Post Award Administration

POST AWARD MANAGEMENT OVERVIEW

 

Receipt of a Grant Award Notification (GAN) is the final step of a lengthy process. First, a funding agency (or "sponsor") will issue a solicitation, call for proposals or request for application (RFA). One or more faculty members (led by a "Principal Investigator") will prepare a proposal application in response to the call. As part of the proposal process, the Principal Investigator (PI), in coordination with their departmental research administrator, completes a Proposal Transmittal Form (PTF) at the time of submission, which is routed through the appropriate College/School Department and forwarded to the Office of Sponsored Programs (OSP). An authorized organization representative must approve all proposal(s) submissions. This process assures that the proposal follows University policy and sponsor guidelines, that the university is capable and willing to support the project, and that the F&A and fringe rates used in the proposed budget are appropriate. If the sponsor decides to issue an award to FAMU, it will forward the award notification through the Division of Research, OSP, which will review the contractual terms and conditions to ensure they are acceptable to FAMU. Please note that all contracts require FAMU Legal Office review before obtaining Authorizing Official signature.

A Principal Investigator sometimes will receive an award without submitting a proposal. Generally, results from a more informal conversation with a sponsor (such as submitting a "white paper"). In such cases, the PI should work with their Research Departmental Administrator to complete all required pre-award proposal documentation. Pre-award documentation should be submitted to OSP, along with a copy of any prior correspondence (i.e., proposal, budget, justification). The proposed and approved Statement of Work (SOW), Budget, and Budget Justification are included in the award documentation. OSP will then review the terms and conditions of the award.  

Once OSP has determined that the award is acceptable to FAMU, a copy of the award documents will be scanned and distributed electronically to the PI, the College/School Dean, and other University Administrators. The College/School Departmental Research Administrator may request accounting information (also known as "Project budget/program/fund/department" numbers) in which the PI can charge project-related expenditures. OSP is responsible for setting up the award account, and the Contracts and Grants Office prepares and submits invoices against the award, preparing financial reports, and eventually closing the award account.

It is imperative that the PI carefully review any reporting requirements (also known as "deliverables") associated with the award. Dissatisfied sponsors can suspend awards, refuse to make payments, and demand refunds of previously provided funds. In extreme cases, sponsors can threaten to have FAMU debarred (which would make FAMU ineligible to receive federal funds). Different awards have different reporting requirements, but the most common report types are progress reports, technical reports, patent reports, property reports, and financial reports.

If a portion of the award is to be sub-contracted to another institution, a Subaward/Subcontract Form will have to be completed. See Subrecipient Procurement, Management, and Monitoring Procedure for more detailed instructions on this process.

The PI has a fiduciary responsibility to ensure that project funds are allowable, allocable, and reasonable within the period of performance outlined in the award. Expenditures on an award project are always subject to audit by internal and external auditors. It is, therefore, essential that expenses, award modifications, and special instructions are diligently recorded and documented. Faculty members can monitor their expenditures and balances in the iRattler system. All projects are accounted for separately.

In some cases, it may be appropriate to split the cost of an item between two or more projects (A large piece of equipment used on multiple projects). If numerous projects use an equipment item, the items must apply to the approved award. Costs applicability must be allocated appropriately among the projects. (i.e., it may be appropriate to split the cost of an item based on usage rates, but never simply because one project had a larger remaining balance.) See Uniform Guidance Cost Principles.

The terms and conditions of the award frequently include additional instructions on allowable costs. Some projects will not permit the purchase of any item not included in the original proposal budget, while other projects require the sponsor's prior approval before purchasing certain items. Many sponsors require prior authorization for expenditures outside of the terms and conditions of the award, for example, issuing subcontracts, purchasing capital equipment, authorizing foreign travel, and re-budgeting.

Keeping the sponsor well informed of any unforeseen problems is always good. For more information on extension requests, budget revisions, changes in project personnel (significantly when changing the PI), and changes in the scope of work, see Review and Approval of Revision of Budget and Program Plan to Sponsored Projects Procedure.

Upon completion of a project, the PI should work with their College Department Research Administrator, Sponsored Programs and Contracts and Grants Coordinators to ensure proper closeout of an award. OSP will send out 90, 60, and 30 days notices to PI to confirm final expenditures and submit a final invoice to accountspayabledocs@famu.edu and any applicable final financial, technical reports (check terms and conditions of award for reporting method) to the sponsor. Contracts and Grants will close the awarded project when all invoiced amounts have been received based on confirmation by PI.

 

 

TYPES OF AWARDS

 

GIFTS to the University support broad faculty activities. Florida A&M University (FAMU)/University Advancement manages Donations (gifts). Please contact FAMU Advancement Foundation at (850) 412-5755. Three general features of Donations (gifts) include:

  • No deliverables may be required from the activities supported
  • No formal technical reports are required
  • No standard financial statements are required

GRANTS are made to the University on behalf of faculty to perform a specific project. The sponsor generally supports the project as outlined in a proposal. Grant characteristics include:

  • A project usually has stated goals and objectives
  • The sponsor has expectations about how the funds will be expended
  • Grant deliverables may consist of formal project reports
  • A financial report is required
  • Additional requirements may be applicable based on the terms and conditions of an award

COOPERATIVE AGREEMENTS are agreements in which the Federal Government provides funding or a thing of value authorized by public statute, and the government plays a substantial role.

A cooperative agreement is a form of assistance. It reflects a relationship between the US Government and a recipient. Cooperative Agreements are used when the government's purpose is to assist the intermediary in providing goods or services to the authorized recipient, rather than to acquire an intermediary's services, which the agency may ultimately be delivered to a recipient. 

CONTRACTS are the most formal type of award made to the University. Under a contract, the sponsor supports clearly defined activities. Contract characteristics include:

  • Specific deliverables are stipulated
  • The sponsor monitors project performance
  • Technical reports are required
  • Detailed financial statements are required

Authorized University officials must review all four types of awards to ensure that FAMU will comply with any sponsor-imposed terms and conditions.  Please note that the Legal Office requires up to three (3) weeks to review a contract (if applicable).

Please see Submission of Proposals and Management of Awards by Division of Research or Office of University Advancement Memorandum dated December 15, 2009, for additional information regarding gifts, grants, and contracts from private sources. 

 

 

FUNDING SOURCE

 

FEDERAL

Most federal grants are subject to the Research Terms and Conditions established by the Federal Demonstration Partnership (FDP).

Most federal contracts are subject to the Federal Acquisition Regulations (FAR).

Federal grants and contracts are both subject to the Uniform Guidance (UG) components. The UG Update section provides an overview of key concepts.

Intellectual Property generated on Federal Funds is subject to the Bayh-Dole Act (37 CFR 401).

Some commonly used terms for federal awards include the following:

  • Grant Award Notification (GAN)
  • Pre-award Cost Authorization (PCA)
  • Project Extension Notification (PEN)

 

INDUSTRY

Industry agreements to the University are in various formats, and PI should route documents to sponsor@famu.edu. FAMU Legal Office must review all contracts.

 

 

AWARD/CONTRACT NEGOTIATIONS

 

All awards received by faculty members of Florida A&M University (FAMU) are made to the University on the individual's (faculty researcher) behalf. FAMU assumes all financial responsibility and guarantees that the project will be completed in compliance with the terms and conditions of the award.

First, the Division of Research (DoR) Office of Sponsored Projects (OSP) receives notification that the sponsor wishes to support the submitted proposal. DoR OSP enters into formal negotiations with the sponsor by reviewing the award's terms and conditions. After all, parties agree upon the contract's content, and the University accepts the award.

START DATE

Funding authority is not released to the University until after the project's official start date is established. This date is predicated upon acceptance of all terms of the award by both parties. The agency may require updated information from the PI to support the project.

The sponsor in the award sets Contract/Grant start dates. Contracts are not as predictable. An agency may specify a contract/grant start date before obtaining both parties' signatures. In other cases, the contract/grant start date may be determined by the final signature date. Depending on the contract, the final signatory may be the University Authorizing Official or the sponsor.

FUND NUMBERS

Once the start date is determined, the OSP will set up the project award approved budget (project, fund, program, and department numbers) in iRattler Financial System. Project expenditures are processed using these assigned unique codes which identifies the combo with associated unique award number.

 SUB-CONTRACTS/SUB-AWARDS

The College/School must submit a Sub-contract/Sub-award information to OSP for proposals that require sub-award participation. OSP will then prepare a subcontract or sub-award between FAMU and the third party with applicable terms and conditions. Terms and conditions of the prime award will be flowed-down to the sub-awardee.

EXPENDITURES

The PI, with the cooperation of the appropriate departmental staff, manages award funds and initiates all expenditures. FAMU Division of Research OSP monitors and reviews expenditure requests for allowability, allocability, and reasonableness of costs. Contracts and Grants submit invoices and official financial reports to the sponsor as required.

In some instances, the PI may need to expend funds for a project before the sponsoring agency completes the award process. In these cases, your College/School may request prior approval for an award project to be established prior to an award's acceptance if the sponsor has a solid commitment. The College/School assumes all risk in covering advance fund to incur expenditures should the award never become fully executed.

INVESTIGATOR'S RESPONSIBILITIES

The PI must: 1) maintain contact with the sponsor's technical monitor and comply with all technical reporting requirements; and 2) initiate correspondence with the sponsor's administrative or contract monitor to request programmatic or budgetary changes. Revisions require an Authorized Official signature.

 

Documents

Agency Prior Approval Appendix

Allowable and Unallowable Costs

Important Information

 

Revision to 2 CFR 200 (“The Uniform Guidance”)

 

The top ten list below highlights revisions that everyone should know about. Certain other modifications may be of interest to specific units at FAMU. (For example, if you work in FAMU Purchasing, you’ll want to check out 200.318, 319, 320, and 322. If you perform sub-recipient risk assessments, you’ll want to check out 200.325 and 200.332. If you work on the FAMU audit, you’ll want to review any changes to Subpart F.)

  1. Most revisions are effective 11/12/20. (Two of the revisions—216 and 200.471—were effective 8/13/20.)
  2. Several sections of the UG have been re-numbered. (We’ll update hyperlinks in policies, hyperlinks, etc. Please let us know if you find one we’ve missed.)
  3. All definitions have been combined into one section (1 Definitions).
  4. 216: We can’t use grant funds to purchase Covered Telecommunications Equipment (CTE), e.g., equipment produced by Huawei and ZTE.
  5. 105: Agencies may impose legally binding requirements only through formal rulemaking. They can’t implement policy changes by issuing an FAQ or agency guidance that hasn’t gone through notice and public comment processes.
  6. 329 and 200.344: Allows recipients an additional 30 days to file final reports (i.e., 120 calendar days after the end of the performance period.) Subrecipients must submit their closeout reports no later than 90 calendar days after the end date of the period of performance.
  7. 340 provides the Government with more latitude to terminate projects whenever they want, even if we’ve done good work and followed all the terms and conditions.
  8. 405: If a sub-recipient doesn’t have a current F&A rate agreement, we are allowed to accept their expired, previously negotiated rate. Several other options are available for determining the appropriate F&A rate for sub-recipients.
  9. 414 allows any entity, whether or not they’ve ever had a Federal negotiated F&A rate, to use the 10% de minimus F&A rate. No documentation is required to use this rate.
  10. “CFDA number” is now being called “assistance listing number.”

 

Uniform Guidance: Executive Summary

 
The Uniform Guidance (2 CFR 200)

The Office of Management and Budget (OMB) combined many Federal circulars–including OMB Circulars A-110, A-21, and A-133–into a single document called the "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards," generally referred to as the Uniform Guidance or 2 CFR 200. The Uniform Guidance applies to new and incremental Federal awards issued on or after December 26, 2014. Following are some key sections of the Uniform Guidance:

 

Cost Sharing

The Uniform Guidance states in 200.306 that voluntarily committed cost sharing is not expected under Federal research proposals and cannot be used as a factor during the merit review of the proposal. Cost-sharing may only be considered when regulation requires and transparent in the notice of funding opportunity.

 

Administrative/Clerical Staff

Administrative and clerical salaries should not generally be charged to sponsored programs unless all of the following criteria are met (§ 200.413(c)):

  • Administrative or clerical services areintegral to a project or activity; 
  • Individuals involved can be specifically identifiedwith the project or activity; 
  • Such costs are explicitly included in the budgetor have the prior written approval of the Federal awarding agency; and 
  • The costs are not also recovered as indirect costs.

Please complete the Exemption to Direct Charge Cost Normally Treated as Indirect Cost Form for proposals, where administrative and clerical salaries are being directly charged to provide the justification and documentation required to support our decision to direct charge these costs. There should also be an explicit explanation in the budget justification of the proposal.

 

Computing Devices.

General-purpose computing devices may be directly charged as a supply cost applicable to the above criteria. §200.94 clarifies that a computing device is a supply, provided the acquisition cost is less than $5,000. However, approval on one award/contract does not mean that it's appropriate to charge a laptop or IPad on another funded project. A computing device will only be an allowable expense if necessary, reasonable, consistently treated, and properly allocated (see §200.403 and §200.405).  In plain language, this means the computing device must be: 

  • essential for carrying out a specific aim of the funded project, 
  • above and beyond what is generally provided by the department for academic use, and 
  • charged the grant in some reasonable proportion relative to how much is used for the funded project.

PIs and departments should maintain documentation that describes how the proposed computing device meets the above requirements. The Cost Accounting Justification for Non-Personnel Costs is recommended as a best practice. 

 

Travel Costs

According to Uniform Guidance 2 CFR 200.474, an individual's travel can only be paid on a federally-sponsored award if the individual's participation is necessary for the award and the costs are a direct result of the individual's travel for the federally sponsored award.  Documentation should be maintained clarifying why the particular person is traveling, why it is necessary and how it benefited the project.  

TIPS TO POST PI’S AND DEPARTMENT MANAGERS

  • Check Awarded Information
      • Agency Approved Budget
      • Terms and Conditions of Award
      • Reporting and Close-out Requirements
  • Maintain oversight of approve budget
      • Contact Contracts and Grants for monthly encumbrance and expenditure reports
      • Clear-up any outstanding encumbrances
      • Send PO’s and Requisitions Cancellations requests to Procurement
      • Receipt goods and services timely to ensure timely payment of vendors
      • Verify all payments to vendors including subcontractors or consultants
      • Check payroll encumbrances to ensure employees are paid from correct project
      • Never request or authorized services or receipt items prior to going through the appropriate University procurement and travel processes
      • Complete travel (prior to trip) and expense requests timely
      • Submit amendment request prior to sending documents for approval if allowable
  • Monitor and track expenditures monthly (payroll bi-weekly)
      • Payroll
      • Procurement
      • Travel
      • Journal Transfer
  • Prior to expenditures requests verify available funding
      • Check Commitment Control
      • Previous amendment requests
  • Communicate!!!!!
      • Send email questions or concerns to assigned Coordinator or sponsor@famu.edu