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. Many times sponsor prior approval is required before certain actions can be taken which is why it is very important that any changes must be addressed in advance of their occurrence.
Grants and contracts specify the frequency and type of reports, including financial reports, management 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 Administration is generally responsible for submitting financial reports and invoices. When unique financial reporting requirements are required, 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 any 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 be need to request a budget reallocation. 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. To issue this request, please send an email to your assigned Grants Management Specialist and Grants and Contracts Assistant with the following details:
- Which budget categories should be reduced, and by what amounts
- Which budget categories should be increased, and by what amounts
- Detailed justification for the reallocation
- Copies of price quotes, if applicable (for example: equipment purchases)
There are varying reasons why an investigator may need to alter the proposed scope of work (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 Grants Management Specialist as soon as possible. In many cases, a formal written letter countersigned by an institutional official may be required. Your Grants Management 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 Grants Management Specialist for review prior to signature and submission. At times, progress reports may also require a 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 the subaward sites are completing the assigned scope of work in a timely manner. PI’s should review and approve all invoices from subaward sites prior to requesting issuance of payment. Additionally, the sub 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 subsite has completed the work satisfactorily and has been invoicing appropriately.
There are several contributing factors that may lead to a project having a new Principal Investigator or Project Director identified. These may include (not an exhaustive list):
- The PI is relocating to another institution but not transferring the grant/project to the new institution
- Health issues that would prevent the Principal Investigator from completing the project
- Changes in the current Principal Investigator's responsibilities within the University
- Absence of the Principal Investigator for an extened period
If you find it necessary to change the identified Principal Investigator/Project Director, you will want to contact your assigned Grants Management Specialist as early as possible in the process. Such requests will require prior approval from the sponsor, and your Grants Management Specialist will assist in navigating this process, including providing information regarding necessary University and sponsor documentation required as well as facilitate the review and submission process.
Many sponsors will allow for 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 termination date. Some no cost extension requests and approvals are able to be processed by the Office of Sponsored Programs Administration through expanded authorities provided to us by the sponsors. Some require sponsor prior approval. In either situation, the information we must collect is the same. You will need to contact your assigned Grants Management Specialist with the following information:
- 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 Grants Management 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.
Unless the sponsor's terms and conditions are MORE restrictive, the University follows the NIH Grants Policy Statement (NIHGPS) which 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 of Louisville. A PI will be held accountable for the appropriate fiscal management and conduct of the research project. Sponsors hold the University of Louisville 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 to manage your sponsored funds to ensure that expenditures and revenues are within appropriate limits and guidelines. More information on limits and guidelines can be found on the appropriate sponsor websites and in the OMB Super Circular. In addition, regular monitoring of your sponsored accounts helps to:
- Ascertain 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 stop 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.
- Give your Principal Investigator a high degree of confidence that the project complies with the sponsor's spending terms and conditions.
- Verify cost transfers and corrections are made in a timely manner.
- Maintain a clear audit trail for the future.
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 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.