Manage Award
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During the lifecycle of an award, proactive action and maintenance may be required to ensure that you are adequately meeting both the needs of your project as well as the requirements of the sponsoring agency. Commonly, sponsor prior approval is required before certain actions can be taken which is why it is very important that any changes be addressed in advance of their occurrence.
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Grants and contracts specify the frequency and type of reports, including financial reports, progress reports, case report forms (for clinical trials), and invention disclosures required. The PI/PD is solely responsible for meeting all technical and programmatic reporting requirements. The Office of Sponsored Programs Financial Administration is generally responsible for submitting financial reports and invoices to sponsors. When unique financial reporting requirements are specified, the department must assist the Office of Sponsored Programs Administration in meeting financial report requirements.
The University considers timely reporting essential to the proper stewardship of sponsored funds. Payment for final project expenses may be delayed if reports are not submitted in a timely manner. In addition, pending proposals may not receive favorable consideration. Some sponsors will withhold future awards to individual faculty delinquent in reporting requirements. Others may withhold awards to all University employees anticipating funding from that same sponsor. Therefore, the Office of Sponsored Programs Administration will inform chairs and deans of delinquent reporting and if the problem is not corrected, may withhold approval of any new proposals for faculty who are seriously delinquent in their technical reporting responsibilities.
As an award progresses, there may need to be a budget reallocation request. You may find that you will need to adjust your budget pools in order to complete a specific experiment, to address an unanticipated need, or to bring in additional personnel. Follow instructions outlined in the Cayuse SP OSPA Procedure Manual [PDF].
There are varying reasons why an investigator may need to alter the proposed scope of work (e.g., a change in the proposed animal model, reduction in funding leading to a reduction in aims that can be accomplished, etc.). Changes in the scope of work need to be negotiated and approved by the sponsor.
When you are aware that a change in scope will be required, please contact your assigned OSPA Grant Specialist as soon as possible. In many cases, a formal written letter countersigned by an institutional official may be required. Your Grant Specialist will assist you in navigating this process with your sponsoring agency.
It is important to know when progress reports are due, in what format they need to be prepared, and how they need to be submitted. You may not receive a reminder from your sponsor that a progress report is due until it is delinquent. Technical progress reports, requiring institutional signature or submission, must be routed to your assigned Grant Specialist for review prior to signature and submission. At times, progress reports may also require financial reporting details such as expenditure by category to date. This information must be prepared and approved by your assigned accountant in Sponsored Programs Financial Administration and may require their sign off as well.
It is the PI’s responsibility to ensure that subaward sites are completing the assigned scope of work in a timely manner. PIs should review and approve all invoices from subaward sites prior to requesting issuance of payment. Additionally, subaward sites must provide the PI with any necessary technical progress reports as evidence of work performed. Subsequent year subaward agreements will only be issued upon verification from the PI that the subaward site has completed the work satisfactorily and has invoiced UofL appropriately.
There are several contributing factors that may lead to a project having a new Principal Investigator or Project Director identified. These may include:
- The PI is relocating to another institution, but not transferring the grant/project to the new institution
- Health issues that would prevent the PI from completing the project
- Changes in the current PI’s responsibilities within the University
- Absence of the PI for an extended period
If you find it necessary to change the identified Principal Investigator/Project Director, you will want to contact your assigned OSPA Grant Specialist [Excel] as early as possible in the process. Such requests will require prior approval from the sponsor, and your OSPA Grant Specialist will assist in navigating this process
Many sponsors allow a Principal Investigator to request an extension of time (without the provision of additional funds) if the completion of the scope of work was delayed and unable to be completed by the originally planned end date. Some no-cost extension requests and approvals can be processed by the Office of Sponsored Programs Administration through expanded authorities provided by the sponsor. Some, however, require sponsor prior approval. In either situation, the information collected is the same:
- Length of extension requested, including the anticipated new end date
- Justification for the extension, including brief yet sufficient detail regarding what work remains to be completed, based upon the project’s current scope of work
- If there is no change in scope of work, you will need to provide a statement of such in the justification. If there will be a change in the scope of work, you will need to indicate this as well and provide a detailed justification for the change at this stage of the project
- Estimated obligated balance and how you intend to use these funds during the extension period. Please note that some sponsors may require a detailed budget be submitted as part of the request
- Updated certification letters (IRB, IACUC, etc., as applicable)
Should your request require prior approval, your assigned Grant Specialist will inform you of this requirement and facilitate the process once institutional approval is provided. In all cases, you must first obtain institutional approval prior to seeking sponsor approval for extensions. You will begin the process in Cayuse SP, following the instructions outlined in the Cayuse SP End User Manual [PDF].
Unless the sponsor's terms and conditions are more restrictive, the University follows the NIH Grants Policy Statement that requires prior approval when there is a significant change in status, including absence, of the Principal Investigator and other Key Personnel.
The PI takes on the primary leadership role for a sponsored research project. Administration of sponsored research projects is a joint effort between the PI and the university. The PI is accountable for the appropriate fiscal management and conduct of the research project. Sponsors hold the university legally and financially responsible for the performance of the scope of work funded and accountable for the proper use of funds.
Reconciling accounts on a regular basis will help you manage your sponsored funds to ensure that expenditures and revenues are within appropriate limits and guidelines. In addition, regular monitoring of your sponsored accounts helps to:
- Confirm revenues have been received.
- Confirm the availability of project funds as needed.
- Ensure that costs are consistent with the project schedule and incurred between the start and end dates of the project.
- Discover any errors in your budget, encumbrances, or expenditures whether these are caused by an end user, a service department, or any other system-generated problem.
- Avoid overspending, which may cause a deficit and limit further spending.
- Verify cost transfers and corrections are made in a timely manner.
- Maintain a clear audit trail for the project.
Do not wait until an issue arises or until a project has terminated before reconciling an account. The longer an error remains uncorrected, the harder it is to show allowability and allocability within the university.
The University must have certification that the effort put forth on a sponsored project is reasonable in relation to the amount of salary being charged to the sponsored project. This is necessary to comply with federal regulations and to provide assurance to sponsors that the salary charged to a sponsored program is reasonable with respect to the effort. The home department of an employee must ensure that the Payroll Action Form for that employee properly reflects a true allocation of his/her salary in proportion to the effort performed on sponsored projects. The mechanism used to document that pay charged to the project is reasonable relative to actual effort is the Effort Certification Report.
Federal guidelines dictate that effort reports must be completed at least on an annual basis. The University has chosen to certify effort on a semi-annual basis for salaried employees and biweekly certification for hourly workers, to comply with federal guidelines. While completing the review of the employee’s effort for certification on the effort report, the department should ensure that the Personnel Action Notice (PAN) provides an accurate reflection of the employee’s effort.
For information regarding procedures, roles and responsibilities for certifying effort on federally sponsored programs, see the Guidance on Effort Report Certification [PDF].
When charging expenses to sponsored agreements, University faculty and staff must be cognizant of the allowability of the charges found in 2 CFR 200, “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards,”. The basic principle is that costs charged to a sponsored project must be allocable, reasonable, and necessary, treated consistently and adequately documented to be allowable on Federal awards. Any expense that does not meet all these criteria should not be directly charged to a federally sponsored project.
Sponsored Program Financial Administration (SFPA) is responsible for the submission of invoices for reimbursement of expenditures incurred in the process of conducting sponsored research and other sponsored activity. SPFA monitors and tracks outstanding invoices through the University accounting system, Workday. SPFA is also responsible for Draw Down and AR follow-up in collaboration with the PI and Department if needed.
To ensure that the university is in compliance with Federal regulations, the Principal Investigator (PI) and the department are required to record appropriate project expenses timely, and to support them with adequate documentation. Every cost placed on an account should be allowable, allocable and direct benefit to a project.
Cost transfers should be kept to a minimum by initially charging expenses to the appropriate sponsored account(s) in a timely and accurate manner. However, in those instances in which a cost transfer is required, the proposed cost transfer should comply with the following guidelines:
- Documentation of the original charge must be included with the appropriate cost transfer form.
- An explanation of the reason for the cost transfer is required on the appropriate cost transfer form. The explanation must address why the expense is being transferred and must provide more explanation than ex. "to correct an error" or "to transfer a cost." Funding issues are not sufficient justification for moving an expense to a sponsored project.
Cost sharing occurs when the university proposes, and the sponsor accepts, that a portion of award activities will be funded by the university. Once a cost sharing commitment is accepted, the university is obligated to expend those funds during the award period. Federal regulations and university policy require cost sharing transactions also be identified and tracked as such.
Program income is defined as gross income earned that is directly generated by a supported project activity or earned because of the award during the period of performance.
Examples of income include:
- Income from fees, such as registration fees for conferences and workshops
- Fees charged for laboratory tests and analysis
- License fees and royalties on patents and copyrights
- Fees garnered from the use or rental of property acquired using award funds
- Proceeds from the sale of items fabricated using award funds, such as software
When income is directly generated by a supported activity or earned as a result of an award, that income is considered part of the award and must be spent on award activities (i.e., funds generated by one award cannot be used for a different award or other activity). Program income is subject to the award terms and conditions, must be treated according to the sponsor’s requirements, and should be expended prior to requesting reimbursement against the award. There are no Federal requirements governing the disposition of income earned after the period of performance, unless the award specifies otherwise in the terms and conditions. For more information, please refer to the Uniform Guidance, § 200.307: Program Income.
Effort Certification Guidance:
Research Handbook
More information on the Office of Research and Innovation's policies and procedures can be found in the Research Handbook. Award financial management is covered in Chapter 6 (sign in required), while non-financial and administrative management is covered in Chapter 7 (sign in required).
For inquiries related to your sponsored award, contact the OSPA Specialist or Accountant assigned to your department using the OSPA Department Matrix [Excel].