VIII.
Post-Award Activities: Ongoing Administration
Of Sponsored Projects
A. Overview
Post-award grant and contract administration
begins when the University receives notification
of the award. The process continues through
the life of the award and through financial
and technical closeout of the grant or contract.
To assist investigators in successfully
administering their sponsored projects,
the Office of the Vice President for Research
(OVPR) established the following
policies and procedures governing post-award
activities. Investigators should follow
these guidelines when making expenditures,
hiring employees, reporting progress, etc.
A chart of the forms and approvals required
in particular instances can be found in
Table VIII at the end of this section.
Post-award administration at the central
administration level is carried out jointly
by OVPR/Sponsored Projects Administration
(SPA), Controllers Office/Grants and Contracts
Accounting (G&CA). SPA is responsible
for most aspects of post-award administration
process at the Health Sciences Center (HSC)
Campus. G&CA is responsible for most
aspects of post award administration at
all other University campuses. In the following
guidelines, SPA/G&CA will specify responsibilities
by campuses. SPA or G&CA alone will
denote separate responsibilities for departments,
regardless of campus location. That is,
if the project is located at HSC, SPA is
responsible. If the project is located on
any other campus, G&CA is responsible.
B. University
Policy On Project Administration
Most grants and contracts are awarded to
the University and not to an individual
investigator. The University designated
SPA/G&CA as the departments responsible
for review and approval of all expenditures
of funds from sponsored agreements.
However, the daily administration of fiscal
and technical aspects of a grant or contract
remains the responsibility of the principal
investigator. Investigators continue to
be responsible to their Dean and ultimately
to the Provost for the project.
C. Processing
Of Awards
The two most common types of awards are
grants and contracts. Grant award notices
generally do not require a University endorsement
or acknowledgement. Those that do are signed
by the Vice Provost for Research or designee.
Contracts require special procedures and
University signatures prior to the acceptance
of funds. The President and the Vice President,
Chief Financial Officer and Treasurer are
the only two University officials who have
the authority to bind the University contractually.
OVPR notifies the Office of Development
of any awards from private sources.
D. Establishment
Of Center Number
Upon receipt of an award for a grant or
contract, SPA requests the G&CA to establish
a separate center number for the project.
Funds expended in the performance of the
project are charged to the center number.
When G&CA establishes the center number,
G&CA/SPA sends a copy of the award notice
and approved budget to the investigator,
appropriate chairs and Deans.
E. Responsibilities
Of The Principal Investigator (PI)
During the life of the project the PI is
responsible for:
-
meeting
the approved goals and objectives
of the award;
-
managing the
award effectively;
-
staying within
the approved budget;
-
conducting research
or other sponsored projects responsibly;
-
avoiding conflicts
of commitment or interest (real or
apparent);
-
completing and
filing all technical reports, including
final technical reports as required
by the funding agency;
-
cooperating in
any audits that may be required by
the University or funding agency;
-
adhering to University
policies and procedures related to
administration of the award;
-
complying with
University safety and health requirements
by maintaining a safe environment
for the conduct of the sponsored activity;
and
-
adhering to University procurement
and expenditure policies and procedures.
The PI has authority to sign for all expenditures
related to the award. In some cases, the
University requires additional authorization.
The PI may delegate signature authority
to another individual at the University,
such as a department financial officer or
business manager, however, he or she retains
final responsibility for financial integrity
of the program.
F. Signature Authorization
The PI or an employee to whom the PI has
designated signature authorization must
provide written approval of all expenditures
of sponsored project funds. Specific dollar
amounts determines the appropriate expenditure
authorization.
For Main Campus sponsored project centers
beginning with 2x, 3x, or 4x, G&CA will
send a green signature authorization card
to the PI at the time the award notification
is sent. The PI signs the card and returns
it to G&CA. This authorization allows
expenditures up to the full amount of the
award. Additional authorization needed on
certain items, such as personnel forms,
will be discussed below in the appropriate
sections.
Main Campus centers beginning with "55"
are subject to the Expenditure Authorization
Policy (See Appendix NN). The University
Signature Authorization card (white) will
be sent with the award notification. These
cards require the PI's signature as well
as that of his or her immediate supervisor.
G. Post_Award
Administrative Activities
The PI, or his or her designee, must submit
all requests for expenditures to SPA/G&CA
for approval. SPA/G&CA reviews all requests
to make sure they meet both the terms of
the award and University policies; consistent
application of current University policy
and procedures is required on external awards.
All University forms currently available
for such expenditures (e.g., salaries and
wages, travel, supplies and equipment, check
requests, and hiring of personnel) must
be properly completed before awarded funds
can be utilized. Forms and instructions
are available in the appropriate Deans'
Offices and/or departments. Commonly used
FMS Budget Categories are listed in Appendix
E.
Charges to grants and contracts for materials
received and services rendered can only
be made prior to the expiration date of
the award. Investigators should refer to
the appropriate section of the manual or
contact OVPR with any questions
regarding processing procedures.
PERSONNEL
– New Hires
To hire new employees on grants and contracts,
the PI must complete a HRS Employee Requisition
and HRS Position Questionnaire Form (Appendix
D) which the appropriate Dean must approve.
The Personnel Office should be consulted
during the pre-award process, as described
in "Hiring Staff" in Section VII,
to assure that salary levels are consistent
with the University's salary structure.
Once the Dean has approved it, send the
form to SPA/G&CA for approval, Compensation
for grading, and to the Office of Personnel
Services (OPS) for posting. At HSC, the
requisition must be approved by SPA/HSC,
which will then forward it to the Finance
Office. All positions will be posted in
accordance with University posting and bidding
procedures and Affirmative Action Guidelines.
A job offer can only be made by a representative
from OPS.
Before a new hire can be paid, the new
employee must complete an Employee Eligibility
Verification Form (INS Form I-9) and IRS
form (W-4) at the OPS, in compliance with
federal law. Graduate assistants, postdoctoral
fellows, students, and medical residents
working in their disciplines are excluded
from the above procedures. Postdoctoral
fellowship appointments, however, do require
the approval of the Dean.
Graduate assistants hired on sponsored
projects may purchase their health insurance
at a group rate. Post-doctoral employees
and post-doctoral trainees may receive health
care benefits, but cannot receive pension,
dental, or vision care benefits. Some part-time
staff may be eligible for pro-rated health
and welfare benefits.
Student workers to be paid on a weekly
basis must be hired using the Student Personnel/Payroll
Form. The PI must complete this form and
forward it to SPA/G&CA for approval
and delivery to OPS. The start and termination
dates on the form must coincide with the
approved dates of funding. The PI should
provide the names of graduate students to
be supported by the grant or contract to
the Department Chair, the Dean and the Graduate
School.
– Effort Reporting
The Personnel Activity Reporting System
(PARS) enables the University to certify
effort on sponsored projects (Appendix O).
The Controllers Office prepares this form
and sends it to the Department Chair or
designee for certification. The Effort Report
is created once each semester for faculty,
and on a quarterly basis for technical/professional
staff. The PI should review the certification
of the Effort Reports made by the departmental
designees to make sure these correspond
with the proposed effort listed in the project's
approved budget. It is the responsibility
of the departmental designee to verify these
effort reports with the PI.
– Payroll
All University employees are paid either
weekly or monthly. In general, hourly students
and clerical workers are paid weekly, while
other employees are paid monthly.
Weekly hourly workers are paid through
Weekly Hourly Time Reports submitted directly
to the Payroll Office. Although these forms
do not need SPA/G&CA approval on a weekly
basis, the investigator must obtain an initial
approval from SPA/G&CA by submitting
to SPA/G&CA the Student Personnel/Payroll
Form (Appendix P). The SPA/G&CA approved
form authorizes payroll through the end
of the funding period, and at the approved
rate. SPA/G&CA monitors the charges
through FMS. In the case of any questions,
investigators should maintain backup for
weekly hourly employee records.
For employees who are paid on a monthly
basis, the Employment HRS Requisition used
to begin the hiring process alerts Payroll
that a job offer has been accepted. Therefore,
once the original form has been completed
and sent to OPS, there is no additional
form required to initiate payroll other
than the forms required by OPS (e.g. Personnel
Action Authorization, W-4, I-9, and Personal
Data Form). Any changes in distribution
of salary, including a new account code
and center number, or a salary change, must
be reported to SPA/G&CA on an Expense
Distribution/Change Form (Appendix P). This
form must be completed and signed by the
PI or designee and forwarded to SPA/G&CA
for approval before such changes can go
into effect.
All personnel/payroll-related forms must
be submitted to SPA/G&CA on a timely
basis to meet payroll deadlines. For weekly
hourly and salary payroll changes, the normal
deadline for submittal to SPA/G&CA is
10:30 a.m. on Fridays (checks are issued
one week later). For monthly payrolls, the
deadline is the 15th day of the month (checks
are issued on the last business day of the
month).
– Employees as Paid Participants
or Research Subjects
Any employees, in any capacity, who are
affiliated with a project outside of their
normal work place must still be paid through
the Personnel/Payroll system. Employees
cannot be paid as independent contractors.
Any employee who participates in a research
program as a research subject and is entitled
to compensation must be paid through the
Personnel/Payroll system.
– Termination
At least one month in advance of the project
termination date, the PI should provide
written notification of pending termination
to employees supported by the grant or contract.
The staff should be referred to OPS for
possible relocation within the University.
For Main Campus employees, the Employee
Relations Manager in the OPS (204-3317),
or for HSC Employees, the Employee Relations
Manager (707-3147), also should be notified
at least four weeks prior to the date of
termination. Employees supported on sponsored
projects may be eligible for unemployment
compensation or disability. Vacation time
must be fully utilized during the time of
the project; no funding is provided for
unused vacation leave.
At the time the employee is notified of
the pending termination, the Termination/LOA/Return
From LOA form should also be completed and
forwarded to Payroll. This form is used
to terminate the employee from University
payroll (Appendix P).
CONSULTANTS
Consultants are individuals who assist in
the conduct of the project or are paid participants
or research subjects in the project. They
may be University employees or individuals
from outside the University.
– University Employees
If a consultant on a sponsored project is
an employee of the University, the PI and
other appropriate collegial administrators,
must complete and sign an Expense Distribution
Change Form and a Consultant Form then forward
it to SPA/G&CA for approval. SPA/G&CA
then sends the approved forms to OPS and
to Payroll. Additional payments to faculty
must be signed by their Dean or designee.
One-time only payments can also be processed
on the Monthly Salaried Payroll Adjustment
Form (PRVI 5/92) (Appendix P).
– Outside Consultants
A consultant who is not an employee of the
University is to be paid using Request for
Payment (Check Requests). Two forms, a University
Contractual Agreement/Consulting Service/Independent
Contractor Form and W-9 form, must be completed
and submitted to SPA/G&CA for approval.
The Contractual Agreement Form can be used
as a Request for Payment (Check Request)
(Appendix T). After approval, SPA/G&CA
submits these forms to Accounts Payable.
If a consultant is an "occasional employee,"
payroll forms as described above for University
employees must be submitted.
TRAVEL
University personnel, including staff hired
on grants or contracts, must use World Travel
for all business travel regardless of source
of external funding. Travel supported entirely
by grant or contract funds only requires
SPA/G&CA approval. World Travel requires
completion and approval of a Travel Authorization
Form (Appendix G) prior to purchase of tickets.
All travel authorizations on sponsored projects
must receive SPA/G&CA approval to certify
that the travel is allowable under the terms
of the award, and that there are sufficient
funds to pay for reimbursement. It is understood
that grant and contract activities were
approved by the department and college/school
when their respective representatives signed
the SPAF. However, department chairs and
deans may require notification and approval
for their own planning purposes.
Travel related expenses are reimbursed
utilizing the Travel and Expense Report
(Appendix G). The Report requires SPA/G&CA
approval as well as original receipts. Meal
allowances differ depending on the visited
city. Please refer to Appendix G for the
appropriate meal allowance and mileage rates.
See the Controllers Office web site for
rate updates (www.temple.edu/controller).
A Travel and Business Related and Expense
Exception Authorization Form (Appendix G)
is used for all travel where there are missing
receipts or when a meal is provided to a
non-University individual. The Dean and
SPA/G&CA must approve these expenses.
Travel and expense exception authorizations
for dinners and meetings where the expense
per person averages more than the allowable
per diem must contain a statement declaring
that alcoholic beverages are not part of
the expense.
Note: Foreign travel must comply with certain
regulations that are not applicable to domestic
travel. For more information, refer to the
Special Travel Advisory in Appendix G.
EQUIPMENT
Equipment should be ordered as early as
possible in the funding period. Equipment
may not be purchased in the last six months
of a project period. Equipment may be either
expendable (costing less than $2,500 or
having a useful life of less than one year)
or capital (costing $2,500 and having a
useful life of more than one year). For
all equipment costing $2,500 or more, the
investigator must submit to SPA/G&CA
an Equipment Screening Report Form (Appendix
Q), prior to ordering the equipment and
after an award is made. At least every two
years, the Controllers Office verifies the
existence of the equipment. All equipment
must be appropriately tagged.
Title to equipment purchased with grant
or contract funds is determined by the funding
agency's policies. In general, title to
the equipment either resides with the University
or with the funding agency. Title to equipment
never resides with the PI. Refer to funding
agency guidelines for details.
Equipment that is transferred from other
institutions to the University is subject
to the same policies as above.
SPECIAL PURCHASES OR CHARGES
– Purchase of Laboratory and
Research Animals
Requests for research animals are placed
with the Central Animal Facility. The Facility
can process such orders only if they are
accompanied by an approved Institutional
Care and Use Committee (IACUC) number. The
Facility for purchases and services rendered
bills investigators monthly.
– Purchase of Computers
To purchase up to $5,000 in computer hardware
with externally funded grants or contract,
the PI or designee must complete a purchase
requisition and forward it directly to SPA/G&CA
for approval. Computer Services must approve
requisitions to purchase computer equipment
in excess of $5,000 before submitting it
to SPA/G&CA. SPA/G&CA forwards the
requisition to the Purchasing Department.
Investigators are advised to discuss hardware
needs with Computer Services prior to completing
the purchase requisition. Refer to the University's
Direct and Indirect Cost Policy (Appendix
LL) for guidance on the appropriate use
of sponsored funds for the purchase of computers
and other general-purpose equipment.
– Purchase of Radioactive Materials
Investigators must obtain approval of all
purchases of radioactive materials from
the Radiation Safety Office of the Office
of Environmental Health and Safety.
– Purchase of Biological or Chemical Hazardous
Materials
Investigators must obtain approval of all
purchases of biological or chemical hazardous
materials from the Office of Environmental
Health and Safety.
– Tuition
Costs of scholarships are allowable only
when the purpose of the sponsored agreement
is to provide training to selected participants
and the charge is approved by the sponsoring
agency. A tuition remission form may be
used to pay for such trainee tuition. However,
tuition paid as, or in lieu of, wages to
students performing necessary work is allowable
provided that (1) there is a bona fide employer-employee
relationship between the student and the
institution for the work performed, and
(2) the tuition or other payments are reasonable
compensation for the work performed and
are conditioned explicitly upon the performance
of necessary work. Because such compensation
is taxable, a tuition remission form may
not be used. Rather, the student must be
paid through Payroll. See Appendix R for
a decision tree for tuition allowability
on sponsored agreements.
To charge tuition, if allowed in a sponsored
project, the PI must complete and sign a
Tuition Remission form (Appendix R). Other
signatures may be required by the college
or school. The form, together with the tuition
bill and tuition letter, must be submitted
to SPA/G&CA for approval. SPA/G&CA
returns these documents to the student or
the PI, either of whom must submit them
to Cash Operations for tuition reimbursement.
For tuition remission supported by a department,
college/school or the Graduate School, a
Tuition Remission Form must be completed
and signed by the PI and other required
individuals. This form, together with the
tuition bill and tuition letter, should
be submitted directly to Cash Operations
for reimbursement. Students having tuition
paid through the Graduate School must complete
the Research Assistant Tuition Remission
Request for External Grants Form, available
through the Dean of the Graduate School.
SPA/G&CA approval is not required if
award funds are not used.
H. Methods For
Purchasing Supplies & Equipment
Purchases for sponsored projects can be
made by regular purchase orders, master
purchase orders, short orders, or University
purchasing card orders. Details can be found
in the Purchasing Department User's Guide,
PI's Fact Sheet, and Supplier's Guide (Appendix
S). Basic procedures for purchasing and
payment are as follows:
– Purchase Orders
The purchase process begins with the completion
of a Purchase Requisition form (Appendix
S), SPA/G&CA and Purchasing Department
approval. The Purchasing Department then
completes a Purchase Order based on the
information contained in the Purchase Requisition,
and sends it to the vendor. When the item
is sent to the investigator, an invoice
from the vendor is sent directly to Accounts
Payable.
When the Purchase Order amount is over
$5,000, the PI must sign and submit the
receiving documentation to Accounts Payable.
After the invoice, purchase order, and receiving
document are received, and all documentation
is shown to match, Accounts Payable prepares
a check and sends it to the vendor.
When the Purchase Order amount is under
$5,000, no receiving documentation is required.
Each month a cost center report is generated
which shows all payments made where no receiving
documents were required. PIs should review
this report to assure that all payments
are appropriate. Any discrepancies should
be brought to the attention of Accounts
Payable.
– Master Purchase Orders
When a single vendor frequently provides
a product or product(s), a Master Purchase
Order (MPO) stream-lines the purchasing
process. A purchase requisition that requires
the approvals cited above generates an MPO.
The Purchasing Department completes and
sends it to the vendor. Invoices are then
sent from the vendor directly to the sending
PI who signs the invoice indicating receipt
of acceptable goods or services, and lists
the account code and cost center to be charged.
The PI sends the invoice to SPA/G&CA
for approval, and SPA/G&CA forwards
the invoice to Accounts Payable. Accounts
Payable verifies the approving signatures,
records the invoice against the master purchase
order, and sends payment directly to the
vendor.
– Short Orders
Short Orders (Appendix S) are an expedited
method of purchasing items that cost less
than $1,000. The investigator or designee
may place verbal orders with vendors for
items not to exceed $1,000 in total order
value and in accordance with the established
signature authorization policy. Vendors
must be advised to forward the original
invoice to the PI, who then signs the invoice,
indicates the account and cost center to
be charged, and forwards the invoice to
Accounts Payable. The signature on the invoice
indicates receipt of acceptable goods or
services and authorizes payment. If written
purchase orders are required by the vendor,
short order books are available in the Purchasing
Department.
– Temple University Purchasing Cards
The University Purchasing Card is a VISA
Purchasing Card. It may be used to purchase
goods and services valued at $1,000 or less.
PIs may apply for the business VISA through
the Purchasing Department. SPA/G&CA
must approve the application for the card
for a sponsored project. Although no single
line item is to exceed $1,000, purchases
can be accumulated each month up to the
monthly approved credit limit. Billing verification
and authorization takes place monthly. The
cardholder should approve his or her individual
statement for verification of receipt, correct
pricing, and authorization for payment.
Note: The card cannot be used for items
relating to contract maintenance, laboratory
research animals, entertainment, furniture,
hazardous or radioactive materials, items
currently under MPOs or contracts, office
fixtures, rental or lease of equipment,
services usually provided through Physical
Plant work orders, temporary help, travel,
entertainment and items valued over $1,000.
As purchasing card statements do not need
approval by SPA/G&CA prior to submission
to Accounts Payable, the PI has total responsibility
for ensuring that purchases are in compliance
with the approved budget. The PI also has
the responsibility for maintaining documentation
of purchases made on Purchasing Cards. Outstanding
charges that are not disclosed to SPA/G&CA
in the final financial reporting are to
be charged to the PI's incentive award account
or to the School/College. For more information
on the program, see (Appendix S).
– Personal Funds
Investigators may purchase items under $100
with their personal funds. They should be
reimbursed through Petty Cash or the Travel
and Expense Report.
– Stationery Supply Requisition
Most general office supplies and all University
forms can be ordered on the Stationery Supply
Requisition form. Investigators can obtain
the Stationery Supply Catalog through the
stationery supply system.
– Emergency Purchase Orders
Emergency purchases may be authorized where
there exists a threat to public health,
welfare, or safety at the University. If
such a need occurs, the investigator should
contact SPA/G&CA which will contact
the Purchasing Department to obtain an Emergency
Purchase Order.
I. Cost Transfers
From University Departments
The University provides services that are
directly related to specific sponsored activities.
These services are direct charges to the
sponsored activity and are not part of its
indirect costs. The following summarizes
the most common University services that
do or do not require SPA/G&CA prior
approval.
INTERNAL CHARGES THAT NEED SPA APPROVAL
University service departments provide services
that may be charged directly to grants and
contracts. The following charges do require
SPA/G&CA approval before they can be
processed. They include:
– Facilities Management Work Orders
To utilize the services of Facilities Management
for such jobs as set-up for events, renovations,
repairs, and maintenance, a Work Request
Form must be completed. SPA/G&CA must
first approve the requisition and forward
it to Facilities Management for execution.
– Diamond Club
Requisitions to use the Diamond Club for
meals and for room rentals need prior approval
from SPA/G&CA. The Diamond Club Catering
Requisition must be completed and sent to
SPA/G&CA which will approve and forward
it to the Diamond Club.
– Barnes & Noble
Purchases made at any Barnes & Noble
bookstore can be directly charged to grants
and contracts. A completed purchase requisition
is sent to SPA/G&CA for approval. It
is then responsible for making the actual
purchase. The yellow copy of the requisition
must remain attached until bookstore personnel
complete the pricing of the items. The bookstore
will return the yellow copy to the purchaser
for their records. The department returns
a completed copy of the requisition (with
actual dollar amounts) to SPA/G&CA.
– Faculty Student Center/HSC Student Activities
Usage of any Student Faculty Center (SFC)
facility at HSC (including rental fees and
services fees), requires the prior approval
of SPA/G&CA. SFC completes the form,
the PI signs it, and SPA/G&CA approves
and forwards it to the Office of Student
Activities.
INTERNAL CHARGES THAT DO NOT REQUIRE SPA
APPROVAL
The following department charges can be
processed without prior approval of SPA.
- Telephone Services
- Biomedical Engineering
- Publications
- Central Animal Laboratories
- R & D Machine Shop
- Medical Communications
- Audio Visual
- Word Processing
- Shared Resources
- Parking Services
- Television Services
- Metered Mail
- Copying/Duplicating
These transactions are reviewed by SPA/G&CA
on a monthly basis. It is the responsibility
of the PI/project director to maintain records
and supporting documentation for all transactions.
J. Processing
Of Expenditures
The procedures and approvals required for
most post-award expenditures and actions
on grants and contracts are as follows:
METHODS OF PAYMENT
There are several different methods by which
expenses charged to a sponsored activity
can be paid. Normally, Accounts Payable
issues a check after being presented with
an invoice. Other possible methods of payment
are Request for Payments (Check Requests)
and Petty Cash Vouchers. To pay for services
provided by different units in the University,
or for correcting any items inadvertently
charged to an incorrect account or center,
use a Journal Entry Transfers (JET).
– Request of Payment (Check Requests)
Request of Payment (Check Requests) (Appendix
T) can be used to pay for a variety of expenses,
such as conference registration fees, journal
subscriptions, book allowances, honoraria
or stipends. The PI completes the Request
of Payment (Check Request Form) then sends
it with the appropriate signatures to SPA/G&CA
for final approval. Documentation, such
as an invoice, must accompany the request.
SPA/G&CA will forward the request to
Accounts Payable which issues the check.
– Petty Cash
When necessary, a PI may receive advances
of up to $200. A Petty Cash Advance Form
(Appendix U) must be completed and signed
by the PI as well as any other required
parties, before submission to SPA/G&CA
for approval. If the advance is approved,
the investigator presents the approved form
to Cash Operations for cash disbursement.
For reimbursement of petty cash, and to
"clear an advance," a Petty Cash
Voucher (Appendix U) must be completed and
signed by the PI, as well as any other required
parties, and forwarded to SPA/G&CA for
approval. Signatures from department financial
officers, business managers, or other individuals
with signature authority for a cost center
will not be accepted. The investigator presents
the approved Voucher to Cash Operations
for payment in cash with all original receipts
attached. The PI is responsible for maintaining
all records of petty cash disbursements.
– Journal Entry Transfer (JET)
To transfer charges from one account/center
to another, a Request for JET form (Appendix
V) must be completed and signed by the PI
and any other required parties. Submit the
form to SPA for approval, and depending
on the center assignment, forward it to
G&CA. Requests for JET forms may not
be used to correct salaries, except in the
case of weekly/hourly students.
The investigator must attach any copies
of cost centers reports showing the original
charge to the JET. The transfer of any charge
that is older than 90 days must include
a letter of explanation.
K. Monthly Cost
Center Statements
The Controllers Office produces monthly
accounting reports of the budget status
of cost centers using Financial Management
System (FMS). These reports are sent to
the Deans and department financial officers.
PIs and/or department financial officers
should review the monthly reports for accuracy.
PIs may chose to monitor the financial status
of their grants through FMS.
Copies of all monthly cost center statements
are sent to each Dean from General Accounting
for distribution. The cost center statements
should be made available to Department Chairs,
who in turn should make them available to
PIs. The reports are usually distributed
from General Accounting between the 9th
and 11th of each month.
L. Special Considerations
In the normal course of a sponsored project,
changes in the budget or other aspects of
the project may become necessary. The most
common special considerations are described
below. Questions about these or any other
changes should be addressed to SPA/G&CA.
RE-BUDGETING
When an investigator requests a budget revision,
prior to the expenditure of funds, SPA must
approve the request and justification. The
request may be approved if sufficient funds
remain in the award and if the funding agency
grants SPA approval authority. If approval
from the funding agency is necessary, the
PI must justify in writing the request to
the funding agency; SPA must countersign
this written request. In such cases, re-budgeting
is not permitted unless the request has
been approved in writing.
PRIOR APPROVALS
Changes in other aspects of sponsored programs
may require prior approval from either SPA
or the funding agency. In all cases, the
PI should contact SPA first. The following
lists some of the most common changes to
federally funded projects that will require
prior approval:
-
change
in the scope of the research objectives;
-
change of principal
investigator;
-
change in the
grantee organization;
-
need for additional
funds;
-
deviations from
special conditions of the grant;
-
incurring or
committing pre-award costs prior to
the official start of the grant or
contract, and
-
incurring expenditures
after the official termination of
the project period.
The University generally seeks approval
from federal funding agencies for any changes
in the scope of work, changes in key personnel,
and requests for additional funds.
On most federal grants, SPA has the authority
to approve transfer of funds between budget
categories (including pre-award costs up
to 90 days in advance of the start date),
no-cost extensions of up to one year, and
the carrying forward of unobligated balances
from one funding period to the next.
CARRY-OVER OF FUNDS
Some agencies allow carry-over of funds
from one budget period to the next. However,
the PI must justify and document carry-overs
in excess of 25% of the total direct cost.
The justification must be on file in the
SPA. Because federal agencies are currently
scrutinizing carry-over of funds very closely,
they may not allow carry-overs in excess
of 25%, or they might deduct the carry-over
from future funds.
CHANGE IN PROJECT DIRECTOR
Notify SPA whenever there is to be a significant
change in the level of participation by
the project director or PI for a continuing
period of three months or when an individual
withdraws from the project entirely. The
PI is to notify SPA no later than thirty
days before the expected date of departure
or change in participation level. If the
PI withdraws, SPA will work with the Department
Chair or Dean to attempt to identify an
individual acceptable to the funding agency
to continue the project. SPA will also notify
the awarding agency of proposed alternative
plans. If such arrangements are not acceptable
to either SPA or the funding agency, the
project may be terminated.
TRANSFER OF A PROJECT
If a project is to be transferred to another
institution before the expiration of the
project period, SPA is to be notified so
that it can make appropriate plans. If SPA
agrees that the transfer is in the best
interest of all parties, it will contact
the appropriate officials at the funding
agency and at the recipient institution
to ensure that there will be no diminution
of services and that the change is conducted
in a timely, efficient, and orderly manner.
After all University obligations have been
met, remaining funds may be transferred
to the new institution. In addition to financial
obligations, obligations may include, where
appropriate: the PHS Grants Policy Statement;
DHHS Publication No. 90-50,000 (Rev.) October,
1990; transfer of equipment; completion
of any necessary Material Transfer Agreements
or disclosure statements to intellectual
property; decommissioning of a laboratory
for radioactive materials; and disposal
of hazardous materials.
PROGRAM INCOME
One further requirement of recipients of
awards is the treatment and reporting of
Program Income. Program Income may be defined
as gross income earned by a recipient of
an award from activities part or all of
which are borne as a direct cost by the
award or counted as a direct cost toward
meeting a cost sharing or matching requirement.
Program Income may include: fees from services
performed during the award period; proceeds
from sale of real property, equipment, or
supplies; usage or rental fees; patent or
copyright royalties; and third-party reimbursement
for hospital or medical services. Agencies
providing awards require that information
on Program Income be included in applications
submitted for awards; they also require
reporting of Program Income during the award
period. Certain agencies, such as the National
Science Foundation (NSF), the Public Health
Service (PHS) and the Department of Education,
have printed regulations dealing with the
treatment of Program Income. In most instances,
the award document indicates what the recipients'
responsibilities are regarding the reporting
of Program Income. Any questions on treatment
and reporting of Program Income should be
directed to SPA/G&CA.
CONSIDERATIONS NOT INVOLVING PROJECT SUPPORT
A PI who requests special arrangements,
such as the establishment of course credit,
tuition remission, a new academic program,
or assignment of space, should forward the
request to the Dean and/or other appropriate
University officials for approval.
M. Reporting
TECHNICAL REPORTS
Technical reports normally required by funding
agencies include progress reports and all
other technical reports. When the award
is processed, SPA will identify such reports
and remind the PI of their reporting requirements.
SPA also regularly generates and submits
to all PIs a document that identifies grants
and contracts requiring technical report
submissions.
– Progress Reports
The PI is responsible for preparing and
submitting technical progress reports to
the sponsoring agency by their due date.
The funding agency normally provides the
investigator with reporting requirements
in the award document; in some cases the
agency may also notify the investigator
in writing 60 to 90 days prior to the deadline
of the progress report. Reports are to be
submitted to SPA for transmittal no later
than ten working days before the due date
at the funding source. A copy of each report
must be maintained by the PI because they
are necessary for agency audits. Failure
to submit technical progress reports to
the funding agency may result in termination
of, or reduction in, support for the continuation
period, and SPA may withhold from the investigator
any applicable discretionary funds.
– Final Technical Reports
The PI has primary responsibility for preparation
of all final technical report(s). The funding
agency notifies the investigator within
a similar time frame as Progress Reports.
Submit reports to SPA/G&CA no later
than ten working days before the due date
at the funding source. SPA/G&CA submits
the final technical report to the funding
agency. In the event that final technical
reports are not provided in a timely manner,
SPA may withhold from the investigator any
applicable discretionary funds.
FINANCIAL REPORTS
The Controllers Office, through the G&CA
Office, is responsible for the submission
of all financial reports required under
the terms of the grant/contract. Prior to
submission, G&CA will contact the PI
or appropriate administrators for verification
of expenditures and outstanding transactions.
When agency mandated cost sharing is required
on an award, the PI must document all related
expenditures on a Cost Sharing Form (Appendix
W) available from the G&CA Office. The
completed form should be returned to that
office at the end of the project period.