CHAPTER SEVEN: Administrative/Non-Financial Management of Awards

7.1 Post-Award Changes and Approvals

Personnel within the Office of Sponsored Programs Administration (OSPA) assist in obtaining Institutional and Sponsor approval (if required) of administrative and budgetary changes to a sponsored project. Such changes may include but are not limited to the following:

1) A change in the scope or the objectives of the project;

2) A change in the amount in funding;

3) A change in the PI/PD, other key personnel, or the addition of a Subrecipient;

4) A change that is not covered by the authority granted by the Sponsor;

5) A change in the period of performance.

All communications should be drafted by the PI/PD and approved and countersigned by the Authorized Institutional Official prior to submission to the Sponsor (if required).  OSPA will coordinate all requests and communications with the Sponsor. Upon approval, OSPA will notify the appropriate parties.

No-Cost Extensions

To assure the successful completion of a sponsored project, a no-cost extension may be requested.  Extensions are dependent upon the Sponsor’s policies but, with justification, 12 months beyond the original end date can usually be obtained.  No-cost extensions do not allow for additional funding but may authorize continued spending of remaining funds. Under Expanded Authority, the University may approve a one-time, no-cost extension of up to 12 months on a sponsored project with notification to the Sponsor. Requests for no-cost extensions should be made in accordance with Sponsor guidelines and submitted to OSPA no later than 30 days prior to the end date of the award.

If the University does not have delegated authority to grant a no-cost extension, requests must be submitted to OSPA at least 60 days prior to the end date of the award.  Written requests should be initiated by the PI/PD and include justification for the request, a budget for the no-cost extension period, and the expected project completion date. Upon approval by OSPA, the request will be forwarded to the Sponsor by the respective Authorized Institutional Official (if required).

Change in or Absence of a Principal Investigator/Project Director

If a PI/PD is unwilling or unable to continue to direct a sponsored project, a replacement PI/PD must be proposed and approved by appropriate University officials and OSPA.  Following Institutional approval the request and justification will be forwarded to the Sponsor along with the Curriculum Vitae and/or Biographical Sketch of the replacement PI/PD.

If a PI/PD will be disengaged from a project for a period of 3 months or more or is requesting a significant percentage reduction in time devoted to the project, prior approval must typically be obtained from the Sponsor. Note that PIs/PDs can be away from campus and still be considered engaged in a project. Written requests should be initiated by the PI/PD and include justification for the request. Upon approval by OSPA, the request will be forwarded to the Sponsor by the respective Authorized Institutional Official (if required).

Carry Forward of Funds

Allowability of the carry forward of unexpended funds/remaining balances from one budget period to the next varies among Sponsors. PIs/PDs should reference the terms and conditions of the respective award to determine whether or not the carry forward of funds is allowable. Any questions related to carry forward of funds can be sent to OSPA.

7.2 External Resources on Sponsored Projects

External Consultants

Consultants are appropriate if:

1) They will work independently without supervision;

2) They are not employees of the University;

3) They are using their own facilities or equipment to conduct the work;

4) They are eligible for participation on Federal programs.

Subawards

Subawards are appropriate if:

1) A third party is identified in the original proposal to conduct a significant portion of the scope of work and is approved by the Sponsor;

2) The work of the Subrecipient is substantive and independent; the Subrecipient makes programmatic decisions and its performance is tied to the objectives of the project;

3) The need for a Subrecipient is determined during the course of the project.

With Sponsor approval, OSPA will issue a subaward agreement that will include a scope of work, budget, and the appropriate terms and conditions of the prime award. Once the subaward agreement has been fully executed, the Subrecipient can invoice the University for expenses incurred during the budget period. It is the PI/PD's responsibility to monitor the activities of the Subrecipient and to inform OSPA if significant changes are contemplated in the subaward agreement.  It is the responsibility of OSPA to obtain and review an annual A-133 or alternate audit documentation from the Subrecipient.

The PI/PD should obtain and process timely invoices for all work performed by a Subrecipient and should determine 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 PI/PD should sign and date each invoice as an indication of approval of the invoice for payment.

Prior to the issuance of a subsequent year's subaward agreement/amendment, the PI/PD must attest that the Subrecipient's work has fulfilled the requirements of the previous year's subaward agreement and that the Subrecipient has submitted all required reports and satisfactory progress has been made. Subrecipients shall maintain reasonable records incident to the performance of a subaward and shall allow the University to access the records upon request.

7.3 Other Award Management Considerations

Property Management/Disposition

Property purchased with sponsored 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 funds remains the property of the Sponsor. The Inventory Control Office is responsible for the University's equipment/asset management system, including inventory, record keeping, sharing, audit, and disposition.

The ownership and transfer rights related to property purchased with sponsored funds is typically defined in the terms and conditions of the award agreement.  The terms and conditions may vary by Sponsor and differing circumstances of ownership (title), original cost, source of funds, and current market value.

Questions regarding property management or disposition should be directed to OSPA and to the Inventory Control Office (852-6131).

Intellectual Property

Questions about intellectual property developed during the course of a sponsored award should be directed to the Commercialization EPI-Center.

If the PI/PD has reason to believe that a potentially protectable invention or discovery has been made during the course of a sponsored award, a disclosure must be submitted to the EPI-Center in the time frame required by the Sponsor as may be outlined in the proposal/agreement or Sponsor guidelines. The EPI-Center is responsible for submitting any disclosure or other periodic invention reports required to the Sponsor. Prompt disclosure allows the EPI-Center to make a decision about pursuing patenting and licensing in accordance with University and Sponsor policies.

Publications

University researchers and their students need the ability to use data and other research work products for noncommercial educational and research purposes and the right to independently publish. This right can be provided under license, can be limited by a sponsor’s right of review or can be delayed for a short period to permit the protection of IP rights.  Credit should be given to the source of support for the project through an appropriate acknowledgement and the terms and conditions of the agreement typically dictate.

If a proposed sponsored agreement restricts publication rights beyond what is described above, OSPA will coordinate with the Commercialization EPI-Center and the Office of Export and Secure Research Compliance to negotiate appropriate publication rights.

Research Data

The University of Louisville has developed Guidelines on the Ownership of Data which address 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. Contact University Archives for assistance on disclosure.

Travel

The University’s Travel Policy governs all travel unless Sponsors have additional restrictions. Travel supported with federal funds usually requires the use of an American flag carrier.  Section 200.474 of 2 CFR 200 requires that “if travel costs are charged directly to the Federal award documentation must justify that: (1) Participation of the individual is necessary to the Federal award; and (2) The costs are reasonable and consistent with the non-Federal entity’s established travel policy.” For additional information on travel on sponsored awards please consult with OSPA.

7.4 Reporting and Closeout

Reporting

Sponsors specify the form, frequency and types of reports required, including financial reports, progress reports, case report forms (for clinical trials) and invention disclosure/reports.  The PI/PD is solely responsible for meeting all technical and programmatic reporting requirements.  The Office of Sponsored Programs Administration-Financial Administration Core is generally responsible for submitting financial reports and invoices.  When unique financial reporting requirements are necessary, the PI/PD may need to assist with the development of the report.

The University considers timely reporting essential to the proper stewardship of sponsored funds.  Consequences when reports are not submitted in a timely manner include but are not limited to: payment for project expenses may be withheld; pending proposals may not receive favorable consideration; and/or some Sponsors may withhold future awards to the University.

Technical Reports

The PI/PD is responsible for preparation and submission of technical reports.  Sponsor-required forms for final technical reports may be provided as part of the application package, with the award documentation, or on a Sponsor’s website.

Invention Reports

OSPA, in conjunction with the Commercialization EPI-Center, will work with the PI/PD to complete and submit invention reports.

Financial Reports

Sponsored Programs Administration-Financial Administration Core is responsible for preparing/reviewing financial reports. The PI/PD or department designee is responsible for reviewing and approving a draft financial report prior to submission to the Sponsor. Final financial reports require that all related expenditures have been posted to the appropriate account.  In instances in which the department or program is responsible for preparation of the financial report, the report must be submitted to Sponsored Programs Administration for review and approval prior to submission.

Property Reports

The PI/PD will prepare property reports and submit them to Sponsored Programs Administration for review, approval, and submission to the Sponsor.  When title to property acquired under a sponsored agreement vests with the Sponsor, it may be possible to have the title transferred to the University.  Contact OSPA for additional information.

Delinquency in Reporting

Delinquent reporting can have an adverse impact on the University’s relationship with Sponsors. Upon notification of delinquency, the Office of the EVPRI will inform departmental chairs and the respective deans of the issue. With permission of the EVPRI, OSPA may withhold submission of new proposals and establishment of awards for PIs/PDs who are seriously delinquent in their reporting responsibilities.

Closeout Reporting

OSPA will assist PIs/PDs with closing sponsored projects by ensuring the timely submission of required final reports. Reports may be due 30 to 120 days following the expiration date of the sponsored agreement. Reports required at closeout may vary by Sponsor.  As a general rule, Federal sponsors require financial, invention, and technical reports; property reports may also be required.

Closeout Audit

Some Sponsors may request that its designated auditor perform a closeout audit prior to issuance of final payment on a sponsored project. PIs/PDs who are notified that a Sponsor intends to perform a closeout audit must contact OSPA.

Residual Funds on Sponsored Projects

Some Sponsored agreements allow the University to retain residual funds upon completion of the project.  If the agreement allows for such retention, the Office of Sponsored Programs Administration-Financial Administration Core will work with the PI/PD or departmental designee to ensure that all expenditures have been posted to the award and to transfer remaining funds to an appropriate residual account.

Award Chartfield/Speedtype Closings

Sponsored awards typically have a specified period of performance.  When the award expires, Sponsored Programs Administration-Financial Administration Core  (SPFA) will work with the PI/PD or departmental designee to confirm effort, address any deficits and closeout the award.  SPFA will obtain confirmation that all charges have been posted to the chartfield/speedtype and are appropriate, allowable, and allocable to the project. The award will then be officially closed in the financial system.

7.5 Record Retention

Maintaining adequate records on sponsored programs/activities is required by Federal agencies as well as most other Sponsors. PIs/PDs and their designees are required to be aware of and meet the requirements of the respective Sponsors, Agreements or as defined by the University’s Records Retention Policy.

7.6 Transfer of Sponsored Projects to Other Institutions

If the PI/PD of an active sponsored project moves to another institution, the University of Louisville may agree to transfer the award(s).  Such transfer must be approved by the University and Sponsor. Equipment purchased on sponsored awards may be transferred to the new institution depending upon the nature of the project and the terms and conditions of the award.

7.7 Communications from Sponsors

Letters or other communications from Sponsors to any University employee that suggest or identify the existence of a potential problem with the administration of a sponsored project must be forwarded immediately to a Director in OSPA for review, further communication and resolution.

7.8 NIH Awards: Progress Reports and Carryover Requests

Reason For Procedure

With tighter budgets and increased monitoring of awards by NIH agencies, it is important that both progress reports and carryover requests for non-SNAP (Streamlined Noncompeting Award Process) awards be submitted in a timely and accurate manner in order to avoid loss of funding. This notice clarifies procedures on preparation of progress reports and the submittal/processing of carryover requests.

Progress Reports:

Annual NIH non-Research Performance Progress Reports (RPPRs) should be submitted by the date listed in the federal Electronic Research Administration (eRA) system (normally 60 days before the end date of the budget period). Annual RPPRs for NIH e-snap awards should be submitted 45 days prior to the end date of the budget period. Once uploaded the PI must route the RPPR to the respective Grants Management Specialist for review and approval. Once reviewed and approved, an Office of Sponsored Programs Administration (OSPA) institutional official will submit the RPPR and email the PI and departmental contact accordingly.   OSPA must receive the continuation proposal five (5) business days prior to the deadline in order to review, approve, and submit the documents on time. Timely submission of NIH RPPRs is required in order to ensure 1) on-time issuance of the continuation award notice from NIH and 2) approval of requests by the NIH for carryover of unobligated funds. 

Carryover Requests: 

If it is anticipated that a carryover of unobligated funds to a future year will be required for an NIH non-eSNAP award, the carryover request should be described within the NIH continuation RPPR. As the exact amount of unobligated funds requested for carryover may not be known until the Federal Financial Status Report (FFR) [previously called the Financial Status Report (FSR)] is prepared, the carryover request described in the RPPR should include a best estimate of the amount of carryover being requested.

When the FFR is later submitted to NIH via the Office of Sponsored Programs Administration (OSPA), the exact carryover amount requested should be included in Item 12 “Remarks” of the FFR. Simultaneously, a separate written request must be submitted to NIH (via OSPA) as detailed in the NIH Grants Policy Statement, Part II, Terms & Conditions. All carryover requests must include a well-detailed justification of the need for the carryover funds and how they will be used for the benefit of the project.

NIH’s decision about the disposition of a reported unobligated balance will be reflected in the Notice of Award (NoA) for non-SNAP awards that require formal NIH Grants Management Specialist approval. Upon receipt, OSPA and the PI/PD must review the award notice to ensure that the carryover request has been approved, and if questions arise concerning the carryover amount approved or not approved OSPA will contact the NIH GMS for clarification.

Competitive Renewals for SNAP Awards:

If the request for carryover is related to a competitive renewal and the FFR is accepted and approved, the OSPA will process the budget transfer and notify the PI and departmental contact accordingly.

Transfer Awards:

Following receipt of a transfer award, additional carryover from the previous institution may be released and made available for carryover. In this event, a letter from NIH Closeout or a revised Notice of Award will be issued. Once received, OSPA will process the budget transfer and notify the PI and departmental contact accordingly.

T32 Awards:

These grants have special conditions regarding trainee stipends. When an appointment starts in a budget period, the entire stipend for that appointment must be charged to that same budget period. Trainee appointments may extend beyond the end date of the budget period to accommodate a normal 12-month appointment EXCEPT in the final year of the project. In order for appointments to extend beyond the end date, the grantee must send an e-mail request for an extension to avoid issues with appointments through XTRAIN. If an appointment does extend beyond the end date of the budget period, the Federal Financial Report (FFR) should reflect the portion of the stipend commitment remaining unpaid as of the end of the budget period as an unliquidated obligation. Once the FFR for the previous year is accepted/approved, OSPA will move only the unliquidated stipend amount to the new award year. If the PI identifies a need to retain the unobligated balance, a request for prior approval must be submitted through OSPA for review and approval prior to submission. Approval will result in issuance of a revised NoA, at which time OSPA will process the budget transfer and notify the PI and departmental contact accordingly.

11/25/2020