Post-Award Administration

Upon approval of a grant application, the sponsor typically issues a "Grant Award" letter or notice to the Principal Investigator (PI). The following procedures must be followed:

• Award Notification: The PI must promptly provide the Office of Research Services (ORS) with a complete set of award documents, including any agreements or contracts requiring official University signatures.
• ORS Review and Processing:
  • ORS reviews all documents and executes accompanying contracts or agreements.
  • ORS prepares a formal Notification of Award, summarizing the terms and conditions, and codes the approved budget for execution by the PI.
  • With the ORS Director’s endorsement, the Notification of Award authorizes the establishment of a St. Joseph’s University (SJU) grant fund.
  • Copies of the Notification of Award are distributed to the PI, Department Chair, and Dean of the School.
• Budget Activation: Once the approved budget is entered into the University’s financial system, the PI is responsible for:
  • Executing the project to ensure completion of grant-supported activities and spending by the award termination date.
  • Preparing and submitting all technical reports to meet sponsor deadlines, with copies provided to ORS.
  • Requesting no-cost extensions through ORS, per sponsor guidelines, at least eight weeks before the award termination date.

After entering the award budget into the financial system, ORS is responsible for:

• Monitoring grant fiscal activity to ensure compliance with the approved budget and award terms.
• Managing invoicing, billing, fiscal reporting, and other requirements per OMB standards and award conditions.
• Preparing and maintaining quarterly time and effort reports for grant-funded salaries.
• Approving payroll authorization forms for grant-funded employees, ensuring fund availability and cost allowability. The PI must consult Human Resources for project-related staffing and follow University personnel policies for new hires.

Many federal programs require non-federal contributions, known as “cost sharing” or “matching,” governed by OMB Circular A-110. The PI must:

• Report all cost-sharing or in-kind matching to ORS, along with supporting documentation.
• Document institutional matching on the Routing Form during proposal submission, with the Approval for Matching Funds/Cost Share Form, bearing original signatures, filed with ORS.

All matching and cost-sharing resources must:

1. Be verifiable through the University’s accounting records.
2. Not to be used for other federally assisted projects in current or prior periods.
3. It is necessary and reasonable for achieving project objectives.
4. Be allowable under OMB Circular A-21, even for third-party contributions.
5. Not be funded by another federal award unless authorized by the federal agency.
6. Be included in the approved federal budget.

• Cash Outlays: Must demonstrate that non-federal funds benefited the project.
• Third-Party In-Kind Contributions:
  • Volunteer Services: Valued at rates consistent with similar work at the University, including salary and fringe benefits.
  • Donated Supplies: Valued at fair market value upon receipt.
  • Donated Equipment: Only depreciation may be used as a cost-sharing method.
  • Donated Space: Must be owned by a third party, not the grantee institution.

Due to audit risks, thorough documentation of cost sharing and matching is critical.

Program income is revenue directly generated by an award, including:

• Fees for services performed.
• Rental or use of property acquired under the award.
• Sales of commodities or items fabricated under the award.
• License fees and royalties on patents and copyrights.
• Interest on loans made with award funds.

Program income is considered a grant asset and must be used per award terms. Options include:

1. Expanding the project scope beyond the approved budget (up to $25,000).
2. Meeting cost-sharing or matching requirements.
3. Reducing the federal share of the project (deductive alternative, preferred by the federal government).

The PI must monitor expenditures to ensure compliance with the award terms, while ORS provides oversight. All grant-funded expenditures must:

1. Be for official University business.
2. Be reasonable under the specific program guidelines.
3. Contribute to the project’s objectives.

Refer to the University’s policy on Allowable Costs and Cost Principles for further guidance.

Common unallowable costs include:

• Personal use items.
• Personal gifts.
• Sporting event fees.
• Political or charitable contributions.
• Event attendance donations.
• Memberships or dues to organizations, unless directly serving the project.
• Alcoholic beverages.

See the University’s policy on Unallowable Costs for a complete list.

Before the grant termination date, the PI should:

• Review the grant for available funds, deficits, expenditure accuracy, and outstanding encumbrances.
• Submit all requisitions to ORS by the termination date.
• Request extensions through ORS, in writing, six to eight weeks before the termination date.

Sponsors typically require a final, comprehensive project report. Timely submission is critical to maintain the University’s reputation and secure future funding. Responsibilities include:

• PI: Completing and submitting the final project report, if required.
• ORS: Handling final financial reporting requirements.

All modifications to grants, contracts, or agreements must be processed through ORS. Budget reallocation permissions vary by sponsor, and prior approval is required before expenditures. Procedures include:

• Complete a Project Change Form, specifying the request (e.g., budget reallocation, no-cost extension, change of PI) and providing detailed justification.
• ORS reviews the request:
  • If internally approvable, the ORS Director endorses and processes it.
  • If sponsor approval is needed, ORS forwards a written request to the sponsor with justification and revised budget (if applicable). Upon sponsor approval, the ORS Director endorses and processes the request.

Contact ORS for specific guidance on modifications.

• Direct Cost Guidelines
• Expenditure Approval Policy
• Grant Budgeting Reallocation Policy
• Administrative Responsibilities
• Financial Conflict of Interest
  • SFI Disclosure Form
• Allowable Cost and Cost Principles
• Unallowable Costs
  • Unallowable Cost Table
• Cost Transfer Policy

Thomas Kaeo
Director, ORS
Telephone: (610) 660-1206
Email: tkaeo@sju.edu

Amy Robinson
Grants Accountant
Telephone: (610) 660-1910
Email: arobinson@sju.edu