Grants

1. Purpose

The Evergreen State College welcomes grant funding from external organizations to help fulfill its role as a public institution of higher education and encourages faculty and staff to pursue grant funding for projects that support the College’s education and public service mission. This policy describes general requirements for grant seeking and administration, defines grant acceptance criteria, authorizes a procedure for making grant acceptance decisions, and defines the roles and responsibilities of grant directors and principal investigators, administrators, and offices engaged in seeking and managing grants.

2. Rationale

Although grants often emerge from individual interests and initiative, they are awards to the College and can have significant institutional impacts. When the College accepts a grant, it agrees to steward those funds in accordance with the funding organization’s conditions of award. The College should only accept grant funding when there is reasonable assurance that it has the capacities to be successful in meeting the conditions of award. Furthermore, accepting a grant initiates a relationship between the College and one or more external organizations; such relationships, which reflect Evergreen’s values and priorities as an institution, should be entered into advisedly. Finally, like any other source of revenue, grant funds are College funds, and activities funded by grants are de facto activities undertaken and approved by the College. Grant activities are as much an expression of the College as activities funded by other means. The risks as well as the appropriateness of potential grant activities are important considerations in seeking and accepting grant funding.

3. General Provisions

3.1. This policy applies to grants to The Evergreen State College (College) and grants to The Evergreen State College Foundation (Foundation) that support College activities.

3.2. Only the College or the Foundation may apply for and accept grant funding on behalf of Evergreen.

3.3. For the purposes of this policy, grants include subawards to the College or Foundation made by a pass-through entity.

3.4. The grants office is the only entity authorized to submit grant proposals on behalf of the College or the Foundation. Grants from proposals not submitted through the grants office may result in non-acceptance.

3.5. Grant proposals will request the maximum indirect costs allowable. Only the president or chief financial officer may waive collection of indirect costs.

3.6. Ensuring grant compliance and adherence to conditions of award is a shared responsibility of the grant director or principal investigator (PI), the division leader where a grant is administered, the grants office, and the grant accounting office. When questions or issues about compliance arise, all parties shall work together to reach consensus on an interpretation or action. Final determinations of compliance rest with the grants office prior to award of funds and with the grant accounting office after award of funds.

3.7. All grant activities and expenditures made by the College must adhere to College policies.

4. Employment Provisions

4.1. Grant projects and grant-funded employees are subject to the same employment laws, policies, and practices as other College offices and employees—including but not limited to employee recruitment, position classification, collective bargaining, compensation, time and leave provisions, training, and performance.

4.2. In addition to other grant employment requirements, a grant director or PI must:

• Have a current eligible employment relationship with the College through the duration of the grant.
• Complete the College’s grant administration training every three years or as required by the grants office.
• Serve as the primary point of contact for all grant-related business within the College and with the funding organization.
• Oversee all grant activities to ensure the grant meets the conditions of award and other requirements.
• Provide reports and other information about grant activities and progress, when requested, to the president, division leader, grants office, grant accounting office, and other offices as required.

4.3. Resource faculty members, students, or other volunteers without a current eligible employment relationship with the College may be appointed to serve on grant projects with approval of the division leader where the grant is administered. They are not eligible to serve as a sole PI or director. They may serve as co-director or co-PI under management of the PI or director if they meet the qualifications of the role. Such grant-sponsored volunteers must follow College policies and practices, and their duties must conform to allowable volunteer activities. For example, volunteers and resource faculty do not have authority to supervise College employees or students and may have limited access to College resources, records, and information systems. Their duties should recognize these and other limitations.

4.4. All employees and volunteers working on a grant must also meet requirements specified by the grant, including training and adherence to other relevant policies, such as the Financial Disclosure for Federally Funded Grant Projects, Use of Human Subjects, Non-discrimination, and Research Misconduct policies.

4.5. College employees who receive grants directly as individuals (i.e., in their own name and with payment flowing directly to them and not through the College or Foundation) are subject to Evergreen’s Outside Employment Policy when working on such awards.

5. Grant Acceptance Provisions

5.1. Grants must adhere to all provisions of this policy to be accepted.

5.2. Final authority to accept or decline grant funding rests with the president of the College. In practice, the president designates this authority to the division leader and the chief financial officer but may revoke that designation at will. The president may also decline grant funding for reasons not covered in this policy.

5.3. In addition to the president, the executive director of the Foundation must also approve grants made to the Foundation.

5.4. The purpose and activities of grants must adhere to the College’s commitment to ethical and social responsibility. As a public institution of higher education, Evergreen commits itself to operate within sound ethical principles in all its activities, including those funded by grants. This is further reflected in the College’s mission, which states that the College “supports and benefits from local and global commitment to social justice, diversity, environmental stewardship, and service in the public interest.” In keeping with these commitments, the College will only accept grants where the purpose and activities of the grant do not violate the following principles, which coincide with ethical principles governing research and academic freedom.

• Respect for persons — Human beings are treated as autonomous agents whose opinions and choices are valued. People with diminished autonomy (e.g., minors, prisoners, persons who are mentally disabled) are protected.
• Beneficence — Activities avoid harm to human beings and the environment. Potential harm resulting from grant activities should be mitigated, and activities maximize benefits to people, the environment, and society.
• Justice — Human beings are treated in a manner that is equitable and fair, upholds Evergreen’s Non-discrimination Policy and Procedure, and respects the College’s commitment to advancing social justice.
• Respect for law, including international law, and public interest — Activities operate within the laws under which the College must operate and do not promote actions that are against the law or serve to undermine public trust. To the degree possible, grant activities honor international humanitarian law and international human rights law as recognized by the United Nations, the International Committee of the Red Cross, and the Geneva Conventions and their additional protocols when such law is not expressly prohibited by local, state, and federal laws.
• Academic freedom and responsibility — Activities uphold academic freedom and responsibility. Preserving individual faculty members’ academic freedom is a key consideration in grant acceptance decisions. Members of the Evergreen faculty are entitled to full freedom in their teaching and research and in the dissemination of their ideas consistent with the First Amendment. Academic freedom provisions for faculty are outlined in various governance documents, including the College’s collective bargaining agreement with the United Faculty of Evergreen.
  
  Academic freedom also places responsibilities on individual scholars and researchers. These include demonstration of ethical practices, good faith endeavors to be accurate and truthful, operating only within one’s area of expertise, and commitment to non-discrimination. Academic freedom and responsibility are inseparable and must be considered simultaneously in grant acceptance decisions.
  
  Furthermore, grant funding to the College to support research and activities presents unique institutional responsibilities to ensure the ethics and integrity of the College’s operations and preserve public trust. These responsibilities can come into tension with concerns for individual academic freedom. This policy recognizes that grants are awards to the College and not to individual investigators. Participation in grant-funded activities is a privilege and not an entitlement of employment at Evergreen. As such, the College must take responsibility to ensure that grants avoid 1) grantor-driven agendas that seek unwelcome influence at the College over students, faculty, staff, curriculum, or College activities; 2) impingement on the free expression and academic freedom of other members of the College community; 3) misrepresentation of the College or College community members; 4) violation of the Social Contract; and 5) engagement in grant activities beyond the College’s capacity for plausible success. Academic freedom is not absolute and will not outweigh these additional responsibilities carried by the institution.

5.5. The mission, purpose, goals, and activities of funding organizations and partner organizations will be considered as part of determining the purpose of a grant. It is not possible to separate entirely a grant’s purpose from the work of a funding organization or partner organization(s); thus, the purpose of these organizations must also be considered in determining if the grant meets College requirements.

5.6. Grants must support the College’s mission and demonstrate likelihood for success. As an extension of the College’s work and public identity, grants must align with the College’s stated mission. The College also must ensure that a grant does not introduce unacceptable institutional risks and liabilities, including the misrepresentation of the College and its community members, that could result from its implementation or from public scrutiny. Finally, the College will only accept a grant that it determines can plausibly meet the conditions of award within the College’s available human, financial, and physical capacities.

5.7. If additional information, requirements, or circumstances arise concerning a grant that has already been accepted, the College may reevaluate its acceptance decision with the option of terminating the remaining award.

6. Grant Proposals Must be Evaluated Prior to Submission to Funding Organizations to Determine Approval

Before submitting a proposal for grant funding, the College will, based on the purposes and activities of the grant as described in this policy, evaluate every grant proposal, including grant renewals, for adherence to ethical principles, alignment with the College’s stated mission and values, and other requirements. Aspects to be reviewed and considered within each grant proposal include but may not be limited to:

• Goals and objectives of the proposed grant
• Activities and spending of the proposed grant
• Mission, purpose, goals, and activities of the funding organization
• Mission, purpose, goals, and activities of partner organizations in a grant project
• Support of and alignment with the College’s mission and stated values
• Risks to the College, including risks to reputation
• Potential impacts on College operations
• Plausibility for success of grant as proposed

Faculty or staff proposing a grant will provide all available information and documentation about the grant as part of the evaluation procedure. Failure to submit grant information for review in a timely manner or withholding of key information may result in non-acceptance.

7. The College Will Implement a Consistent Review Procedure to Ensure Adherence to this Policy

The procedure will be developed and implemented within ninety (90) days of enactment of this policy. The procedure developed will meet the following requirements.

7.1. The procedure will be administered by the grants office.

7.2. The procedure will be posted in a place easily accessible to faculty and staff and available to anyone on request.

7.3. The procedure will be designed to be as efficient and timely as possible in recognition that many grant proposals have deadlines.

7.4. All proposed grants will undergo a thorough review conducted by staff in the grants office, the chief financial officer or their designee, and the division leaders in the divisions impacted by the grant. The Foundation’s executive director will also review proposed grants for which the Foundation is the applicant.

7.5. As delegated by the president, each division leader is responsible for grant approval decisions for grants administered within or affecting their respective divisions and the chief financial officer is responsible for grant approval decisions for all divisions of the College. Acceptance requires approval from both the chief financial officer and the division leader(s). Grants to the Foundation must also be approved by its executive director. All decisions are subject to review by the president, who has ultimate authority for grant acceptance.

7.6. The College will require additional review of grant proposals (beyond grants office, division leader(s), chief financial officer reviews, and Foundation executive director) when necessary to reach an informed decision. A grant proposal requires additional review when a divergence from acceptance criteria in this policy is suggested or appears possible in the proposed grant. The division leader or the president determines whether such a review is necessary. In such cases, the division leader will convene an independent review relying on interested/affected parties, including faculty, staff, and/or students, to advise on the appropriateness of the grant.

Additional review of a grant proposal is required whenever more information is needed to determine if a proposed grant meets the acceptance criteria established by this policy. Additional review is especially encouraged if there is credible concern that a funding organization, partner organization, or proposed grant activities might do one or more of the following:

• Seek to exercise control over or introduce an unwelcome grantor-driven agenda to influence the College’s curriculum, educational materials, student projects, student organizations, campus events, faculty or staff hiring, campus climate, or grant outcomes.
• Seek to influence legislation or participate in political advocacy for foreign or domestic governments.
• Support or legitimize human rights violations, illegal occupation, limits to free speech, or the oppression of minorities.
• Participate in the manufacture or dealing in weapons prohibited by the rules of international humanitarian law as published by the International Committee of the Red Cross.
• Engage in fossil fuel extraction or act in conflict with the College’s commitment to sustainability and environmental justice.
• Politically advocate for foreign governments or entities that engage in anti-democratic, human rights abusing activity.
• Violate laws or policies governing the College.

7.7. Funding organizations and partner organizations previously reviewed and approved may not require repeat review for each new proposal. The procedure should allow for periodic review of repeating organization for continued alignment with this policy.

7.8. When possible, grantseekers will be given an opportunity to make necessary revisions for the proposal to meet requirements and mitigate risks.

7.9. The grants office has responsibility to gather all relevant information required for determining if a grant is eligible for acceptance. Faculty or staff proposing a grant will supply the grants office all information requested and available to them for evaluation.

7.10. The procedure will be reviewed and renewed as needed by the grants office to reflect changing administrative functions at the College.

8. Definitions

Academic freedom — Defined by the American Association of University Professors (AAUP) as “the freedom of a teacher or researcher in higher education to investigate and discuss the issues in his or her academic field, and to teach and publish findings without interference from administrators, boards of trustees, political figures, donors, or other entities. Academic freedom also protects the right of a faculty member to speak freely when participating in institutional governance, as well as to speak freely as a citizen” (www.aaup.org/programs/academic-freedom/faqs-academic-freedom). At Evergreen, academic freedom is grounded in the United Faculty of Evergreen collective bargaining agreement (CBA), which invokes the AAUP’s 1940 Statement on Academic Freedom and Tenure with 1970 Interpretive Comments. AAUP, with a mission “to advance academic freedom and shared governance,” continues through the present day to issue statements defending academic freedom and condemning administrative and legislative efforts to restrict academic freedom and discriminatory impacts of restrictive policies. Through the CBA, the faculty and the College agree that the College, like other institutions of higher education, is conducted for the common good, which depends upon the free search for truth and its free exposition. Fundamental to that purpose is academic freedom. Members of the faculty are entitled to full freedom in their teaching and research and in the dissemination of their ideas consistent with the First Amendment. Academic freedom also places responsibilities on individual scholars and researchers. These include demonstrating ethical practices, endeavoring in good faith to be accurate and truthful, operating only within one’s area of expertise, and upholding the College’s commitment to non-discrimination.

Chief financial officer — The vice president or other senior executive charged with overseeing the College’s financial functions.

Conditions of award — The requirements and stipulations from a funding organization that a recipient must fulfill to receive and use grant funds. Conditions of award can refer to funder-specific requirements as well as applicable laws, orders, and regulations.

Division leader — The vice president or other senior executive with responsibility for managing an administrative division of the College.

Funding organization — A private organization, nongovernmental organization, or government agency that provides funding for a grant.

Grant — An award of financial assistance, including a cooperative agreement, in the form of money, or property in lieu of money, to an eligible grantee. Unlike gifts, which usually are given without expectation of benefit or deliverables in return, a grant is typically awarded based on specific criteria and is typically intended to fund a project or initiative with defined goals and outcomes. The definition does not include technical assistance (i.e., services) instead of money; revenue sharing; loans; loan guarantees; interest subsidies; insurance; direct appropriations; or assistance such as fellowships or other lump sum awards for which the grantee is not required to account.

Grant accounting office — The office located in the College’s finance division that is responsible for post-award grant administration at the College. Grant accounting has responsibility to ensure and certify that grant funds are spent in compliance with all grant requirements.

Grant activities — Any good or service procured or any action undertaken to meet the requirements of a grant, including items that are a) paid for using grant funding; b) paid for by other sources in fulfillment of grant requirements; or c) provided by voluntary or in-kind sources. Examples of grant activities include but are not limited to purchases; research; employment; volunteer recruitment and coordination; community development; client services; student services; student activities; product development; facilities construction, maintenance, and refurbishment; marketing and communications; educational and extracurricular programming and development; health initiatives; conservation; compliance; arts projects; financial aid awards to students; and internships. Grant activities are often, though not always, delineated in grant award agreements.

Grant director or principal investigator (PI) — The person or persons charged with oversight of all aspects of administering a grant-funded project. Duties include but are not limited to hiring and supervision, contract management, design and conduct of research, financial management, project management, communications with funding organizations, and reporting. The director or PI collaborates closely with relevant College offices to ensure grant success.

Grant proposal — All materials (digital or physical) required by a funder to consider making a grant award. Materials may include but are not limited to initial inquiries (sometimes called letters of inquiry), forms, narratives, budgets, resumes, position descriptions, letters of support, assurances, publications, and other documents or media in support of a proposal.

Grantor-driven agenda — Outcomes, results, or conditions that a funding organization seeks to bring about through the awarding of grant funds. In some cases, a grantor-driven agenda may coincide with the mission and priorities of the College; in other cases, it may be an unwelcome intrusion that runs counter to the College’s mission and priorities. The institutional review process determines whether a grantor-driven agenda is welcome.

Grants office — The office responsible for all pre-award grant administration and proposal submission at the College.

Indirect costs — Expenses that support an organization's overall operations but are not directly tied to a specific project or grant. Such expenses are not easily identifiable with a particular activity and are typically allocated as a percentage of direct costs. Sometimes referred to as overhead or facilities and administrative (F&A) costs.

Interested or affected party — An individual, office, or organization at Evergreen that has an active role in or is likely to be significantly impacted by a particular project or initiative.

Eligible employment relationship — An employment status in which the employee receives a regular, competitive compensation package in a position that exists for the benefit of the College. This includes regular and adjunct faculty members and full-time, part-time, and project staff members. It excludes student employees and temporary employees. Compensation may include grant funding.

Partner organization — An organization external to the College that participates in grant activities as approved by the funding organization. Partner organizations may or may not receive funding from a grant.

Pass-through entity — An organization that receives grant funds and then distributes those funds (subawards) to other organizations or individuals, known as subrecipients, to conduct a specific project or program in fulfillment of the grant conditions of award.

Purpose of a grant — The reason or reasons, stated or inferred, that a funding organization would provide, and that Evergreen would accept, grant funding. It is encompassed by two components: a) the goals, objectives, and activities stated or implied in a grant proposal on behalf of Evergreen; and b) the mission, goals, objectives, and activities of the funding organization, stated by the organization or inferred by its activities.

Subaward — A legal agreement between an organization receiving a grant (the pass-through entity) and another organization (the subrecipient) to conduct a portion of the work required by that award. It does not include payments to a vendor to procure goods or services.