Processing an Award - Ongoing Administration of Sponsored Projects
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 Sponsored Programs & Projects Office 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 Sponsored Programs & Projects, Controllers Office/Research Accounting Services(RAS). Sponsored Programs & Projects is responsible for most aspects of post-award administration process at the Health Sciences Center (HSC) Campus. RAS is responsible for most aspects of post award administration at all other University campuses. In the following guidelines, Sponsored Programs & Projects/RAS will specify responsibilities by campuses. Sponsored Programs & Projects or RAS alone will denote separate responsibilities for departments, regardless of campus location. That is, if the project is located at HSC, Sponsored Programs & Projects is responsible. If the project is located on any other campus, RAS 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 Sponsored Programs & Projects/RAS 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. Sponsored Programs & Projects notifies the Office of Development of any awards from private sources.
D. Establishment Of FOAP Number
Upon receipt of an award for a grant or contract, Sponsored Programs & Projects requests the RAS to establish a separate FOAP number for the project. Funds expended in the performance of the project are charged to the FOAP number. When RAS establishes the FOAP number, RAS/Sponsored Programs & Projects 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, RAS 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 RAS. 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. 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 Sponsored Programs & Projects/RAS for approval. Sponsored Programs & Projects/RAS 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.
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 Sponsored Programs & Projects with any questions regarding processing procedures.
- New Hires
To hire new employees on grants and contracts, the PI must complete a HRS Employee Requisition and HRS Position Questionnaire Form 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 Sponsored Programs & Projects/RAS for approval, Compensation for grading, and to the Office of Personnel Services (OPS) for posting. At HSC, the requisition must be approved by Sponsored Programs & Projects/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 Sponsored Programs & Projects/RAS 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. 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.
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 Sponsored Programs & Projects/RAS approval on a weekly basis, the investigator must obtain an initial approval from Sponsored Programs & Projects/RAS by submitting to Sponsored Programs & Projects/RAS the Student Personnel/Payroll Form. Sponsored Programs & Projects/RAS approved form authorizes payroll through the end of the funding period, and at the approved rate. Sponsored Programs & Projects/RAS monitors the charges through Banner. 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 FOAP number, or a salary change, must be reported to Sponsored Programs & Projects/RAS on an Expense Distribution/Change Form. This form must be completed and signed by the PI or designee and forwarded to Sponsored Programs & Projects/RAS for approval before such changes can go into effect.
All personnel/payroll-related forms must be submitted to Sponsored Programs & Projects/RAS on a timely basis to meet payroll deadlines. For weekly hourly and salary payroll changes, the normal deadline for submittal to Sponsored Programs & Projects/RAS 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.
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.
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 Sponsored Programs & Projects/RAS for approval. Sponsored Programs & Projects/RAS 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).
- 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 Sponsored Programs & Projects/RAS for approval. The Contractual Agreement Form can be used as a Request for Payment (Check Request). After approval, Sponsored Programs & Projects/RAS submits these forms to Accounts Payable. If a consultant is an "occasional employee," payroll forms as described above for University employees must be submitted.
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 Sponsored Programs & Projects/RAS approval. World Travel requires completion and approval of a Travel Authorization Form prior to purchase of tickets. All travel authorizations on sponsored projects must receive Sponsored Programs & Projects/RAS 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. The Report requires Sponsored Programs & Projects/RAS approval as well as original receipts. Meal allowances differ depending on the visited city. See the Controllers Office web site for rate updates (http://www.temple.edu/controller).
A Travel and Business Related and Expense Exception Authorization Form is used for all travel where there are missing receipts or when a meal is provided to a non-University individual. The Dean and Sponsored Programs & Projects/RAS 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.
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 Sponsored Programs & Projects/RAS an Equipment Screening Report Form, 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 Sponsored Programs & Projects/RAS for approval. Computer Services must approve requisitions to purchase computer equipment in excess of $5,000 before submitting it to Sponsored Programs & Projects/RAS. Sponsored Programs & Projects/RAS 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 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.
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.
To charge tuition, if allowed in a sponsored project, the PI must complete and sign a Tuition Remission form. Other signatures may be required by the college or school. The form, together with the tuition bill and tuition letter, must be submitted to Sponsored Programs & Projects/RAS for approval. Sponsored Programs & Projects/RAS 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. Sponsored Programs & Projects/RAS 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. Basic procedures for purchasing and payment are as follows:
- Purchase Orders
The purchase process begins with the completion of a Purchase Requisition form, Sponsored Programs & Projects/RAS 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 FOAP 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 FOAP to be charged. The PI sends the invoice to Sponsored Programs & Projects/RAS for approval, and Sponsored Programs & Projects/RAS 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 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 FOAP 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. Sponsored Programs & Projects/RAS 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 Sponsored Programs & Projects/RAS 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 Sponsored Programs & Projects/RAS in the final financial reporting are to be charged to the PI's incentive award account or to the School/College.
- 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 Sponsored Programs & Projects/RAS 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 Sponsored Programs & Projects/RAS prior approval.
INTERNAL CHARGES THAT NEED SPOSORED PROGRAMS APPROVAL
University service departments provide services that may be charged directly to grants and contracts. The following charges do require Sponsored Programs & Projects/RAS 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. Sponsored Programs & Projects/RAS 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 Sponsored Programs & Projects/RAS. The Diamond Club Catering Requisition must be completed and sent to Sponsored Programs & Projects/RAS 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 Sponsored Programs & Projects/RAS 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 Sponsored Programs & Projects/RAS.
- 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 Sponsored Programs & Projects/RAS. SFC completes the form, the PI signs it, and Sponsored Programs & Projects/RAS approves and forwards it to the Office of Student Activities.
INTERNAL CHARGES THAT DO NOT REQUIRE SPONSORED PROGRAMS APPROVALThe following department charges can be processed without prior approval of Sponsored Programs & Projects.
- Telephone Services
- Biomedical Engineering
- Central Animal Laboratories
- R & D Machine Shop
- Medical Communications
- Audio Visual
- Word Processing
- Shared Resources
- Parking Services
- Television Services
- Metered Mail
These transactions are reviewed by Sponsored Programs & Projects/RAS 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 FOAP, use a Journal Entry Transfers (JET).
- Request of Payment (Check Requests)
Request of Payment (Check Requests) 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 Sponsored Programs & Projects/RAS for final approval. Documentation, such as an invoice, must accompany the request. Sponsored Programs & Projects/RAS 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 must be completed and signed by the PI as well as any other required parties, before submission to Sponsored Programs & Projects/RAS 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 must be completed and signed by the PI, as well as any other required parties, and forwarded to Sponsored Programs & Projects/RAS for approval. Signatures from department financial officers, business managers, or other individuals with signature authority for a FOAP 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/FOAP to another, a Request for JET form must be completed and signed by the PI and any other required parties. Submit the form to Sponsored Programs & Projects for approval, and depending on the FOAP assignment, forward it to RAS. 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 FOAP 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 FOAP Statements
The Controllers Office produces monthly accounting reports of the budget status of FOAPs using Banner. 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 Banner.
Copies of all monthly FOAP statements are sent to each Dean from General Accounting for distribution. The FOAP 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 Sponsored Programs & Projects/RAS.
When an investigator requests a budget revision, prior to the expenditure of funds, Sponsored Programs & Projects must approve the request and justification. The request may be approved if sufficient funds remain in the award and if the funding agency grants Sponsored Programs & Projects approval authority. If approval from the funding agency is necessary, the PI must justify in writing the request to the funding agency; Sponsored Programs & Projects must countersign this written request. In such cases, re-budgeting is not permitted unless the request has been approved in writing.
Changes in other aspects of sponsored programs may require prior approval from either Sponsored Programs & Projects or the funding agency. In all cases, the PI should contact Sponsored Programs & Projects 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, Sponsored Programs & Projects 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 Sponsored Programs & Projects. 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 Sponsored Programs & Projects 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 Sponsored Programs & Projects no later than thirty days before the expected date of departure or change in participation level. If the PI withdraws, Sponsored Programs & Projects will work with the Department Chair or Dean to attempt to identify an individual acceptable to the funding agency to continue the project. Sponsored Programs & Projects will also notify the awarding agency of proposed alternative plans. If such arrangements are not acceptable to either Sponsored Programs & Projects 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, Sponsored Programs & Projects is to be notified so that it can make appropriate plans. If Sponsored Programs & Projects 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.
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 Sponsored Programs & Projects/RAS.
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.
Technical reports normally required by funding agencies include progress reports and all other technical reports. When the award is processed, Sponsored Programs & Projects will identify such reports and remind the PI of their reporting requirements. Sponsored Programs & Projects 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 Sponsored Programs & Projects 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 Sponsored Programs & Projects 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 Sponsored Programs & Projects/RAS no later than ten working days before the due date at the funding source. Sponsored Programs & Projects/RAS submits the final technical report to the funding agency. In the event that final technical reports are not provided in a timely manner, Sponsored Programs & Projects may withhold from the investigator any applicable discretionary funds.
The Controllers Office, through the RAS Office, is responsible for the submission of all financial reports required under the terms of the grant/contract. Prior to submission, RAS 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 available from the RAS Office. The completed form should be returned to that office at the end of the project period.