700.00 Post-Award Administration
The process of managing sponsored research funds is a shared responsibility among the PI, the Office of University Services, the department business manager/accountant, and OSP; each has unique areas of primary responsibility.
710.00 Responsibilities of the PI in Post-Award Administration. The PI has primary responsibility for accomplishing the technical goals of the project and complying with the financial and administrative policies and regulations associated with the award. Although PIs may have administrative staff to assist them with the management of project funds, the ultimate responsibility for the management of the sponsored research project work and funds rests with the PI. The fundamental responsibility of the PI during the performance of the research post-award is to:
- Execute the project as outlined in the funded proposal and the terms and conditions of the award, using sound management techniques
- Authorize only those expenditures that are reasonable and necessary to accomplish the project goals and that are consistent with the sponsor’s terms and conditions.
- Spend no more than the amount authorized by the sponsor for the project period.
- Carry out the project’s financial plan as presented in the funded proposal.
- Notify OSP of any proposed changes in: the scope of work, the PI or other key research personnel, the budget, or the period of performance.
- Follow all applicable University policies and procedures such as travel, purchasing, employment, contracted services, and compensation policies.
- Assure that cost-sharing or matching commitments are fulfilled and reported to OSP in a timely manner.
- Assure that Time and Effort Reports for the funded project are accurately, completely, and timely reported (monthly) by the department.
- Oversee the care and maintenance of property procured with project funds in accordance with sponsor guidelines.
- Report any intellectual property development which relates to the project to the Technology Transfer Office in accordance with Board of Regent http://mus.edu/borpol/bor400/bor400.asp and MSU Patents and Copyrights Policies and Procedures http://www2.montana.edu/policy/copyright_infringement/.
- Report project progress, including final reports as required by the terms of the award.
- Review project expenditures (including the monthly Project Financial Reports provided by OSP), regularly and in a timely fashion to assure they are correct and appropriate.
- Comply with all sponsor rules, regulations and terms and conditions of the award.
720.00 Role of Departmental Business Managers/Accountants in Post-Award Administration. The departmental business manager/accountant helps administer the award. They play a key role in the financial management of a project. At MSU, the departmental business manager/accountant often acts as a liaison between the PI and OSP. Although responsibilities vary by department, typically their responsibilities include:
- Having knowledge of and understanding MSU policies and procedures related to grant management, as well as the terms and conditions that apply to individual awards.
- Maintaining budgetary control through departmental accounting systems, assuring that expenditures comply with the approved budget.
- Assisting the PI in reviewing expenditures to assure appropriateness and correctness.
- Assisting the PI in all business aspects of grant management.
- Monitoring, along with OSP, grant expenditures to assure that overspending does not occur.
730.00 Role of OSP in Post-Award Administration. OSP acts as the primary administrative liaison between PI, sponsors, and other University offices. The primary responsibilities of OSP during the post-award phase of a sponsored research project include:
- Establishing the fund/index in the University financial system.
- Advising PIs regarding sponsor guidelines and regulations.
- Facilitating good project management techniques by disseminating information and providing training to PIs on a wide range of topics related to sponsored activities.
- Serving as the primary interface between the PI and the sponsor in all areas requiring sponsor prior approval, including changes to scope, budget, key personnel, and project end dates.
- Maintaining project files and records and the proposal and grants information system.
- Financial reporting to sponsors. OSP prepares the required financial reports that are sent to sponsors.
- Receivables, billings, and collections. OSP manages the collection of grant funds and maintains account records for each sponsor. OSP draws funds under federal letters of credit as costs are incurred, issues billings to sponsors and follows up with sponsors on payments as required by the terms of agreements.
- Project Financial Reports. OSP generates the monthly grant Inception to Date Report (ITD) for each sponsored project which is available for the PI’s review. OSP also provides training in the use of the ITD.
- For federal funds, OSP administers the effort reporting function that provides the required documentation for employee salary charges to federal grants.
- Monitors, along with departmental business manager/accountant, overspending.
- Coordinates government, private sponsor, and public accounting firm audits.
- Develops and negotiates federal facilities and administrative agreements.
- Monitors government property accounting inventory maintained by Property Management.
- Conducts space function and departmental administration surveys.
Additional information regarding OSP may be found on its website at http://www.montana.edu/wwwvr/osp/index.html.
740.00 Paying Bills and Charging Expenses to Accounts. Charging expenses to a sponsored project is initiated by the PIs or other person authorized to spend funds under the grant. Expenditure must be consistent with grant requirements and purchasing procedures. The Business Procedures Manual and the Purchasing Policy provide guidance on purchasing requirements and submitting bills for payments.
Expenditures on sponsored project accounts must conform to the line item budgets included in the award and bills submitted for payment must have proper documentation (e.g., original invoices).
741.00 Paying Salaries from Project Funds. To pay salaries from a project fund, a Personnel Transaction Form (PTF) for the employee must be completed by the department and forwarded to HR/Personnel and Payroll for payment.
742.00 Internal Institutional Charges. Certain internal university services (e.g., motor pool, computer services, library loans, telephone charges, etc.) may be electronically billed to a departmental account and charged to a sponsored research account if the OSP fund/index number is provided to the internal departments. However, the charges must be reviewed by the PI for accuracy.
743.00 Travel Charges. Travel reimbursement requests must be made to OSP no later than 90 days after the travel took place; late requests will not be paid. See the travel section of the Business Procedures Manual.
744.00 Cost Transfers. Generally, transfers of costs from one sponsored research account to another are not allowed except to correct errors, and, even then, cost transfers are allowed only within 90 days of charging the cost to a fund in Banner. For more detailed information on cost transfers refer to the Cost Transfer Policy, OSP's info sheet on Cost Transfers, and Cost Transfers (90 day memo).
745.00 Time and Effort Reporting. Effort reporting is a method of documenting the work time devoted to an externally sponsored grant or contract and is expressed as a percentage of professional activity devoted to a particular fund. All individuals who devote effort to grants or contracts, whether or not they are paid, are subject to effort reporting. Effort reporting is required by Federal regulations (OMB Circular A-21) for all compensation/salary costs charged to federal grants and contracts. The regulations require MSU to have a system in place for certifying the allocation of salaries and wages associated with sponsored agreements. MSU employs after-the-fact certification to confirm and substantiate that the activity of an employee supports the compensation charged to federal awards. Each month a time and effort report http://www.montana.edu/wwwvr/grants/TEInstruct2010.doc] is submitted by all employees who perform won on the grant or contract. Each person must provide a reasonable estimate of the time actually spent working on the project. PIs are responsible for reviewing all time and effort reports to ensure accurate accountability of their own effort and the effort of their staff in a prompt and timely manner. Certifiers must have suitable means of verification regarding the effort expended on the activities they are certifying.
PIs are responsible for understanding and complying with sponsor requirements for notifications regarding changes in personnel and effort. The PI is responsible for ensuring commitments of effort to awards are met within the flexibility allowed in the sponsor's guidelines and in a timely manner. OSP provides training to PI’s on MSU’s process for effort reporting as well as on the PI’s role and obligations for effort reporting. This training is also available to other investigators and research staff.
When assessing percentage of activity expended on a sponsored project, total effort is defined as actual effort devoted to all the activities for which MSU compensates an employee for their appointment. For faculty, total effort includes instructional activities, administrative activities, public services, and clinical and research activities. The federal government guidelines acknowledge that, in an academic setting, teaching, research, service, and administration are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance is placed on estimates in which a degree of tolerance is appropriate. However, the percentage of compensation charged to a federal award during a reporting period can never exceed the percentage of total effort associated with the award.
746.00 Organizational Prior Approval System (OPAS). In an effort to streamline post-award administration of changes from the approved application or budget, many federal agencies have delegated authority to institutions to approve certain post-award changes. In exercising this authority, OPAS grantees must assure proper stewardship over these funds and that all costs charged to the awards are allowable, allocable and reasonable. OSP has OPAS Request Forms available for your use.
746.10 Budget Revision. PIs wishing to revise the budget in an award should review the sponsors requirements and if the proposed change exceeds the sponsors limits for changes (e.g., some sponsors require prior approval for changes of more than 10%), the PI must request approval by submission of the OPAS form. The OPAS form should be completed and submitted to OSP as soon as the need for change in budget is recognized. The MSU OPAS Committee will review the request, consider the specific sponsor restrictions, and submit its written decision.
746.20 Pre-Award Expenditures. Most federal grants permit the incurrence of pre-award costs, and MSU permits per award expenditures which conform to MSU’s Cost Transfer Policy. MSU’s OPAS Committee is authorized to approve such pre-award spending. If the PI needs to commit funds or order equipment within the ninety (90) days preceding the award start date, a request for pre-award spending may be submitted to OSP. Upon verification of the expected award, and approval by the OPAS Committee, an Office of Sponsored Programs index/fund number will be assigned. However, if funding is not ultimately available, the PI and Department will be responsible for all expenses posted to the grant.
746.30 One-Year, No-Cost Extension. The OPAS Committee may also grant a one-year, no-cost extension on most federally sponsored awards which allows for completion of programmatic commitments. To request an extension, the PI must submit an OPAS form or send an e-mail explaining why an extension is necessary. The request should be sent to the OSP Fiscal Manager thirty (30) days prior to the end date of the existing contract period.
746.40 Rebudgeting. Occasionally, a project's financial resources need to be reallocated due to the nature and progress of the research. For example a piece of equipment may become unnecessary, while another expense becomes necessary, or the scope of the project might change due to unforeseen circumstances. In these cases, rebudgeting may be required.
Rebudgeting will be allowed only to the extent the terms of the award or contract allow it. Therefore, before any attempt to rebudget, the PI should review the terms of the specific award. The PI should also assess the potential impacts of the proposed rebudgeting--e.g., shifting an expense from one budget category to another or shifting expenses from direct costs which may result in adjustment to the F&A cost collection. Rebudgeting to or from a restricted class (such as participant support or subcontract), may need OPAS or sponsor approval. PIs should contact OSP to determine whether the proposed rebudgeting is authorized under the award and whether it requires OPAS approval.
747.00 Principal Investigator Termination Checklist. If you are the PI on any current or ongoing awards and you are leaving employment at Montana State University you will need to take steps to address several issues.
747.10 Grant Closeout. If you are transferring to another institution and desiring to move grant/contracts(s) to the new institution you will need to contact your department head to initiate this discussion. Since the award is made to Montana State University, whether a transfer will be allowed is determined by the institution and sometimes in conjunction with the sponsoring agency. Once the transfer has been approved by the department head, then contact the Office of Sponsored Programs to identify the specific transfer requirements for your project’s sponsor. Most frequently on federal awards a final financial report will need to be submitted that reflects the unexpended balance that could be moved to your new institution. Please work with your department accountant and OSP Fiscal Manager to finalize this balance.
If the grant/contract is to remain at Montana State University, a new PI must be identified and the sponsoring agency must approve this person. Typically this is accomplished with a letter requesting the change and a copy of the new PI’s vitae. A signature from the authorized representative for MSU may be required, depending on the sponsoring agency requirements.
747.20 Equipment. If you are transferring to a new institution you may want to request transfer of any equipment purchased with grant funding during your employment at MSU. In order to initiate this process you must prepare a listing to be presented to your department head for approval. Any release of equipment will be at the discretion of the department head. A copy of the approved list will need to be supplied to the Property Management Office so that accurate inventory records can be maintained and the MSU property control tags get removed. For government owned equipment, the underlying grant/contract document will provide the disposition instructions to follow.
747.30 Final Reports and Deliverables. As the PI on a grant/contract it is your responsibility to ensure that the final technical report and any other deliverables as required under the contract documents are delivered to the sponsor within the allowable time frame and prior to your departure from MSU.
747.40 Facilities and Administrative (F & A) Fund Balances. Once PI terminates from their position at the university any unexpended funds in the PI F & A return fund will revert to the Vice President for Research. IF there are ongoing obligations it will be the responsibility of the department to request retention of these funds by supplying an outline of how the funds are to be utilized. The decision to release these funds to the department will be made at the Vice President for Research level.
748.00 Program Income. Program Income is defined in OMB Circular A110 as “Gross income earned by the University that is directly generated by a sponsored activity or earned as a result of an award.” Examples include:
- Fees for services, such as laboratory tests
- Receipts from the sale, use or rental of equipment purchased with project funds
- Royalties from patents and copyrights
MSU may be required to credit program income to the grant, and, therefore, OSP should always be consulted for advice if any income is generated by work under a grant.
749.00 Closing a Sponsored Research Account. Federal agencies and many other sponsors require that projects be closed within 90 days of the termination date of the award. In fact, new awards may be denied if existing awards are not properly closed.
OSP is responsible for closing grants, awards, and contracts and will do so when the following conditions are met:
- The project must be complete by the contractual completion date.
- All reports are complete and filed.
- Any cost-sharing commitments must have been met and are documented.
- Except for fixed price contracts, the total expenditures in the index/fund must match total income in the index/fund. Any excess funds must be returned to the sponsor and any account deficiencies will not be paid by sponsors; however, fixed-price contracts may be an exception to this requirement.
Once the project has been properly closed, the index/fund is inactivated from use and is archived.