Module 4: PostAward Administration of Sponsored Projects Part 2

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Module 4 Post-Award Administration of Sponsored
Projects (Part 2)

• Office of Research and Sponsored Programs
• The University of Mississippi
• 100 Barr Hall 662-915-7482
• www.olemiss.edu/depts/research

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Part 2 of Module 4 provides detailed information
on some of the most common post-award
administration activities including

• Changes to an existing award
• Subawards
• Regrants
• Reporting
• Closeout
• Beyond closeout

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Changes to an existing award
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Changes to an existing award

• Some changes can be approved by the institution
  (through the ORSP) this is called Expanded
  Authorities (not applicable to federal
  contracts)
• Other changes require prior approval from the
  sponsor
• The award terms and conditions will tell you how
  to handle changes to an existing award
• Any change that is subject to Expanded
  Authorities or that requires sponsor prior
  approval should be processed through the ORSP

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Changes that always require sponsor prior approval

• Written prior approval from the sponsor is always
  required for any of the following
• Change in the project scope or objectives
• Absence of the principal investigator for more
  than three months or a reduction of 25 or more
  in effort devoted to the project
• Change in key personnel
• The transfer of funds allotted for training
  allowances (direct payment to trainees) to other
  categories of expense
• Transfer the performance of substantive work on
  the project to a third party (subcontract,
  subaward)

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Changes that sometimes require sponsor prior
approval

• Written prior approval from the sponsor is
  sometimes required for any of the following
• Purchase of equipment not in the approved budget
• Use of consultants
• Rebudgeting between direct and FA costs

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Changes that do not require sponsor prior approval

• OMB Circular A-110 permits federal granting
  agencies to waive certain sponsor prior approval
  requirements and gives the grantee institution
  the authority to approve actions such as
• Incurring pre-award costs (if allowed by the
  agency)
• First-time no-cost extension of up to one year
  (but you cannot extend just to spend out
  remaining funds)
• Carry forward of unobligated balances

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How do I obtain prior approval?

• It depends on whether your award is
• Federal or
• Non-federal

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Obtaining prior approval on federal awards

• To obtain institutional prior approval, the
  investigator should complete a UM Prior Approval
  System for Federal Grants and Agreements form and
  forward it to the ORSP
• then
• The ORSP will request prior approval from the
  sponsor if sponsor approval required or..
• The ORSP will notify the sponsor of the change if
  institutional approval required

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Obtaining prior approval on non-federal awards

• Contact the ORSP
• The ORSP will request prior approval from the
  sponsor if sponsor approval required or..
• The ORSP will notify the sponsor of the change if
  institutional approval required

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Subawards
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Subawards

• Need for a subaward
• Initiating subawards
• Monitoring subawards
• Changing subawards
• Closing subawards

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Need for a subaward

• The potential need for a subaward should be
  considered by the investigator at the proposal
  stage.
• Why?
• Because most funding agencies require written
  approval before a subaward is issued
• Because (depending on sponsor guidelines) other
  information may be required such as
• Letter of intent
• Biographical sketch
• Current and pending other support
• Available facilities information

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Initiating subawards

• The steps to be taken in initiating a subaward
  depend upon whether
• The subaward was included in the approved award
  budget, or
• The subaward was not included in the approved
  award budget

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Initiating subawards Subaward included in
approved budget investigator responsibilities

• The investigator should forward the following to
  the ORSP
• Request to Issue Subcontract or Subcontract
  Modification Under an Externally Funded Program
  form
• Statement of Work (approved by subaward
  institution)
• Budget (approved by subaward institution)
• Copy of the subrecipients FA Rate Agreement (if
  FA is being requested)
• then

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Initiating subawardsSubaward included in
approved budget ORSP responsibilities

• The ORSP will
• Determine that the subrecipient is not debarred
  or suspended from receiving federal awards
• Develop the subaward in compliance with
  sponsoring agency guidelines, UM and subrecipient
  policies and procedures
• Obtain subrecipient A-133 Compliance
  Certification, if applicable
• Obtain signatures of the UM investigator, the
  subrecipient authorized official, and the VC/ORSP
  to execute the subaward
• Create a purchase order to encumber funds
• Provide a copy of the fully executed subaward to
  the UM investigator
• Annually, ensure that the subrecipient remains
  compliant with A-133 audit requirements
  throughout the life of the subaward
• Perform desk audits as necessary for review of
  subrecipient fiscal records

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Initiating subawardsSubaward NOT included in
approved budget investigator responsibilities

• The investigator should
• Obtain sponsor approval to issue the subaward
  (concurrence of the technical manager, then
  approval of the grant/contract manager)
• Document the basis for subrecipient selection
• Forward the following to the ORSP
• A Request to Issue Subcontract or Subcontract
  Modification Under an Externally Funded Program
  form
• Statement of Work (approved by subaward
  institution)
• Budget (approved by subaward institution)
• Copy of the subrecipients FA Rate Agreement (if
  FA is being requested)
• Documentation of sponsor approval of the subaward
• then

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Initiating subawardsSubaward NOT included in
approved budget ORSP responsibilities

• The ORSP will
• Determine that the subrecipient is not debarred
  or suspended from receiving federal awards
• Develop the subaward in compliance with
  sponsoring agency guidelines, UM and subrecipient
  policies and procedures
• Obtain subrecipient A-133 Compliance
  Certification, if applicable
• Obtain signatures of the UM investigator, the
  subrecipient authorized official, and the VC/ORSP
  to execute the subaward
• Create a purchase order to encumber funds
• Provide a copy of the fully executed subaward to
  the UM investigator
• Annually, ensure that the subrecipient remains
  compliant with A-133 audit requirements
  throughout the life of the subaward
• Perform desk audits as necessary for review of
  subrecipient fiscal records

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Monitoring UM subawardsInvestigator
responsibilities

• Provide ongoing monitoring of subrecipients
  programmatic and fiscal compliance throughout the
  life of the subaward
• Maintain regular contact with subaward principal
  investigator regarding technical aspects of
  project
• Review and approve subrecipient invoices
• Perform site visits as necessary to review fiscal
  and program-matic records and/or observe
  programmatic activities of the subrecipient
• Ensure that all deliverables (e.g., technical,
  equipment, and invention reports) required under
  the subaward are being provided before approving
  invoice payment

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Monitoring UM subawardsORSP responsibilities

• Inform each subrecipient of the Catalog of
  Federal Domestic Assistance (CFDA) title and
  number, award name and number, and name of the
  federal agency providing funding, if applicable
• Advise subrecipients of the requirements imposed
  on them by federal laws, regulations, the
  provisions of the prime award, or provisions of
  UM
• Ensure that non-profit subrecipients expending
  500,000 or more in federal awards during the
  subrecipients fiscal year have met the audit
  requirements of OMB Circular A-133
• and

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Monitoring UM subawardsMore ORSP
responsibilities

• Issue a management decision (when subrecipients
  have A-133 audit findings) within six months
  after receipt of the subrecipients audit report
  and ensure that the subrecipient takes
  appropriate and timely corrective action
• Consider whether subrecipient audits necessitate
  adjustment of UMs own records
• Require each subrecipient to permit UM and
  auditors to have access to the records and
  financial statements as necessary for audit
  purpose
• and

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Monitoring UM subawardsMore ORSP
responsibilities

• Review and approve subrecipient invoices and
  forward them to the investigator for final review
  and approval
• Perform desk audits and/or site visits as
  necessary for review of subrecipient financial
  records
• Obtain a Small Business Subcontracting Plan from
  the subrecipient if a subaward is on a federal
  contract incorporating the Small Business
  Subcontracting Plan requirement, the amount of
  the award is 500,000 AND the subrecipient is
  not a small business

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Changes to existing subawards

• A formal amendment or modification should be
  issued to make one or more of the following
  changes to an existing UM subaward
• Change in period of performance
• Significant change to the budget
• Change in scope of work
• Change of key personnel
• Acquisition of equipment not in the budget
• Issuance of a lower-tier subaward

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Initiating a change to an existing subaward

• To initiate a change to an existing UM subaward,
  the investigator should
• Obtain prior approval of the sponsor, if required
  (concurrence of the technical manager, then
  approval of the grant/contract manager)
• Forward the following to the ORSP
• Request to Issue Subcontract or Subcontract
  Modification Under an Externally Funded Program
  form
• Description of the change
• Approved budget (if changing funding)
• Documentation of sponsor approval (if prior
  approval required)

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Closing subawards

• Subawards must be closed by UM before the prime
  award close date (ORSP recommends 30 days before)
• Subawards typically have closeout requirements
  similar to those of the prime award
• The investigator is responsible for insuring that
  the subrecipient has submitted all required
  closeout reports and a FINAL invoice to UM

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Regrants
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Regrants

• On occasion, a sponsored program will require
  contracting with a UM faculty member who has been
  selected to perform a portion of the statement of
  work, but who was not included in the approved
  budget as program personnel. Funds for the
  faculty members effort are provided in the form
  of a regrant.

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Regrants

• In order to initiate the process of transferring
  funds for the faculty members use, a Request to
  Issue Regrant form, along with a Transmittal
  Sheet, statement of work and budget, should be
  submitted to the ORSP.
• Work performed under a regrant is subject to the
  same terms and conditions as the original award.

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Reporting
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Reporting Technical

• Investigator is responsible for preparation and
  submission to sponsor
• Frequency and format specified in award terms and
  conditions
• Timely submission is important
• Failure to submit in a timely manner could
  jeopardize future funding from the sponsor
• Sponsor uses technical report to monitor and
  evaluate project performance

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Reporting Financial

• Accounting Department is responsible for
  preparation and submission to sponsor BUT
  investigator is responsible for submitting to
  Accounting the following information to be used
  in financial reports
• Effort reporting and certification (see Module 6
  for more information)
• Cost sharing documentation (see Module 5 for
  more information)
• Frequency and format specified in award terms and
  conditions

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Reporting Patent/invention

• Investigator is responsible for preparation and
  submission
• Frequency and format specified in award terms and
  conditions
• Work with ORSP Division of Technology Management
  if patents are involved

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Reporting Other

• Investigator is responsible for preparing and
  submitting
• Frequency and format specified in award terms and
  conditions
• Investigator is responsible for preparing and
  forwarding to ORSP if institutional signature is
  required

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Closeout
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Closeout

• What is closeout?
• Where can closeout instructions be found?
• What reports are typically included in closeout
  and who is responsible for submitting them?

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What is closeout?

• Closeout is the process that must be followed
  when a sponsored project ends to ensure that
  sponsor reporting requirements have been met

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Where can closeout instructions be found?

• OMB Circular A-110, Subpart D establishes general
  procedures for closeout of federal grants and
  cooperative agreements
• Agency-specific closeout instructions can be
  found in the award terms and conditions

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The closeout process

• Approximately 60 days before project end date,
  ORSP sends an email reminder to investigator
• The investigator should
• Ensure that all project costs have been
  appropriately charged
• Ensure that cost sharing is on track
• Review personnel on sponsored project and decide
  whether to transfer to another project or
  terminate
• Remind subrecipients of required reports, if
  applicable

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What reports are typically included in closeout?

• Federal grants and cooperative agreements
• Final technical report
• Final financial report
• Final patent report
• Due within 90 days from project end date

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What reports are typically included in closeout?

• Federal contracts
• Final technical report
• Final financial report
• Final patent report
• Final property report
• Contractors release form
• Generally due within 30-90 days from project end
  date

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Final technical report

• Sponsor requirements are usually defined in the
  award terms and conditions
• If an authorizing official signature is required,
  investigator should forward report to ORSP for
  VC/ORSP signature
• Investigator is responsible for submitting report
  to agency and sending a disk copy (CD) to ORSP
  along with documentation of date report was
  submitted to agency

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Final technical reportContent

• The investigator should follow agency
  instructions regarding the content and format of
  the final technical report. When required, the
  final technical report should generally contain
  brief information on each of the following
• A comparison of actual accomplishments with the
  goals and objectives established for the period,
  the findings of the investigator, or both.
  Whenever appropriate and the output of programs
  or projects can be readily quantified, such
  quantitative data should be related to cost data
  for computation of unit costs.
• Reasons why established goals were not met, if
  appropriate.
• Other pertinent information including, when
  appropriate, analysis and explanation of cost
  overruns or high unit costs.

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Final financial report

• Accounting prepares with assistance from the
  investigator
• Accounting usually submits to sponsor, but may
  work with investigator to submit if investigator
  signature is required and/or if financial report
  is to be submitted with technical report

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Final patent/invention report

• Investigator is responsible for preparing report
  and submitting to sponsor (with assistance from
  ORSP, if needed and/or from ORSP Division of
  Technology Management , if patents/inventions are
  involved)
• If an institutional signature is required,
  investigator should forward report to ORSP
• Please note that patents should be discussed
  with staff in the ORSP Division of Technology
  Management as early as possible, even at the
  proposal stage. Technology Management staff are
  available to assist faculty and other personnel
  in identifying proposed project activities that
  may potentially result in patentable inventions.
  This ensures that faculty are informed at the
  outset concerning what to do to protect the
  inventions that may arise from the sponsored
  project, and also ensures that appropriate
  language is included in the sponsored research
  agreement establishing the relationship between
  the university and the sponsor should an
  invention arise from the sponsored project.

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Other final reports

• Investigator is responsible for submission to
  sponsor and for sending a copy to ORSP
• If an institutional signature is required,
  investigator should forward report to ORSP

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Beyond closeout
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Beyond closeout

• Over/under-spent funds
• Project records

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Beyond closeoutOver/under-spent funds

• If a project has significant over-spending or
  under-spending, it reflects negatively on the
  university
• Remember, the budget is the financial expression
  of the project

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Beyond closeoutOver-spent funds

• Over-spent funds indicate
• Inadequate planning
• Inadequate financial management
• And the investigator/department pays

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Beyond closeoutOver-spent funds

• Costs charged to sponsored projects that cannot
  be collected from the sponsorfor reasons such as
  unallowability, unallocability, dispute with or
  bankruptcyby the sponsor, or other reasons, must
  be paid for with principal investigatoror
  departmental funds.
• UM Policy ADM.AC.100.900
• (Transfer of a deficit balance to another grant
  account is generally unallowable.)

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Beyond closeoutUnder-spent funds

• Under-spent funds indicate
• Inadequate planning
• Inadequate financial management
• Goals of the project not being met

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Beyond closeoutUnder-spent funds

• For cost-reimbursement awards, funds remaining at
  the end of the project must be returned to the
  sponsor
• For fixed price awards, funds remaining at the
  end of the project remain available to the
  investigator
• Remember, the budget is the financial expression
  of the project under-spent funds are an
  indication of inadequate planning and inadequate
  financial management

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Beyond closeoutProject records

• Records retention requirements
• Exceptions to records retention requirements
• Other requirements
• Who is responsible for retaining what?

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Beyond closeoutRecords retention
requirements-federal

• Financial records, supporting documents,
  statistical records, and all other records
  pertinent to an award shall be retained for a
  period of three years from the date of submission
  of the final expenditure report or, for awards
  that are renewed quarterly or annually, from the
  date of submission of the quarterly or annual
  financial report.
• OMB Circular A-110, Subpart C Post-Award
  Requirements

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Beyond closeoutExceptions to records retention
requirements

• If any litigation, claim, or audit is started
  before the expiration of the three-year period,
  the records shall be retained until all
  litigation, claims, or audit findings involving
  the records have been resolved and final action
  taken
• Records for real property and equipment acquired
  with federal funds shall be retained for three
  years after final disposition
• When records are transferred to or maintained by
  the federal awarding agency, the three-year
  retention period is not applicable to the
  recipient

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Beyond closeoutOther requirements

• Health Insurance Portability and Accounta-bility
  (HIPAA) documentation should be retained for six
  years from the date of its creation or the date
  when it was last in effect, whichever is later
• Select agent regulations require the retention of
  administrative as well as scientific data for
  three years
• and

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Beyond closeoutMore requirements

• Export control regulations require that all
  records required to be kept by the EAR must be
  retained for five years from the latest of the
  following
• The export from the U.S. of the item involved in
  the transaction, or
• Any known re-export, transshipment, or diversion
  of such item
• and

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Beyond closeoutMore requirements

• For projects involving patent applications, lab
  notebooks and supporting information related to
  the patent should be retained for the life of the
  patent (20 years)
• Misconduct records should be retained for seven
  years

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Who is responsible for retaining what records?

• The Investigator is responsible for retaining and
  disposing of all project data and materials as
  specified in the applicable regulations
• Accounting is responsible for retaining and
  disposing of all project financial records as
  specified in the applicable regulations
• The ORSP is responsible for retaining and
  disposing of all award records as specified in
  the applicable regulations

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Resources

• Post-Award Resource Guide for Principal
  Investigators
• http//www.olemiss.edu/depts/research/toolbox/inde
  x.html
• ORSP Subaward Policies and Procedures
• http//www.olemiss.edu/depts/research/office/polic
  ies/index.html
• Subaward Checklist Primary and Supporting Roles
• http//www.olemiss.edu/depts/research/forms/index.
  html
• Request to Issue Subcontract or Subcontract
  Modification under an Externally Funded Program
  form
• http//www.olemiss.edu/depts/research/forms/index.
  html
• Office of Research and Sponsored Programs x7482