT include any salary compensation for the portion of the VA appointment that will be devoted to the project. An asterisk (*) should also be included next to the zero dollar value, to clarify that the non-salary is related to the VA appointment.
- Institutional Base Salary
The individual's salary with the University determines the base salary for computing the NIH salary and fringe benefit request. Individuals may request the University's share of their salary in proportion to the University effort devoted to the research project.
- The Budget Justification
All individuals on a proposal who have a joint University/VA appointment must disclose the joint appointment on the budget justification of the application. In addition, a formal Memorandum of Understanding (MOU) for each joint appointee must be included as part of the budget justification. The MOU serves to provide a full explanation of the individual's total responsibilities under the joint appointment. Specify the title of each appointment, the types of responsibilities (teaching, research, clinical, consulting, and administration) and the proportion of each responsibility to the total set of responsibilities. Please see the example memorandum of understanding (DOC). The Momerendum of Understanding forms can be obtained by using the link bellow: Memorendum of Understanding.
- Cost Sharing
Please note that effort expended on a VA appointment on a grant or contract routed through the University must be approved by the VA and disclosed to the sponsor. Any such effort does not fulfill any mandatory cost share requirement even with sponsor approval, unless approved by Congress. Any effort should be referred to as effort expended on a VA appointment and must never be referred to as “cost share”. It is not acceptable to cost share with other federal funds unless it is specifically authorized in the appropriating language.
- Modular Grants
Disclosure of the UC Denver/VA appointment and the Memorandum of Understanding should be included in the Budget Narrative. Either through the description in the Budget Narrative or the Memorandum of Understanding, it should be disclosed to NIH what portion of the time committed will be out of UC Denver's effort and what portion will be out of VA time.
- Routing and Responsibilities
The Principal Investigator's signature on the application and on the UCD Approval of Application for Grant or Contract (also called the Routing Form) certifies that: (1) any individual included in the proposal who has a joint University/VA appointment has disclosed the nature and extent of the appointment with a formal Memorandum of Understanding between the University and the Department of Veterans Affairs (VA); and (2) there is no possibility of dual compensation for the same work, or of an actual or apparent conflict of interest regarding such work.
It is the principal investigator's and the department's responsibility to insure that all joint University/VA faculty listed on the budget page have disclosed the UC Denver/VA effort information on the budget page and justification and have included the MOU form as part of the application. Grants and Contracts will work to assist departments in a more complete implementation of this requirement.