Research Manual for Uptown Investigators

 

GENERAL PRINCIPLES OF POST AWARD ADMINISTRATION

 

Project Monitoring and Oversight

Acceptance of an award imposes an obligation on both the PI and Tulane to conduct the research and use the funds for the purposes set forth in the application, in accordance with applicable cost principles. Tulane also assumes responsibility for fiscal and administrative management of the project. The PI, as designated project director, is responsible and accountable for the proper conduct of the project, including the scientific performance and the submission of required technical reports. Tulane is legally responsible and accountable to the agency for the financial aspects of the supported activity and relies on the PI to spend in accordance with the approved budget.

Tulane's responsibilities also include monitoring expenditures, approving re-budgets and no-cost extensions, and ensuring that cost sharing is completed and documented in the accounting records. Unauthorized expenditures or unapproved changes in the budget can result in penalties against the institution and the loss of further research money for the PI. An awarding agency reserves the right to audit a project at any time while it is active and usually for up to three years after the completion of the project.

PIs receive a monthly statement from the Accounting Office that includes a report of cumulative expenditures and a detailed listing of current month expenditures. PIs may also obtain on-line access to the Financial Records System (FRS) in order to track grant expenditures in a timely manner; this system is particularly helpful at the end of a budget cycle when expenditures must be monitored as they occur. The Accounting Office can assist PIs or their designated assistants in accessing the FRS system. A PI or a designated assistant can contact Grants and Contracts Accounting if there are questions on financial status reports, or can attend one of the training sessions offered jointly by Grants and Contracts Accounting and the Office of Research. PIs should review their expenditure statements on a regular basis. Occasionally errors are made and incorrect charges may appear on the account. Such errors can be corrected, but should be done within ninety (90) days of the original transaction.

Prior Approvals

During the course of a project, it may become necessary to revise a budget or change significant aspects of the work to better meet the original objectives. Any changes to the original award concerning project start and end dates, budget variances, etc., must have prior written approval, whether from Tulane or the funding agency. A PI considering such an adjustment must consider what kind of changes the sponsor will allow, if the sponsor requires that such a change be approved in writing, and whether the sponsor or the University has the authority to approve. The terms and conditions of the award are the definitive source of answers to questions about changes, but a PI may also confer with the Office of Research.

To request such changes, file an Institutional Prior Approval Form with the Office of Research, which will secure the necessary approvals and submit the change to the appropriate offices for implementation. Amendments to the original budget must be documented in writing. Changes requested in writing using the Institutional Prior Approval Form must be made on a timely basis. If the change does not require agency approval, it is reviewed and approved by the Office of Research and sent to the PI, Grants and Contracts Accounting, and to the sponsor.

If the change requires approval by the sponsor, the PI must prepare a letter requesting the change, attach it to an Institutional Prior Approval Form, and send it to the Office of Research for review and signature. The request is then forwarded to the sponsoring agency. Sponsors will not approve requests sent directly from a PI unless evidence of institutional review is included. The Office of Research will notify the PI and the Office of Grants and Contracts Accounting once the documentation indicating sponsor approval is received.

Expanded Authorities

Expanded authorities give a recipient institution the responsibility for and the ability to approve certain changes in an award and eliminate the need for prior agency approval on certain aspects of grant administration. Expanded authorities apply only to grants and not to contracts. Included in expanded authorities is the right to incur pre-award costs up to ninety (90) days before the effective date of a grant, the right to extend the performance period for up to one year without additional funds, and the ability to carry forward balances from one budget period to the next. In return, recipient organizations are required to have systems sufficient to monitor and track such changes.

An Institutional Prior Approval Form is used to request such a change. The Office of Research reviews the request and, when approved, notifies the agency in writing. A PI must ensure adequate completion of the original scope of work within the funds available. Any request must include supporting reasons for the change. A one-time no-cost extension may not be granted merely for the purpose of using an unliquidated grant balance.

Federal Agency Oversight

Federal grant awards follow consistent administrative patterns; under expanded authorities, universities can now approve certain changes internally. Contracts are generally more restrictive, however. Prior to making any change in an approved contract, agency approval must be obtained.

The following actions always require approval by the federal sponsor:

  • Changes in the scope or objectives of the project.
  • Absence of the PI for more than three months, or a reduction of 25% or more in effort devoted to the project.
  • Change in key personnel, as specified in the application or award.
  • The transfer of funds allotted for training allowances (direct payment to trainees) to other categories of expense.
  • A subcontract or the contracting out of any work under an award, unless described in the application and approved in the award.

The following changes in grants are more likely to fall under Tulane authority. Consult the Office of Research for the terms and conditions of the award prior to making such a change:

  • Pre-award spending
  • Rebudgeting of funds
  • The purchase of equipment not identified in the award
  • Carry-over of funds
  • No-cost extensions

Non-Federal Agency Oversight

It is difficult to generalize about non-federal awards because sponsor regulations can vary widely. Depending on the level of detail provided in the terms and conditions of an award, the Office of Research will likely need to contact the sponsor prior to making changes in the project or budget.

Account Oversight

In order to ensure consistency and compliance with regulations, the Office of Research reviews and approves the following charges to sponsored research accounts:

  • Payroll Action Forms (PAFs)
  • Purchase Orders for Equipment
  • Subcontract Invoices

The Office of Grants and Contracts Accounting also reviews expenditures on accounts as they are processed through the system, and is responsible for monitoring and approving all travel expenses, supplies, equipment, and Interdepartmental Transfers (ITs) associated with grant/contract accounts. This oversight ensures that expenditures comply with federal regulations or sponsor guidelines. If a question by Grants and Contracts Accounting staff arises regarding whether an expenditure is allowable on an account, contact the Office of Research for further explanation and/or clarification.

General Guidelines on Changes

No-cost extensions

Federal regulations provide criteria for approving a one-time extension of up to twelve months. An extension may be approved unless one or more of the following conditions apply:

  • The terms and conditions of the award prohibit the extension.
  • The extension requires additional federal funds.
  • The extension involves any change in the approved objectives or scope of the project.

An extension of more than twelve months requires agency approval. Also, if an initial request of less than twelve months has been previously approved by the University, any subsequent request for an additional extension requires agency approval. Some federal agencies have adopted more restrictive policies in granting no-cost extensions. Check with the Office of Research for information about specific agencies.

To obtain a no-cost extension, a PI must prepare an Institutional Prior Approval Form along with a letter describing the need for the additional period of time to complete the project objectives. The letter should address programmatic issues and justifiable delays. The fact that money remains in the account is not sufficient reason for an extension. If sponsor approval is required, a letter addressed to the grants officer at the agency, along with an Institutional Prior Approval Form, should be sent to the Office of Research, which will forward both to the agency. The agency will not act on requests which have not been signed by the institution.

Because federal agencies require receipt of such requests in advance of the grant expiration date, requests should be processed forty-five (45) days prior to expiration. If the University has the authority to approve the no-cost extension, the request can be made to the Office of Research thirty (30) days before expiration of the grant, allowing time for the Office to notify the funding agency that an extension has been approved. Non-federal sponsors generally reserve the right to approve no-cost extensions.

Expenditures obligated and incurred after the project end-date are not allowable. In addition, purchases made toward the end of the grant/contract period which could be construed as being of no use to the project in the remaining time of the project may be disallowed by the granting agency.

Budget Revisions

Sponsor guidelines for modifying an approved budget vary widely, and may even vary within a single agency from program to program. Consult the terms and conditions of the award to determine in which categories and/or at what level of spending the sponsor retains the authority to approve changes. In addition, when rebudgeting funds, consider the impact on indirect (F&A) costs.

Equipment Changes

If equipment was not requested or approved in the award document, it may be requested by using the Institutional Prior Approval Form. Indicate the desired equipment along with a detailed justification of its necessity to the project. Also indicate how award funds will be rebudgeted to purchase the requested equipment.

If equipment was approved in the award document but the acquisition cost of a certain piece of equipment is higher than indicated in the budget, complete an Institutional Prior Approval Form to rebudget available funds to cover the cost increase. Include an explanation for the increased acquisition cost.

An Institutional Prior Approval Form is also required if an equipment item is purchased which differs from that approved in the award. Provide a justification as to why the alternate equipment is necessary to the project and why the original equipment approved in the award is no longer needed.

Transferring Grants or Contracts

Transfer of a Grant or Contract from Tulane

If a PI with an active award leaves Tulane, there are several options for handling the award, depending on the type of award, the sponsor's policies, the relationship of the project to Tulane, and the expectations of the PI's new institution.

One option is for the award to remain at Tulane with a substitute PI named. Another is the transfer of the award to the PI's new employer. Yet a third option would be for the project to remain at Tulane, with a portion of the work subcontracted to the PI's new institution; conversely, the award may be moved with the PI, and a portion of the original work subcontracted back to Tulane.

Any such process will involve discussions among the PI, the Office of Research, and the sponsor to determine the most effective way to continue the work. If an award is to be transferred to the PI's new institution, the remaining balance of funds must be identified and the Office of Research must prepare a form or letter to relinquish the project on a specified date. The project will be terminated at Tulane as of that date, and the sponsor will issue another award to the new institution. If a portion of the work will be subcontracted to the new institution, the budget must be revised to include a subcontract. A negotiation with the Office of Research regarding indirect (F&A) costs may be necessary since the addition of a subcontract may place a burden on the original budget. The subcontract and the new budget must be approved by the subcontract recipient and by the sponsor. Once approved, the subcontract will be issued by the Office of Research.

Any transfer requires the cooperation of the PI, the Office of Research, and Grants and Contracts Accounting. Outstanding commitments must be anticipated, payrolls estimated, and retroactive adjustments identified. There is no mechanism for moving funds at a later date if the funds to be transferred are either underestimated or overestimated.

Transfer of a Grant or Contract to Tulane

In the event a new member of the Tulane faculty wishes to transfer an existing award to Tulane, much of the process described above applies. The PI should contact the sponsored programs office at the current institution, which in turn will initiate contact with the Tulane Office of Research. A new budget will be developed and changes in indirect (F&A) costs adjusted. If the award is to be transferred in its entirety, the PI's previous employer must formally relinquish the award, and Tulane must submit a proposal to the sponsor. If only a portion of the work is to be transferred, a subcontract is the likely means of handling the transfer.

Transfer of Equipment

Title to equipment vests either in the sponsor or the recipient organization, but never in an individual PI. If the University has title, written permission must be secured from the appropriate Tulane chair and dean before the equipment can be released. If the sponsor owns the equipment, written approval must be secured before the equipment can leave Tulane. If a PI wishes to transfer equipment provided under a sponsored agreement, contact the Office of Research for assistance.

Close Out of a Grant or Contract

The Office of Research works in conjunction with Grants and Contracts Accounting to assist PIs with grant close-out. Approximately three months before an award is scheduled to end, the Office of Research notifies the PI of the expiration date. Options such as extending the award, applying for a continuation or a renewal, or closing out the account must be decided.

If the account is to be closed, a number of steps must be taken. Thoroughly review charges to the account for accuracy. All items charged should have been posted and appear in the account history. Use on-line access in this process. Correct any errors well in advance of the account end-date. Evaluate outstanding purchase orders and, if necessary, cancel them once the purchase is completed and the invoice has been paid. Assess the remaining anticipated expenditures to be charged to determine if a re-budgeting is necessary. Take steps to ensure that the account does not go into deficit and that all remaining funds are "obligated" before the grant or contract end-date. Review labor reports to identify all personnel paid from the account, and complete Payroll Action Forms (PAFs) to transfer all personnel to a new funding source or to terminate their employment prior to the end-date.

Upon project completion, the Office of Research or the Office of Grants and Contracts Accounting will review the specific reporting requirements and advise PIs of the requirements. It is routine for a sponsor to require a final Technical Report and a final Financial Status Report (FSR). Additional specialized reports may be required for equipment, cost sharing, or other circumstances. The final Technical Report is prepared by the PI and forwarded to the agency. One copy is sent to the Office of Research for archival purposes.

The FSR is prepared by Grants and Contracts Accounting and sent to the PI for approval. Outstanding items should be resolved as soon as possible so as not to delay the submission of the final FSR. Generally, an agency will require submission of all reports within ninety (90) days of termination. Failure to comply with the time frame can result in payment being withheld from the University and can jeopardize future funding from the sponsor, both for the PI and other Tulane faculty.


 
 
 
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