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Home >> Sponsored Research >> The Principal Investigator's Guide to Sponsored Projects >> Post Award Management

Post Award Management

Purpose

The Office of Contracts and Grants Post-Award team comprises Contract and Grant Administrators, Subcontract Administrators, Property Managers, and Data Specialists dedicated to helping Principal Investigators negotiate the terms and conditions of contracts and grants and to manage their projects in compliance with Federal, State, University, and Sponsor regulations.

Responsibilities

These are the responsibilities necessary to establish a good working relationship among Principal Investigators, Department Staff Members, Sponsored Projects Accounting, and OCG to ensure compliant and successful project implementation.

Principal Investigator (and their departments)

    • Submit all binding agreements to OCG for review, negotiation, and signature
    • Implement the Scope of Work in accordance with the terms of the award
    • Comply with all University, State, Federal, and Sponsor rules and regulations
    • Adhere to all requirements for human subjects, animal care, hazardous materials, biosafety, etc.
    • Hire and Supervise project personnel
    • Approve effort reports
    • Manage project budgets
    • Authorize, approve, and document project expenditures
    • Authorize, approve, and document cost sharing expenditures
    • Manage subcontractors and approve subcontract expenses
    • Secure appropriate internal and external approvals for any changes to the award agreement
    • Notify and coordinate with OCG and SPA on any external audits or site visits
    • Prepare technical reports and other deliverables
    • Work with SPA to submit interim and final financial reports
    • Work with OCG to submit interim and final property and invention reports

Sponsored Projects Accounting

    • Review the award document to ensure that the budget is set up correctly in the University's accounting system and that invoice and other financial requirements are well understood by all responsible parties
    • Manage the financial aspects of awards after they are received, including financial reporting, billing, and closeout
    • Ensure that expenditures are incurred in accordance with the project budget and sponsor guidelines
    • Administer the Personal Effort Reporting System (EPERS)
    • Maintain systems to ensure compliance with University, State, Federal, and Sponsor rules and regulations
    • Consult/advise/train/assist with the financial administration of projects,
    • Provide general financial accounting for funds 30 and 31, and
    • Coordinate, with OCG, internal and external audits and project reviews

Office of Contracts and Grants

Establish pending accounts (OPAS and At-Risk)

Review and negotiate, when necessary, all binding grants, agreements, and contracts

Interpret University and Sponsor policies and procedures, State and Federal rules and regulations for the Principal Investigators and their departments

Authorize the establishment of permanent accounts

Assist with project planning and start-up

Prepare, negotiate, and monitor subcontracts and sub-recipient agreements

Provide administrative oversight during the life of the project, including property and travel

Review, approve, document, and process all changes to the award agreement during the life of the project, including budget revisions and deviations, key personnel changes, no cost extensions, and other actions requiring University and/or Sponsor approval

Coordinate the resolution of all administrative, financial, and legal problems effecting project implementation

Assemble interim and final property and invention reports

Coordinate project closeout

Coordinate, with SPA, internal and external audits and project reviews

Serve as the authorized administrative contact with the sponsor during the life of the project

Provide training and educational opportunities to PI's and departmental staff members

Maintain data bases and reports on proposals, awards, expenditures (with SPA), and F&A cost recovery (with SPA)

Post-Award Policies and Procedures

Definition of Sponsored Projects (versus Auxiliary or Gift Accounts)

The proposal responds to a formal RFA, RFP, or other formal solicitation and the project is initiated by notice of award.

The Statement of Work specifies programmatic objectives to be accomplished within a delimited period of time and budget.

These awards require deliverables or detailed technical reports.

These awards require separate accounting procedures and detailed financial reports.

These awards include provisions for audit by the sponsor.

These awards involve the disposition of property, whether tangible or intangible, that may result from the project.

These awards require regulatory oversight in areas such as animal care, human subjects, bio-safety, or financial conflict of interest.

Gifts

    Gifts are donations provided with few or no conditions specified in the award document.

Auxiliary Enterprises

    Auxiliary accounts are established to manage funds received from non research related activities, such as laboratory or testing services, Alumni activities, or student services.

See APS Sponsored Project Revenues at:

https://www.cusys.edu/policies/Fiscal/Rev_Sponsored-Project-Revenue.pdf

Sponsored Projects versus Personal Services Agreements

Grants, Cooperative Agreements, and Contracts

Grants

    Governed by the Grant and Cooperative Agreement Act of 1977

    The purpose is to transfer money, property, services, or anything of value to a recipient in order to accomplish a public purpose.

    Grants are implemented independently from the Sponsor.

    Grants are often called "assistance mechanisms".

    Grants are "exchange like" agreements.

Cooperative Agreements

    Governed by the Grant and Cooperative Agreement Act of 1977

    The purpose is to transfer funds to a recipient to accomplish a public purpose.

    Cooperative Agreements are implemented with the "Substantial Involvement" of the Sponsor.

    Cooperative Agreements are considered "assistance mechanisms".

    Cooperative Agreements are "exchange like" agreements.

Contracts

Federal Contracts:

Governed by the Federal Acquisition Regulations (FAR)

    The principal purpose is to acquire property or services for the direct benefit or use of the Government.

    The Government determines that a procurement contract is appropriate and prepares the SOW.

    Contracts are often called "procurement mechanisms".

    Contracts are "exchange agreements".

Industry Contracts:

Negotiation with industry is particularly complicated because of their different culture, goals, and business practices. The following are important points to be raised in the very beginning of contract discussions with industry.

  • The University must be able to publish research results first generated under the agreement;
  • Retain ownership of Intellectual Property developed by its employees;
  • Comply with the Colorado Open Records Act (CORA).
  • The University cannot enter into exclusive or non-compete agreements if such agreements will prohibit students, post-docs, or junior faculty members to from disclosing the results of their efforts or restrict their freedom to seek research funding or employment;
  • indemnify other parties;
  • Accept binding arbitration;
  • Agree to conduct business under the laws of another political entity or to litigate in courts outside the State of Colorado;
  • Add sponsors as "additional insures" to its insurance policies.

A contract establishes a legal relationship between two parties, such as a buyer and seller that is defined by an agreement that makes a promise and creates an obligation. A written contract will memorialize the agreements made between the parties about their respective rights and responsibilities.

BEWARE, contracts can be more problematic.

They are:

  • More difficult to negotiate -- They must be negotiated within state law, University policy, and project needs.
  • More difficult to administer -- They are governed by specific terms and conditions. OCG will identify issues, and outline deliverables, payment schedules and other unique terms in the award notification.
  • Legally binding; and,
  • Require specific standards of performance.

 

Contracts may masquerade as:

    • Memoranda of Understanding;
    • Teaming Agreements;
    • Agreements with funds: e.g. grants with terms and conditions, purchase orders, Interagency Agreements; Intergovernmental Agreements;
    • Agreements without funds: e.g. Material Transfer
    • Agreements (MTA's), non-disclosure agreements, data use/transfer agreements; software licenses; intellectual property licenses; facilities use agreements; visiting scholar agreements.

Remember:

The content of the agreement determines if it is a contract, not the title!

Personal Services Agreements (Consulting Agreements)

    Special expertise or short term service required to support research or meet a specific requirement;

    Issued by Purchasing Service Center (PSC).

Vendor/Supplier Agreements

    Provides goods and services within normal business operations;

    Provides similar goods and services to multiple purchasers;

    Purchase Orders processed through PSC;

    SPO authorizes Subcontractor to expend funds and invoice.

Special case: Non-Disclosure Agreements (NDA's)

NDA's are also known as: Confidential Information Agreements or Proprietary Information Agreements

NDA's are used when --

  • There is a need to share proprietary information to evaluate a potential collaboration or licensing opportunity.
  • There is a need to guard against a public disclosure of proprietary Information that would result in harm to the owning party.

NDA's can be unilateral or bilateral; for an individual or organization; or for multiple parties.

NDA's should:

    • Identify the parties to the agreement;
    • Identify the points of contact for the receipt and the responsibility for the protection of proprietary information;
    • Identify the points of contract for administrative or legal notices;
    • Provide a stated reason to share confidential information (i.e. the purpose of the agreement);
    • Contain a brief, high level, summary of the proprietary information each party will bring to the discussion held under the agreement.

Other important considerations:

Keep proprietary information secure – lock it up, keep it off web accessible computers, password protect files, and, do not share with anyone who does not have a need to know.

Do not share proprietary information with University faculty or students without having them sign an agreement stating that they have a copy of the NDA, have read it, and agree to abide by its terms.

Proprietary technical information received from a sponsor is subject to export law (always ask the sponsor).

Faculty, staff and students are not authorized to sign NDAs related to their research at the University – authority is delegated in writing from the President of the University and comes to OCG;

NOTE!

Marking University information proprietary removes the fundamental research exclusion under export law.

Remember:

    • A nondisclosure agreement is a legally binding contract between the parties;
    • It is subject to all the rights and remedies that a injured party may have under law to become whole;
    • The University and the faculty member responsible for managing the proprietary information can be held liable for violating the terms of the agreement.

Funding Mechanisms

Cost Reimbursement Grants and Contracts

A grant or contract for which the sponsor has agreed to pay for the full costs incurred for the work up to a specific amount.

Characteristics include:

    • Budget based
    • An obligation or letter of credit
    • The check does not have to be "in the mail" because the
    • University underwrites the project expenditures.
    • SPA invoices for actual expenses.
    • The Sponsor incurs the risk.

Fixed Price Contracts

Typically, this is a contract for which a predetermined price is paid, regardless of actual costs. Often it is considered a work for hire or a fee for services. Characteristics include:

      • Price based (lump sum)
      • The check does not have to be "in the mail" because the
      • University underwrites the project expenditures
    • As milestones are met or products delivered, SPA bills and the Sponsor pays the invoice if the performance and deliverables are acceptable.
    • The University incurs the risk.

Award Receipt and Processing

Award Processing

    Award details are entered in the Filemaker award database by the Data Specialist (Award Processor).

    Award is reviewed and negotiated by the CGA.

    If required, the award is reviewed and signed by the Director or Associate Director.

    If a new award, SPA assigns a project number and speedtype.

    An e-mail notification is sent to the Principal Investigator and Department Administrator with the project number, speed type, copy of the award, and budget.

Common Delays

    A revised budget is required.

    The proposal was not submitted through OCG and one needs to be generated.

    The award contains unacceptable or problematic language.

    Regulatory approvals are missing (human subjects, animal care, bio-safety, radiation safety).

    The award has not been signed by the Sponsor.

Often, the following departments need to be consulted or to approve specific terms of the award:

    University Counsel

    Office of Technology Transfer

    Office of Risk Management

    Sponsored Projects Accounting

    Office of Research Integrity

    OVCR regarding Conflicts of Interest

    OVCR regarding Export Controls

Negotiation of Awards

The following are examples of issues that often need to be negotiated before a contract or grant can be accepted by the University:

    • Publication Restrictions/Nondisclosure Issues
    • Protection of Students' right to Publish
    • Restricted, Proprietary, and Classified Research
    • Intellectual Property/Work for Hire/Rights in Data/Freedom of Action Licensing Issues
    • Indemnification /Insurance
    • Governing Law and Venue
    • Inspection and Acceptance of Reports and other Deliverables
    • Export Regulations, including Restrictions on Publication and the Participation of Foreign Persons
    • Exclusivity and Non-Compete Restrictions
    • Financial Provisions, including Payment Schedules and Procedures, Excessive Documentation, Withholding of Payments/ Audit Requirements
    • Available Funding to Complete the Scope of Work
    • Ownership of Equipment
    • Default
    • Termination
    • Key Personnel/Approval of Staff
    • Technical Direction
    • Publicity/Use of Name/Disclosure of Sponsorship
    • Endorsement of Results

Establishing Pre-Award and At-Risk Accounts

Organizational Prior Approval System (OPAS):

Federally funded Grants may include authorization to expend grant funds up to 90 days prior to the official start date of the grant.

To establish a pre-award spending account:

    The official start date needs to be confirmed in advance of issuing a project (account) number.

    Your Contract and Grant Administrator will coordinate the paperwork and authorize the assignment of an account number.

    You will use this number to ensure that the appropriate account is charged and unnecessary cost transfers are avoided.

    Your department must agree to be financially responsible for any project costs that are disallowed, e.g. the award is not issued by the sponsoring agency or expenses are incurred prior to the estimated 90-day pre-award period.

NOTE: New project numbers may not be authorized by OCG if the PI has over-expended existing accounts or is delinquent on any technical reports.

At-Risk Accounts:

    Pre-award spending on Contracts requires explicit authorization from the funding agency's Contracting Officer.

    An at-risk account is appropriate when:

    The contract has not been fully executed but has a confirmed start date and all terms have been agreed upon.

    The Contract and Grant Administrator has worked with Sponsor to ensure that a clause will be written into the contract to allow for pre-contract costs.

    Your department has agreed to be financially responsible for any project costs that are disallowed if the contract is not executed. (Note: The at-risk form requires an alternative account number to which expenses will be charged if the contract is not executed.)

Project Management

Start Up Meeting

If requested, OCG will meet with the Principal Investigator and project staff members to discuss project management, including reports and deliverables, subcontract set-up and monitoring, and an explanation of unusual terms and conditions.

Managing your grant award using the Organizational Prior Approval System (OPAS)

The University's Organizational Prior Approval System demonstrates that the University has an administrative system to monitor award activity and document the decisions made on behalf of the Federal government.

Prior written authorization from the sponsor is required only for the following actions:

  • Change in the scope of work or the project objectives;
  • Change in a key person specified in the application or award document;
  • The absence for more than three months, or a 25% reduction in time devoted to the project, by the Principal Investigator;
  • The need for more Federal funding;
  • The transfer of amounts budgeted for indirect costs to absorb increases in direct costs, or vice versa;
  • The inclusion of costs that require prior approval according to OMB Circular A-21, ""Cost Principles for Educational Institutions";
  • The transfer of funds allocated for training allowances (stipends or participant expenses) to other categories of expenses;
  • Unless described in the application and funded in the approved awards, the subaward, transfer, or contracting out of any substantive work under an award, not including purchase of supplies, material, equipment, or general support services;
  • Reduction in a cost sharing amount identified in the award budget;
  • Pre-award expenses earlier than 90 calendar days prior to the award start date.

In accordance with OMB Circular A-110, the terms and conditions of most federal grant awards allow for considerable flexibility in managing your project.

Using the OPAS, the University can approve the following actions:

  • Incurrence of pre-award costs 90 calendar days prior to award;
  • Initiate a one-time extension of the expiration date of the the award of up to 12 months;
  • Carry forward unobligated balances to subsequent funding periods.

Budget Changes:

The award budget has been approved by the Sponsoring Agency. Consequently, only the Sponsor can authorize a change in the project budget.

Sponsoring Agency approval of a budget change results in a change to the PeopleSoft financial system.

Most grant awards allow for budget deviations, which are approvals to spend outside of the approved budget. Budget deviations require OCG approval, using the OPAS form.

Budget deviations approved by OCG do not result in changes to the PeopleSoft financial system so that actual expenditures can be compared with the approved budget.

Cost Transfers:

Journal Entries (JE's) reassign costs to a sponsored project after they were initially charged to another account to:

    • Correct errors;
    • Allocate costs that benefit more than one project;
    • Move over-expenditures to another non-restricted source of funding, e.g. dept account.

Remember: Cost transfers are acceptable under some circumstances, but they must meet specific procedural requirements.

Justification for Cost Transfers:

According to federal guidelines, "an explanation which merely states that the transfer was made 'to correct error' or 'to transfer to correct project' is not sufficient".

    Why was correct account not charged initially?

    How does this expense benefit the project receiving it?

    If the request to transfer funds is more than 90 days from initial entry, why did it take so to make the request?

Documentation:

Sponsored Projects Accounting requires documentation on specific types of expenses before approval.

Format:

Each journal must transfer specific transactions, and must also identify the original transaction Journal ID number and original Journal Date. Lump-sum cost transfers are usually not permitted.

SPA cannot approve a JE until it has departmental approval.

    The creator needs to contact the one who approved it and then follow up when not approved.

    SPA notifies the department about the JE only in the last week before month end close.

    SPA's goal is to approve JE's within 5 business days after they have received departmental approval.

Subcontracting

A Subcontract:

  • Is issued by OCG under a prime contract;
  • Requires the inclusion of the terms of the prime contract;
  • Includes specific requirements and deliverables.

A Sub-recipient Agreement:

Is issued by OCG under a federal financial assistance award (i.e. grant, cooperative agreement):

    For a substantial piece of the research project that contributes to the body of knowledge;

Subject to grant or cooperative agreement terms from Agencies.

    The Principal Investigator must identify and provide documentation for the Subcontract(s) or Sub-Recipient(s) during proposal preparation. At a minimum, this includes:

  • The official name, address, and contact for the Subcontractor or Sub-Recipient;
  • A detailed Scope of Work;
  • A detailed budget and budget justification;
  • A sole source justification; and
  • A commitment letter signed by the Subcontractor's Authorized Organizational Representative.

Subcontract/Sub-Recipient Process

The prime award is received; negotiated; and set up;

OCG ensures that the subcontract is approved by the Sponsor;

A subcontract notification (e-mail) is sent to the Principal Investigator and Department Administrator with a copy of the Subcontractor's original proposal;

The Principal Investigator and Department Administrator review the original proposal to determine if changes are needed;

A Request for Subcontract form sent to Principal Investigator and Department Administrator for completion;

The Principal Investigator and Department Administrator provide final subcontract documentation to OCG, which includes:

  • Confirmed/Updated Statement of Work
  • Confirmed/Updated Budget
  • Sole Source Justification, if not previously submitted
  • Technical analysis
  • Cost/price analysis

OCG prepares subcontract in accordance with the terms of the prime contract;

OCG sends subcontract to Subcontractor;

OCG negotiates terms as necessary;

Subcontractor signs and returns subcontract to OCG;

(If the value of the subcontract is over $100,000 or if the negotiated terms vary significantly from the subcontract template(s), it is forwarded to University Counsel for review.)

(If the value of the subcontract is over $5,000,000, it is sent to the President's office for review and signature.)

Signed by OCG Director;

Forwarded to the Procurement Service Center for processing;

Fully executed document is returned to Subcontractor with the SPO by PSC.

Delays:

  • Incomplete or erroneous materials received from the Principal Investigator/Department Administrator or Subcontractor;
  • Subcontract terms that require negotiation, including State of Colorado Special Provisions;
  • Intellectual Property issues;
  • University Counsel review;
  • President's signature;
  • Approvals required by the Sponsor;
  • Subcontract approval process at the subcontract organization.

Travel Authorizations:

OCG reviews and approves all travel authorization forms (TAP electronic forms) for sponsored project travel. All State of Colorado travel rules, University policies, Sponsor guidelines and, if applicable, federal rules and regulations must be followed.

The purpose of the review is to ensure that the travel is appropriate and an allowed expenditure.

    Is the trip directly related to the Project Scope of Work?

    Is the traveler paid by or otherwise directly engaged with the project?

    Are there sufficient funds to pay travel expenses?

    Are there any agency restrictions or additional approvals required?

Equipment Purchases:

OCG approves all capital equipment purchase requisitions prior to purchase.

Permanent equipment is defined as an item with an acquisition cost of $5,000 or more and an expected useful life of one year or more. However, for many funding agencies other definitions may apply.

    Procedures:

    • Review daily electronic list of equipment requisitions (fund 30 and 31 only);
    • Determine if the item is in the approved budget;
    • Determine if additional Sponsor approval is necessary;
    • Review the most recent financial report to determine if sufficient funds are available;
    • Approve the requisition electronically.

    For items requiring additional Sponsor approval:

    • Provide, as needed, any additional documentation and justification;
    • Prepare and/or cosign any letter necessary to obtain approval;

    For items requiring additional approvals under OPAS:

      Most federal grants include terms and conditions that either waive the prior approval requirements of OMB Circular A-21 or allow the University to approve certain budget deviations through the use of an internal approval system. UCB has an Organizational Prior Approval System (OPAS) whereby the Principal Investigator may request a significant budget deviation by completing the OPAS form, co-signed by his department chair or other appropriate academic official, and submitting it to OCG.

    General Purpose Equipment:

      General purpose equipment is equipment that is multi-purpose in nature and not used solely for research (research equipment is called "special purpose equipment"). Federal rules state that general purpose items should be provided by the University. Such equipment costs are allowable on grants and contracts only when specifically identified and justified in the proposal, included in the award budget, and approved by OCG through the submission of a Cost Accounting Standards Exceptions form.

Effort Reporting:

Salaries & wages for work performed directly on sponsored agreements represent the largest direct cost component on sponsored projects (approximately 70%-75%).

It is a federal requirement that people paid salary from sponsored projects substantiate they actually worked on those projects.

University uses an "after-the-fact" electronic system to certify work effort – ePERS (Electronic Personal Effort Reporting System), which requires self-monitoring, updating, and certification by the Principal Investigator and project staff members.

Three reports provide information on ePERS that your department can use to manage certification:

  • ePERSs by Org;
  • ePERS by PI;
  • uncertified ePERS by org or campus.

Employees with access to financial system can run these reports "on demand".

Invoicing

Sponsored Projects Accounting is responsible for all invoicing. SPA bills Sponsors after month end close or at another time established by the award notice. Departments should not send invoices to the Sponsors.

The Department is responsible for posting all expenses to the correct project, in a timely manner, so that an accurate invoice may be submitted to the Sponsor.

Invoices are sent out after the month end close, usually from the 4th - 7th of the month.

Depending upon Sponsor requirements, the following documentation may be needed:

  • Travel Documentation (e.g. ticket receipts, hotel receipts);
  • Copies of receipts for Fixed Assets and Operating Expenses;
  • Copies of Subcontract invoices, sometimes with backup;
  • Reports (e.g. travel summaries and justification);
  • Breakdown of salaries by name, hours worked, hourly rate (If the Department or project has agreed to provide this level of detail.);
  • Anything the Sponsor requests in support of the invoice.
  • Remember: at project close, SPA needs to invoice within 90 days. The Department/project has only 60 days to make changes and assign expenses correctly.

Special situations:

Some projects require Final Invoices 30, 45, or 60 days after the Period of Performance ends. Consequently, all expenses must be posted by the end date.

Delinquent reports may require more time to submit and/or correct.

Excessive carry forward funds may require special justification.

Accounts in deficit will need to be reconciled.

Program Income

Program Income is directly generated from a sponsored project, e.g. income from laboratory tests, software sales, and conferences.

Program income must be held in a separate account.

Program income can be:

Added to the funds available to support the project;

Deducted from the funds available to support the project; or

Used as non-federal cost share to support the project.

No-Cost Extensions

A No Cost Extension (NCE) is an extension of the period of performance beyond the expiration date. Usually, no additional funds are provided by the Sponsor.

Under grants with expanded authorities, one 12 month No Cost Extension (NCE) can be approved by OCG.

To submit a request for a NCE, provide the following information to OCG:

The desired length of the extension;

A brief summary of the work progress to date;

A brief summary of the work to be accomplished;

An estimate of remaining funds; and

A brief description of how the remaining funds will be expended in support of the project.

Note: all no-cost extensions require a genuine programmatic justification. Sponsoring agencies do not permit no-cost extensions solely for the purpose of spending the remaining funds.

Transfer of the Principal Investigator to another Institution

Under grant agreements, Principal Investigators are allowed to transfer their awards to their new institution. First, each award must be relinquished by the original institution to the awarding agency. Second, the new institution must submit an application to the awarding agency for the relinquished award. Third, the awarding agency must make a new award to the new institution.

This process may require from six months to a year to accomplish.

See Also: Checklist for PIs who Terminate or are on Extended Leave

Close Out Procedures

Unless the awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period of the date of completion

Recipients shall submit all reports as required by the terms and conditions of the award, for example:

  • Technical Reports (Principal Investigator)
  • Deliverables (Principal Investigator)
  • Financial (Sponsored Projects Accounting)
  • Property (Office of Contracts and Grants)
  • Inventions (Office of Contracts and Grants)
  • Contract Release (Office of Contracts and Grants)
  • Subcontract Release (Office of Contracts and Grants)
  • Small Business Plan Results (Department/Project)

Note: equipment disposal requests must be submitted to OCG.

Note: most final financial reports and final invoices on prime awards are due to the agency on or before 90 days after the project end date. Therefore, your transactions must be completed within 60 days after the end of the project for the SPA Grant Accountant to report timely and accurately.

The following issues may need to be addressed:

  • Over-expenditures;
  • Unallowable expenses;
  • Accounting errors, e.g. incorrect assignment of expenses;
  • Delinquent reports may result in delayed incremental funding, withholding of new awards, or, even, returning of funding.

The closeout process:

SPA and OCG review projects to determine that:

  • Expenses are accurate and allowable;
  • Encumbrances are legitimate and will be liquidated in a timely manner;
  • Standing Purchase Orders have been terminated;
  • Cost-sharing obligations have been met and documented;
  • HR procedures have been followed to change and/or terminate appointments.
  • All deliverables are complete and accepted (i.e. final technical report).

Subcontract closeout materials include:

  • Final invention report
  • Final invoice marked, received, paid
  • Final property report
  • A-133 certifications or other audit requirements
  • Small business forms (>$550,000)

PI must certify that the work was performed satisfactorily and the expenses were reasonable.

Audits

An audit is a formal examination of an institution's accounts or financial situation.

It may include examination of compliance with applicable terms, laws and regulations. Essentially, an audit is a tool that sponsors use to ensure we are being good managers and stewards of sponsor funding.

Audits review large number of items/issues, including (but not limited to):

  • Are the costs allowable, allocable, reasonable and consistent?
  • Were the charges assigned to the correct account in a timely manner?
  • Have we followed our own policies and procedures?
  • Did we meet our obligations as committed in our proposals?

What they are looking for:

  • Direct attribution must be established and demonstrated through supporting documentation.
  • Readily identifiable causal-beneficial relationship must exist between costs and the project.
  • Costs incurred for the same purpose in like circumstances should be treated consistently as either direct or indirect.
  • Indirect costs in award budget must have sufficient justification of different purpose and circumstance.
  • Other testing may include effort reporting, cost transfers, program income, reporting, sub-contract monitoring . . .

Governing Regulations

  • OMB Circular A-21, Cost Principle for Universities, Hospitals, and other Non-Profit Organizations These are the basic rules for determining applicable costs for federally funded Grants, Contracts, and other agreements with educational institutions.
  • OMB Circular A-110, Management Principles for Grants and Agreements These are the basic rules for managing Federal Grants and Cooperative Agreements. The Circular requires that institutions will have in place policies, procedures, and management systems adequate for monitoring sponsored project performance.
  • OMB Circular A-133, Single Audit Act
  • Federal Acquisition Regulations (FAR)
  • Fly America Act
  • Agency Policies and Procedures
    • NIH Grants Policy Statement
    • NSF Grants Policy Manual

Related Policies and Procedures

  • Regent Laws
  • Regent Policies
  • Administrative Policy Statements
  • Vice Chancellor for Research Website (including OCG)
  • Accounting and Business Support Website
  • Sponsored Projects Accounting Website
  • Departmental Financial Management Guide ("The Guide")
  • UCB DS-2 Statement (Accounting Disclosure Statement)
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