CHAPTER SEVEN: Non-Financial Management of Awards
7.1 Post-Award Changes and Approvals
The Office of Sponsored Programs Grants Administraion (OSPGA), formerly known as Office of Grants Management (OGM), provides assistance in requesting changes and 3 approving changes related to the performance of a project if sponsor approval is required. Such changes may include but are not limited to the following:
· A change in the scope or the objectives of the project
· An increase in the funding
· A change in the PI/PD, other key personnel, or the addition of Subrecipient
· A change in the budget that is not covered by the rebudgeting authority originally granted by the sponsor
· A change in the performance period
For changes requiring sponsor approval, OSPGA will coordinate all requests to modify an award and will be the correspondent when detailing the need and justification for change. All communications should be drafted by the PI/PD and approved and countersigned by the Authorized University Official. OSPGA personnel are familiar with the different policies of sponsors, including rebudgeting as addressed in Section 6.3; therefore, OSPGA should be consulted if a revision to a sponsored program budget is being considered.
For those instances in which the sponsor has allowed the University to approve such changes, the procedure is similar. The PI/PD contacts the designated OSPGA personnel to request the change. The request is reviewed, and if the justification is reasonable, the request will be approved. If the request is for a change in the end date, OSPGA will notify the sponsor of the new end date.
To assure the successful completion of a grant or contract, a no-cost extension can be requested. Any extension is dependent on the sponsor’s policies but, with justification, 12 months beyond the original ending date can usually be obtained. Extensions do not usually allow for additional funds.
OSPGA has received authority from many federal sponsors to approve a one-time, no-cost extension of up to 12 months on a grant. If OSPGA has this authority, the PI/PD must provide an explanation why an extension is necessary. Notification must include the length of extension needed and must justify the need for the extension on programmatic grounds. OSPGA will notify the sponsoring agency and make internal adjustments necessary to reflect the extension. Requests for extensions should be made no later than 30 days prior to the termination of the grant.
If the University does not have delegated authority to grant no-cost extensions, requests must be made at least 60 days before the end of the current budget period. Written requests should come from the PI/PD and include the reason the extension is needed and the expected project completion date. A budget for use of any unexpended funds must be included in the request and the new budget approved by the Office of Sponsored Programs Grants Administration. Once the request is approved by the OSPGA, it will be countersigned and forwarded to the sponsor.
Change in Principal Investigator/Project Director
If a PI/PD will be absent from a project for a period of 3 months or more, a substitute PI/PD must be proposed and approved by OSPGA and the sponsor. The PI/PD must notify OSPGA as well as the sponsor at least 30 days before leaving the project or as soon as possible once the PI/PD knows he/she will be absent. It is necessary to identify a substitute PI/PD, to justify the change, and to include the curriculum vitae of the proposed replacement. The new PI/PD, as well as OSPGA, must endorse the request.
Goods and services for sponsored projects must be obtained in compliance with University Purchasing Policies and sponsor restrictions. Some awards prohibit certain purchases and others require the sponsor to approve purchases in advance. Purchases must be made and charged within the period of the agreement. Purchases must be appropriately allocated to the sponsored project. If an investigator has more than one award and items will be used by more than one project, the expense incurred in obtaining the items should be proportionately allocated to each research project budget.
Supplies and equipment not received during the project period are not considered of benefit to the project and may be disallowed. Consequently, no purchase of equipment should be made later than six months prior to the final termination date of an agreement. Government sponsors require reimbursement for unconsumed supplies with an aggregate value exceeding $5,000 at the end of a project period. Therefore, toward the end of a grant, purchases should be carefully planned to assure that quantities ordered could be consumed during the project period.
The University defines equipment as items with an acquisition cost of $5,000 or greater and a useful life of more than one year. Refer to the Equipment Policies for further discussion of equipment. If an equipment purchase is not authorized in the original budget, it may be necessary to obtain sponsor approval. OSPGA and the sponsor will not approve general-purpose equipment, such as computers or furniture, unless it is used primarily or exclusively for the research project.
Carry forward of Funds
Carry forward of unexpended balances from one budget period to the next is usually allowable but varies among sponsors. Typically, if the unexpended balance is less than 25% of the total budget, the balance can be carried forward without sponsor approval. Please refer questions related to carryforwards to the Office of Sponsored Programs Grants Administration.
Consultants are appropriate if:
· They will work independently without supervision
· They are not employees of the University and have not been so within the last 12 months
· They are using their own facilities or equipment to conduct the work
· They are eligible for participation in federal programs
Subawards are appropriate if:
· A third party is contracted to conduct a significant portion of the scope of work and the arrangement is approved by the funding agency
· The work of the Subrecipient is substantive and independent as is the case when the Subrecipient makes programmatic decisions and its performance is tied to the objectives of the project
· A third party is necessary to the successful completion of the work
· A subaward is identified in the original proposal or approval has been obtained that a subaward may be issued.
With sponsor approval, the Office of Sponsored Programs Grants Administration (OSPGA)/Industry Contracts (OIC) will issue a subaward document that will include a scope of work and budget and incorporate the appropriate terms and conditions of the prime grant or contract. When the Subrecipient has agreed to the terms and conditions and signed the agreement, it can invoice the University for its incurred expenses with the expectation that only in unusual circumstances will the University advance funds to a Subrecipient. It is the PI/PD's responsibility to monitor the activities of the Subrecipient, and to inform the sponsor and the OSPGA/OIC if significant changes are contemplated inthe Subrecipient arrangement. It is the responsibility of the controller to obtain an annual A133 or alternate documentation from the Subrecipient.
The Prime Recipient PI shall be responsible for obtaining timely invoices for all work performed to date and for determining that the work covered by the respective invoice(s) has been performed satisfactorily and that the costs associated with such performance are appropriate for the work performed. The Prime Repipient PI will be responsible for signing and dating each invoice as an indication of approval of the invoice for payment.
Prior to issuance of a subsequent year's Research Subaward Agreement/Amendment, Prime Recipient PI must sign and submit an attestation to Prime Recipient's Administrataive Contact ensuring that the Subrecipient's work has fulfilled the requirements of the previous year's Research Subaward Agreement/Amendment; that Subrecipient has submitted all required reports to date, and that satisfactory progress has been made.
Subrecipient shall maintain reasonable records incident to the performance of this Subaward and shall allow Prime Recipient access to those records upon request.
7.3 Other Award Management Considerations
Property purchased with sponsor funds is to be used for the sponsored project. Vesting of title and/or reporting requirements vary by sponsor. In some cases, equipment purchased with sponsored program funds remains the property of the sponsor. The Inventory Control Office within the Office of the VP for Business is responsible for the University's equipment management system, including inventory, record keeping, sharing, audit, and disposition.
Some agencies reserve the right to transfer the equipment following completion of the grant. The right to transfer equipment is normally reserved when the PI/PD transfers to another institution and the University has no further need for the equipment. There are many stipulations that govern the transfer or disposition of property. These stipulations vary under differing circumstances of ownership (title), original cost, source of funds, and current market value.
Questions regarding property management or disposition should be directed to the Inventory Control Office at extension 6131 or to the link above.
If the PI/PD has reason to believe that a potentially patentable invention or discovery has been made during the course of a sponsored program, it is important to make a disclosure to the Office of Technology Development (OTD) in the time frame required by the sponsor. OTD is responsible for submitting any disclosure or other periodic invention reporting required to the sponsor. Prompt disclosure allows the OTD to make a decision about pursuing patenting and licensing in accordance with University and sponsor policies.
A copy of the University's intellectual property policy is available. Questions about intellectual property developed during the course of a sponsored agreement should be directed to the Office of Technology Development at extension 2965.
The University retains the right of investigators to publish results of their research and scholarly activities in all sponsored agreements. Nonetheless, grants and contracts often contain clauses that require prior or simultaneous submission of papers or abstracts to the sponsor for review and comment before publication. Credit should normally be given to the source of support for the project through an appropriate footnote but specific instructions in each grant, contract or other agreement will govern.
The University of Louisville has developed Guidelines on the Ownership of Data. This statement addresses faculty obligations and responsibilities regarding access to and retention of research data.
Freedom of Information
Commonwealth of Kentucky statutes guarantee the right of access to information about public agencies. The Federal Freedom of Information Act (FOIA) applies to federally funded projects. University policy documents and funded research proposals must be disclosed to the public upon request. Exceptions include proprietary data or confidential salary information. Contact the Director of the University Archives for assistance on disclosure.
The University’s Travel Policies govern all travel unless sponsors have additional restrictions. Travel must directly benefit the project to be allowed on a sponsored program speedtype. In some cases, sponsor approval in advance is required for travel and foreign travel may need approval for each trip. Travel supported with federal funds usually requires the use of an American flag carrier. Please consult the Office of Sponsored Programs Grants Administration if foreign travel restrictions are unclear.
7.4 Reporting and Closeout
Grants and contracts specify the form, 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 the Controller is generally responsible for submitting financial reports and invoices. When unique financial reporting requirements are required, the department must assist the Office of the Controller 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. 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 Grants 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.
The Office of the Controller and the Office of Sponsored Programs Grants Administraion will assist PIs/PDs with closing sponsored projects by ensuring the timely submission of required final reports. Sponsors require different reports at closeout. As a rule, federal sponsors require financial, invention and technical reports. Property reports may also be required. Generally, reports are due 30 to 90 days from the expiration date of the sponsored agreement.
Final Technical Reports
The PI/PD is responsible for final technical reports. Sponsors that require their own forms for final technical reports may provide them in the application packages, with the award documents, or on-line via the internet. Sponsor instructions should be carefully followed. The Office of Sponsored Programs Grants Administration will follow up with the PI/PD and, if necessary, his/her chair and/or dean to ensure that the final technical report is submitted.
Final Invention Report
The Office of Technology Development will work with the PI/PD to complete reporting on inventions. The Office of Technology Development or the Office of Sponosred Programs Grants Administration, dependent upon sponsor guidelines, will forward final reports to the agency.
Final Financial Reports
The Office of the Controller usually prepares final financial reports. The PI/PD or academic department is responsible for reviewing a draft prior to final submission to the funding agency. Final reports require that all expenditures have been processed and personnel and other on-going charges moved to other appropriate accounts. In instances in which the department or program is responsible for preparation of the final financial report, the report should be submitted to the Office of the Controller for review and signature prior to submission. It is the responsibility of the controller to obtain an annual A133 or alternate documentation from the sub recipient.
Final Property Reports
The Office of the Controller will prepare property reports and submit them to the sponsor. When title to property acquired under a sponsored agreement vests with the sponsor when the project is complete, it may be possible to have the title transferred to the University. PIs/PDs wishing to request title transfer should inform the Sponsored Programs section of the Office of the Controller for preparation of the necessary request to the funding agency.
Some sponsors may ask the Department of Health and Human Services or its designated auditor to perform a closeout audit before final payment on a contract or grant or before the sponsor closes the account administratively. PIs/PDs who are notified that a sponsor wants to perform a closeout audit must contact the Sponsored Programs section of the Office of the Controller.
Residual Funds From Sponsored Projects
Some contracts allow the University to retain residual funds at the end of a project. If the agreement allows such retention, the Office of the Controller will work with the department to transfer the funds to an appropriate account. For more information, refer to the University’s Residual Funds Policy (PDF).
Award Speedtype Closings
Sponsored awards normally have a specified period for completion of the program. When the period expires, the Office of the Controller will work with the department to close the award on the PeopleSoft system. This will require a confirmation from the department that all of the proper charges have been placed on the speedtype, and that no charges are in error. All PeopleSoft speedtypes should have deficits resolved by transferring expenditures in excess of budget to discretionary or other departmental funds. Refer to Chapter 6, Section 4 for the University’s deficit policy. The Office of the Controller will verify that F&A has been properly charged to the speedtype.
Once these steps are complete, the Office of the Controller will prepare any necessary financial report for the sponsor and will collect any funds due from the sponsor. After all necessary reports have been filed and the correct amount of funds has been received, the Office of the Controller will close the speedtype on the system.
7.5 Record Retention
Maintaining adequate records on sponsored programs activities is a federal requirement. Even non-federal sponsors have very specific guidelines about the retention of records. All awardees are required to be aware of and meet the requirements of their sponsors as required by the University’s Records Retention Policy (PDF).
7.6 Transfer of Investigators to Other Institutions
If the PI/PD moves to another institution, the University of Louisville will transfer awards pending approval of the sponsor and the new institution. Generally, while an award does transfer with the PI/PD, criteria for this decision include considerations such as time left on the project, remaining funds, and whether the new institution has the resources in the form of facilities, equipment, and/or staff to take on specific sponsored projects.
Equipment charged to the project is transferred with the PI/PD if sponsor guidelines require it. Grants and contracts that do not require transfer will be considered on a case-by-case basis. As a rule, equipment bought on budgets of active grants will transfer and equipment bought on funds from grants that have ended will not. For information on how to transfer equipment, please contact the Office of Sponsored Programs Grants Administration.
7.7 Communications from Agencies
Letters from funding agencies to any University employee that suggest or identify the existence of a problem with the administration of a grant or contract must be forwarded immediately to the Executive Vice President for Research. The Executive Vice President for Research will determine the resources to be enlisted to work with the employee to address the concern so that it will not escalate into a serious compliance and/or legal problem.