VSU SPONSORED PROJECT AWARD REVIEW

Please retain this information for future reference!

Project Title:
Principal Investigator/Project Director: / Dept:
E-mail: / Phone:
Sponsor: / Program: / Award No:
If Federal Funds, Originating Agency: / CFDA No:
181
Program Officer: / Phone: / E-mail:
GAdmin/ContrOfficer: / Phone: / E-mail:
Project Period: / Current Budget Period:
Total Project Budget: / Amount Funded This Action:
Type of Agreement: Grant Coop Agrmnt Contract Subaward Other
Type of Payment: Cost Reimbursement Fee for Service
Fixed Price for Deliverables Fixed Price per Schedule
  1. APPROVED BUDGET (First Budget Period): or See attached

Budget Category

/ Sponsor / Cost Share /

Total

Personnel
Fringe Benefits
Travel
Supplies
Subaward(s)
Other Contractual
Participant Support Costs
Other
Total Direct Costs
F&A (Indirect Costs)
Total Project Cost
  1. PERSONNEL COMPENSATION FROM SPONSORED PROJECT:

Name / Period of Time / %Time or Mos. / Amount*

3.PERSONNEL COMMITTED AS COST SHARE:

Name/Title / Period of Time / Percent / Amount
  1. OTHER NON-VSU COMMITTED COST SHARE:

Description / Source / Amount/Value
  1. REPORT DUE DATES

Interim Technical Reports: / Final Technical Report:
Interim Financial Reports: / Final Financial Report:
Inventions/IP Report: / Equipment Report:
Other:
6. Publication Restrictions? / No / Yes
Describe:
7.Award Acknowledgement Required? / No / Yes
Describe:
8.Other Requirements:

GENERAL RESPONSIBILITIES OF THE PRINCIPAL INVESTIGATOR/PROJECT DIRECTOR

The Principal Investigator/Project Director is responsible for:

  • Reading sponsor policies and guidelines and terms and conditions of the award and adhering to these, as well as VSU policies and procedures.
  • Programmatic management of the sponsored project to meet project goals and objectives
  • Financial management of the project and, as requested, providing information to the Restricted Funds Accountant who will assist with accounting procedures and will prepare all invoices and financial reports.
  • Ensuring that all project expenditures are directly related to the project and necessary to meet project goals and objectives.
  • Ensuring that cost share commitments, if any, are met, and that appropriate documentation of non-personnel cost share is timely provided to the Restricted Funds Accountant.
  • Confirming personnel effort to be paid by the sponsored project or cost shared prior to the commencement of work so that payroll can be distributed appropriately before personnel expenses are incurred.
  • Notifying OSPRA and the Restricted Funds Accountant of any change in time to be devoted to the sponsored project by any individual that equals or exceeds 5% of the individual’s time prior to implementation of the change so that the payroll distribution can be adjusted before additional expenses are incurred.
  • Timely certifying his/her own effort; ensuring that all personnel paid from the project or cost sharing on the project are included in the university’s effort certification program; and, when personnel are unavailable to certify their own effort, timely certify effort for these individuals.
  • Disclosing possible conflicts of interest that exists at the time of proposal submission or award or that develop during the course of the project as soon as it is apparent.
  • Ensuring that all VSU policies for the responsible conduct of research (including protection of human research participants and animal care and use and required training) are followed.
  • Timely disclosing the development of intellectual property related to the sponsored project in accordance with VSU’s policy and procedures.
  • Timely completing and submitting all non-financial reports and project deliverables required by the agreement/contract.

GENERAL GUIDELINES FOR PROJECT MANAGEMENT

Research/Sponsored Project Non-Financial Compliance Training/Disclosure Requirements

1.Financial Conflict of Interest (FCOI): The Principal Investigator/Project Director (PI/PD), Co-PI/PDs, Key Personnel, and other individuals who perform tasks on a sponsored program who potentially could be influenced by a conflict of interest in the production of project outcomes or deliverables must receive conflict of interest training and submit a Significant Financial Interest Disclosure Statement in accordance with VSU’s Financial Conflict of Interest Policy and Procedures for Sponsored Programs. Such training and disclosure is required at the following times:

  • Prior to submission of the first sponsored program proposal or prior to engagement in a sponsored program if the award is not the result of a formal proposal;
  • Within seven (7) days of engaging for the first time in an ongoing sponsored program activity;
  • Annually thereafter, on a calendar year basis (on or before each January 31), as long as the Investigator remains engaged in any VSU sponsored program activity; and
  • Within thirty (30) days of discovering or acquiring (e.g., through purchase, marriage, inheritance) a new significant financial interest (SFI).

If the PI/PD assigns individuals to work on the sponsored project who are covered under the conflict of interest policy and procedures, whether or not they are compensated by the project, it is the PI/PD’s responsibility to ensure that these individuals either have met training and disclosure requirements or do so within seven (7) days of first engagement in the sponsored program activity.

2.NSF Awards - Responsible Conduct of Research Training Requirement: TheNationalScienceFoundation (NSF)requiresuniversities to ensure training and oversight in the responsible conductofresearch (RCR) for undergraduates, graduatestudents, and postdoctoralresearcherssupported byNSF funds. Responsibilityfor compliancewith theNSF RCR training mandaterests with the PI/PD, who must:

  • Within the first week of employment, inform OSPRA of the identity of undergraduates,graduatestudents, andpost-doctoral associates and
  • Ensure these individuals complete RCR training within sixty(60)daysof employment

Award Administration

1.Project Start and End Dates: Expenditures for the project must occur during the grant period. Unless 90-day pre-award cost are allowed under expanded authorities or approved in writing by the sponsor (please consult with the Office of Sponsored Programs & Research Administration about this possibility), expenditures should not be charged before the beginning date of the award. Likewise, costs should not be charged to the project after the end date of the award. A request for a “no-cost extension” of the project end date must be executed at least thirty (30) days before the end date of the award and approved by the sponsor(or granted by the Office of Sponsored Programs & Research Administration under expanded authorities) before Financial Services will extend the date of the award. No-cost extensions must be justified based on progress on the project and cannot be used merely to “spend out” the sponsored project account.

2.Authorized Official: The “Authorized Institutional Official” is the President of VSU or his designee.

3.Signature Authority: The signature of the Principal Investigator/Project Director (PI/PD) must be on all expenditures requests. If the PI/PD is being reimbursed, his/her supervisor should sign the reimbursement forms. If the PI/PD is unable to sign due to extended absence, he/she must designate someone to sign on his/her behalf. A memo or email must be sent to the Restricted Funds Accountant to designate someone else as the signature authority.

4.Expenditures and Grant Budget: Expenditures billed to the sponsored project should be in accordance with the budget approved by the awarding agency or amended in accordance with sponsor requirements. All costs charged to the sponsored project must be allowable, allocable, reasonable, and correctly classified.

Expenditures on federal grants and contracts must be in compliance with Section J of OMB Circular A-21, Cost Principles for Educational Institutions, available at Entertainment, food (unless approved in the award), alcoholic beverages, and gratuities are not allowable costs and cannot be charged to a grant. Costs that are classified by the institution as Facilities & Administration (F&A or “indirect”) costs cannot be charged to federal grants as direct costs. Costs that are not allowable on a federal grant (such as entertainment costs) are likewise unallowable as cost share.

Allowability of costs on grants and contracts from non-federal sources, which are considered state funds upon receipt, closely parallels the federal regulations. Non-routine expenditures should be discussed with the Restricted Funds Accountant prior to being made to ensure allowability and appropriate classification.

The PI/PD should maintain adequate records identifying all expenditures. An example of how to track expenditures can be found at:

The PI/PD is responsible for ensuring that sufficient budget authority is available to cover expenditures. If the sponsored project account goes into deficit, the overrun will be charged to the PI/PD’s indirect account, if applicable, or to the PI/PD’s department.

Advance approval from the funding agency may be required for deviations from the approved budget. Generally, federal research agencies give the PI/PD substantial flexibility. Federal awards for educational and social programs and awards from non-federal sponsors may have specific restrictions on rebudgeting and/or require sponsor approval before the expenditure necessitating the rebudgeting is made. Rebudgeting and use of funds are either described in the award document or in the regulations that govern the award. The Project Director should review the budget and send an email to the Restricted Funds Accountant if a change in the budget is needed.If allowable by the agency, the Accountant will make the adjustment. Covering the budget ahead of time will expedite reimbursements and speed up the month end accounting processes (purchasing card and payroll).

Any changes in personnel assignment (new and departing employees or change in level of effort of any employee on a sponsored project) should be promptly reported to the Restricted Funds Accountant so that, if necessary, sufficient funds can be rebudgeted for the personnel change and/or payroll can be redistributed to reflect actual personnel assignments. In order to ensure accurate data for effort certification (see below) these changes must be communicated before they are implemented.

5.Certifying Personnel Effort: Effort that is compensated by sponsored project funds or that is formally committed as cost share on a sponsored project must be certified. Time cards for hourly employees are considered certified when the employee submits them. For salaried personnel, including faculty/ administrative/professional staff, and graduate assistants, effort forms are generated from payroll records by OSPRA. Employees are asked to certify their own effort. The PI/PD may certify effort for an individual who worked on the sponsored project if that person is not available to certify his/her own effort. Effort reporting, which is required by the federal government, is done on a semester basis.

6.Equipment: The federal equipment threshold is $5,000 per unit cost; VSU’s threshold is $3,000. Items costing between $3,000 and $4,999 will be budget as supplies/materials in the sponsor budget but will be booked as equipment purchases in the VSU accounting system. No indirect costs can be charged to any equipment

costing less than $5,000 per unit, regardless of the internal classification of the direct cost. Items less than $3,000, regardless of anticipated useful life, are considered supplies. If equipment was not originally budgeted, sponsor approval may be required before it can be purchased.

7.Sub-Recipient of Federal Funds/Sub-Awards: If VSU is the subrecipient of federal funds, all restrictions and requirements contained within the original award to the prime awardee flow down to VSU. If VSU is subawarding funds to another entity, OSPRA will prepare the subaward document.

8.Documenting Cost Sharing: The PI/PD must maintain records of any non-personnel transactions that are cost share contributions indicated on the approved budget or committed in the proposal narrative. The PI/PD must provide this documentation to the Restricted Funds Accountant for financial reporting. Contributions of in-kind goods or services must be documented in accordance with federal regulations.

9.Fiscal Year End: If the grant ends on June 30th, the Project Director MUST follow the VSU year-end financial deadlines, with the exception of PCard purchases which may be made through June 26th. NO OTHER EXCEPTIONS will be allowed because of financial year-end reporting required by state auditors. The Restricted Funds Accountant will send a reminder email to all Project Directors who have grants ending June 30th.

10.Facilities & Administration (F&A or “Indirect”) Revenue: F&A costs recovered will be distributed as follows:

  • 35% to PI/PD
  • 35% to OSPRA
  • 15% to PI/PD’s Department Head
  • 15% to PI/PD’s College Dean

An alternate distribution for collaborative projects that involve co-PI/PDs or cross departments and/or colleges may be requested during the proposal submission process.

F&A is earned as grant expenditures are charged. The Restricted Funds Accountant will send an email to the PI/PD each month stating the amount of F&A earned. Unless the PI/PD responds otherwise, the funds will be budgeted to “operating.” F&A funds do not expire and can be carried forward for use in supporting research and other institutional activities of the PI/PD. The PI/PD must provide an annual memo each year regarding the intended use of these funds in the coming year (required reporting to the BOR by Financial Services).

11.Reporting Dates and Requirements: Completion and timely submission of technical/project reports are the responsibility of the PI/PD. The Restricted Funds Accountant in Financial Services will prepare all financial reports required by sponsors, with input from the PI/PD as applicable about deliverables met or services provided.

12.Records Retention: All project records must be retained for seven (7) years after the ending date of the project or the resolution of audit.

SPONSORED PROJECT FINANCIAL MANAGEMENT

Rules of Thumb for Sponsored Program Financial Management:

With the exception of PCard transactions, proposed sponsored project transactions will require some type of pre-approval with at least two signatures. Failure to follow institutional business processes in obtaining appropriate pre-approvals can result in unwanted institutional liability, unauthorized procurements, unnecessary and sometimes suspect after-the-fact reallocation of charges, significant audit exposure, and revocation of employee privileges. Do not make promises or allow individuals to begin grant/contract work or travel or to procure equipment or goods or services until required pre-approvals have been obtained.

If, during the course of a project, it becomes apparent that major modifications to the scope of the project or to the budget may be required (e.g., extended absence of the PI/PD; significant change in level of effort of key personnel; need to retain an external entity to assist in completing the project; need for a time extension to accomplish project objectives; etc.), the PI/PD should consult with OSPRA. Such project or budget modifications may require sponsor pre-approval as well as internal review and pre-approval to ensure allowability and use of appropriate business processes.

Following are some of the more common financial transactions that may be required on a sponsored project. This document is intended to provide guidance to Principal Investigators/Project Directors in negotiating VSU’s business processes. Because these processes are fluid, the PI/PD should direct any questions to the responsible business unit. This list is not exhaustive. The Office of Sponsored Programs & Research Administration and the Restricted Funds Accountant may be consulted at any time regarding non-routine sponsored project financial management issues.

  • Subawards: If the sponsored project includes plans for subawarding of funds to another entity, the transaction will be initiated by the Office of Sponsored Programs & Research Administration. The PI/PD must submit a request to Purchasing (and update it annually as appropriate) to encumber the subaward funds in the project budget. The subawardee may not begin work on the project until OSPRA has either issued a subaward document or a letter of intent to subaward to the subawardee entity. OSPRA will issue annualamendments to subawards, with the PI/PD requesting encumbrance of additional subaward amounts.
  • Grant-Paid Faculty Course Release: If the approved sponsored project plan includes a course release, consult with your Department Head to confirm timing of the release. When the course release is confirmed, follow the instructions for “Grant-Paid Release Time” below. Note that the Department Head is responsible for hiring and compensating a part-time adjunct instructor to cover the released course with departmental funds. The cost of the adjunct instructor cannot be charged to the sponsored project.
  • Grant-Paid Release Time: If the sponsored project will pay a portion of an individual’s academic or calendar year salary (which may or may not include a course release), the individual’s employing department must submit a position change request in the People Admin System. If HR requires a paper form for the position change, the form must be signed by the individual and/or the Principal Investigator/Project Director (PI/PD) and the individual’s Department Head/Unit Director, and sent to Human Resources & Employee Development for processing. The PFR (paper and/or electronic) should be completed before work to be paid by the grant/contract begins.
  • Cost-Shared Time: If the institution has formally committed a portion of an individual’s time as cost-share (contributed effort not compensated by the sponsored project), which may or may not include a course release, the Restricted Funds Accountant will complete a payroll distribution form to move a portion of the individual’s regular departmental pay to a cost-share account that is linked to the sponsored project account. This form will be provided before the cost-shared effort commences. Signatures of the individual contributing cost-shared effort, the PI/PD, and/or the individual’s Department Head/Unit Director are required. The form should be returned to the Restricted Funds Accountant.
  • Faculty Summer Compensation: In late Spring semester, faculty scheduled to receive summer compensation from sponsored projects will receive a request from the Office of Sponsored Programs & Research Administration (OSPRA) to reconfirm their intent to work on the sponsored project during the summer. OSPRA will ensure that these faculty are added to the summer roster. No other paperwork is required.
  • Faculty Extra Compensation: Any extra compensation proposed for faculty on sponsored projects must meet Board of Regents requirements and, if federally funded, must meet the allowability requirements of OMB Circular A-21, including prior approval of the sponsor (preferably in the initial approved budget).