Provides information on post award administration of grants and contracts.
Post Award Administration
Once an award is made it is the University’s responsibility to provide proper management of the fund awarded. This management should not be viewed as a control function, but rather providing support to the project to achieve the ultimate goal of the research being conducted. The role of the research accountant is to provide management for research, not of research.
Principal Investigator Responsibility
The Principal Investigator is ultimately responsible for accomplishing the technical goals of the project and for the fiscal management in accordance with sponsor federal, and University regulations. These fiscal management responsibilities include:
- Authorizing only those expenditures that are reasonable and necessary to accomplish the project goals and are consistent with the sponsor’s terms and conditions;
- Spending no more than the amount authorized by the sponsor for the project period;
- charging project costs directly to the appropriate project account (thus avoiding unnecessary budget transfers);
- review expenditures in a timely manner to ssure that all expenses are correct;
- documenting cost sharing commitments.
Therefore, payroll authorization forms, purchase orders, travel reports, and request for payments should have the signature of the responsible Principal
Research Accountant Responsibility
The Research Accountant is responsible for maintaining the financial records of the research project. These responsibilities include:
- setting up the project budget in the Banner system once an award notification is received from the Office of Research Services;
- reviewing the project financials on a monthly basis to verify that all expenditures are meeting sponsor, federal, and University regulations;
- approval for payroll authorization, purchase orders, travel expenses, and request for funds;
- invoicing for cost reimbursement;
- maintaining financial documentation for any cost sharing;
- allocation of facilities and administration costs;
- any financial reporting that is required by the sponsor.
The federal government through OMB Circular A-110 and A-21, has provided a set of standards which apply to significant areas of administration concerns such as financial management, purchasing, property management, and record access and retention. These “standards” are presented as a minimum set of requirements that must be met by each organization doing business with the federal government in the area of grants and cooperative agreements.
Sponsors have different policies for the rebudgeting of funds. Some sponsors allow latitude in making budget revisions and most requests for budget revisions from one budget category to another can be handled at the University level. To determine whether the award agreement and sponsor permit reallocation among budget categories please contact the Office of Research Services. A written request to the sponsor, countersigned by ORS, may be required.
The most confusing area of grants management is determining what costs are allowable. It is the responsibility of both the Principal Investigator and the Research Accountant to monitor all expenditures to assure compliance with sponsor and federal regulations. It is the policy of the University that all expenditures of grant funds must meet the following standards:
1. must be official University business only;
2. are reasonable under the guidelines of the specific program or project;
3. must contribute to the accomplishment for the specific program or project for which they are being charged.
The following is a list of unallowable charges:
- any item for personal use;
- personal gifts of any kind;
- fees for any sporting event;
- political contributions;
- lobbying costs;
- donations to charitable organizations;
- alcoholic beverages;
- membership dues to a society, association, or organization unless specifically requested in the approved budget;
- capital improvements.
A reasonable cost is recognized as being necessary for the performance of the program or project. The Office of Financial Affairs reviews all expenses charged to sponsored funds for allowability.
Salary and Compensation
Charges for work performed on sponsored agreements by faculty and staff members will be based on the employee’s regular annual salary. All budgets should state the amount of salary that is allowable, either as a percentage or a stated amount. Under federally sponsored programs clerical salaries can not be treated as direct cost unless specifically stated and approved by the federal funding agency. Salary for clerical support can be charged as facilities and administrative costs.
In exceptional cases work on a sponsored agreement is more appropriately performed on an overload basis. Overload is when an employee is being paid over their annual salary. Generally it is not permissible to use federal funds as overload, therefore funds to be used as overload payment should come from a University account. If an employee is to receive overload compensation he/she will need prior approval from the Vice President for Academic Affairs.
Intra-University consulting is considered a University obligation requiring no compensation in addition to the full time salary. In unusual circumstances payment may be received if all of the following conditions are met:
1. the consulting is across departmental lines or at a separate or remote location;
2. work performed is in addition to the departmental workload; and
3. the agreement from the sponsoring agency specifically list the university faculty as a consultant and approves payment for the individual.
To pay an intra-university consultant a Payroll Authorization Form must be completed and signed by the departmental chair of the Principal Investigator and the Research Accountant.
A subcontract is a written agreement in which a sponsored project or program is carried out by the University and one or more cooperating institutions that are separate legal entities independent of the University. Prior approval from the funding agency is necessary before any of the project work can be contracted out. All arrangements for conduct of activities that are subcontracted shall be formalized in a contract between the University and the third party. These negotiations are performed by the Office of Research Services. Contracts should only be made with responsible contractors who possess the ability to perform the work that is being contracted out.
Payment to a subcontractor is done through monthly invoicing. Once an project is funded and an agreement is signed, the subcontractor can begin invoicing the University for reimbursement of expenses. Invoices should be sent to the Principal Investigator for review then forwarded to the Research Accountant for approval and processing. It remains the Principal Investigator’s responsibility to monitor the activities of the subcontractor.
When hiring an external consultant, the Principal Investigator should keep in mind the following tests that determine the appropriateness of such a consultant:
- that the consultant is doing work independently without supervision;
- that the consultant has not been a recent employee of the university;
- and that the consultant is using his/her own facilities or equipment to conduct the work.
Prior sponsored approval may be required for the use of consultants not authorized on the approved budget. For further guidance please contact the Office of Research Services.
To pay for a consultant, he/she must submit an official invoice to the Principal Investigator. A Request for Funds must be completed and authorized by the Principal Investigator. The Request for Funds and the invoice must be sent to the Research Accountant for approval and processing.
If the project’s expenditures exceed the sponsor’s award and/or payment upon completion of the project, the Principal Investigator will be asked to identify another funding source (normally a departmental account) to cover the cost overrun.
The University is required by the federal government to review and certify to the time and effort spent by employees on sponsored programs via the Effort Reporting System. This system reflects activity applicable to each sponsored agreement and to each category needed to identify F&A costs and the functions to which they are allocable.