1100.00 Post-Award Administration
The process of managing sponsored research funds is a shared responsibility among the funder, the PI, the Office of University Business Services, the PI’s departmental accountant/business manager, and Office of Sponsored Programs with each entity responsible for areas under their purview. Federal grants are to be managed in accordance with Uniform Guidance, Subpart D, Post-Federal Award Requirements that stipulate that the Federal awarding agency must manage and administer the Federal award in a manner so as to ensure that Federal funding is expended as associated programs are implemented in full accordance with U.S. statutory and public policy requirements, including, but not limited to the following: protecting public welfare, the environment, and prohibiting discrimination. The Federal agency communicates to MSU all relevant public policy requirements, including those in general appropriations provisions. MSU is responsible for complying with all requirements of the Federal award, and Post Award Administration works closely with the PI to ensure these requirements are satisfactorily met.
1110.00 Responsibilities in Post-Award Administration
The PI assumes primary responsibility for accomplishing the technical goals of the project and for complying with the financial and administrative policies and regulations associated with the award. Although PIs may have administrative staff or graduate students to assist them with the management of project funds, the ultimate responsibility for the management of the sponsored research project activities and responsible expenditure of funds ultimately rests with the PI.
Office of Sponsored Programs Post-Award Responsibilities consist of the following;
- Primarily, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the award is managed in compliance with Federal statutes, regulations, and the terms and conditions of the award;
- Establish the fund/index in the University financial system;
- Advise PIs regarding Federal and sponsor guidelines and regulations;
- Facilitate good project management practices by disseminating information and providing training to PIs on a range of topics related to sponsored activities;
- Serve as the primary liaison between the PI and the sponsor in all areas requiring sponsor approval, including changes to scope, budget, key personnel, and project end dates;
- Maintain project files and records of the proposal and grants information system;
Additional administrative support to departments consist of the following:
- Management of 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 conducts follow-upon payments;
- Project financial reporting: Preparation and submittal of financial reporting to sponsors will be conducted by OSP as well as generation of monthly Inception to Date Report (ITD) for each project for PI review;
- Administer effort reporting in order to provide documentation for employee salary charges to Federal grants;
- Monitor and respond to, in conjunction with the department, incidents of overspending;
- Coordinate government, private sponsor, and public accounting firm audits;
- Develop and negotiate Federal facilities and administrative agreements;
- Monitor government property accounting inventory maintained by Property Management;
PI Post-Award Responsibilities consist of the following:
- 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 are consistent with the sponsor’s terms and conditions;
- Spend no more than the authorized amount for the project period(s);
- Carry out the financial plan as described in funded proposal;
- Notify OSP of any proposed changes in scope of work, changes in personnel including the PI or other key persons, the budget, or period of performance;
- Follow all applicable University policies and procedures such as travel, purchasing, employment, contracted services, and compensation for personnel;
- 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 reported by the department in a state of accuracy, completeness, and timeliness;
- Oversee the care and maintenance of property procured with project funds in accordance with sponsor guidelines;
- Report any intellectual property development that results from the project to the Technology Transfer Office (TTO) in accordance with Board of Regents Policies on Intellectual Property and MSU Patents and Copyrights Policies and Procedures;
- Prepare and submit periodic and final project progress reports in accordance with the terms of the award;
- Review project expenditures (including the monthly Project Financial Reports provided by OSP) to confirm that they are correct and appropriate;
- Comply with all sponsor and MSU rules, regulations, and terms and conditions of the award;
Departmental Accountant/Business Managers Post-Award Responsibilities consist of the following:
- Assist in administration of the award at the departmental level;
- Act as liaison between the PI and OSP;
- Have or acquire knowledge of MSU policies and procedures related to grant management, as well as the terms and conditions that apply to individual awards;
- Maintain budgetary control through departmental accounting systems, assuring that expenditures are in compliance with the approved budget;
- Provide assistance to the PI in reviewing expenditures to assure appropriateness and correctness;
- Monitor grant expenditures to assure that overspending does not occur;
1120.00 Paying Bills and Charging Expenses to Accounts
PIs or other authorized project personnel initiate expense charges to a sponsored project. Expenditures must be consistent with grant requirements and purchasing procedures. The Business Procedures Manual and the Procurement Policy and Procedures provide guidance on purchasing requirements and submitting bills for payments.
1130.00 Paying Salaries from Project Funds
To pay salaries from a project fund, the department (initiated by the PI) must complete and forward a Personnel Transaction Form (PTF) to Human Resources, Personnel and Payroll Services. Additional requirements apply and are detailed in the Employment and Compensation of Personnel Paid from a Grant or a Contract policy.
1140.00 Internal Institutional Charges
Certain internal University services (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. The charges must be reviewed by the PI for accuracy.
1150.00 Travel Charges
Travel reimbursement requests must be made to OSP no later than 10 days after the trip has been completed. PIs and their project personnel must also submit a Travel Authorization request if traveling out of state. Reimbursable travel expenses include only those incurred while traveling on official business. Please consult the Business Procedures Manual, Section 500.00 Travel, before travel arrangements are made.
1160.00 Cost Transfers
Generally, transfers of costs from one sponsored research account to another are not permitted except to correct errors, and even then, cost transfers are generally allowed within 90 days of charging the cost to a fund in Banner. Consult the Cost Transfer Policy for OSP Funds for more information.
Effort reporting is required by Federal regulations, OMB Circulars (for awards made prior to December 26, 2014) and Uniform Guidance, Section 200.328. Effort reporting is a method of documenting the 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 they receive pay or not, are subject to effort reporting. Federal 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 that the activity of an employee supports the compensation charged to Federal awards. All employees who perform work on the project must submit a monthly time and effort report to the OSP Time and Effort System. 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 accounting of their own effort and that of their staff. PIs are also responsible for complying with sponsor requirements for notifications regarding changes in personnel and effort and must ensure that commitments of effort to the project are met according to the timeline and guidelines of the sponsor. OSP provides training to PIs and their research staff on MSU’s process for effort reporting. 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, services, 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, 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.
1180.00 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.
1190.00 Budget Revision and Reallocation of Funds
PIs should begin by contacting OSP to determine whether or not budget revisions or reallocation of funds is authorized under the award and/or whether these actions require OPAS approval. Some sponsors do not allow revisions or allocations while some impose limits for changes (for example, some sponsors require prior approval for charges of more than 10%). The PI should assess the impacts of revision or reallocation to determine if there will be sufficient funds to complete the project activities or whether F&A fees will shift. If required by MSU or the sponsor, the OPAS form should be submitted as soon as the need for a change in the budget is recognized.