1 Module 4: Post-Award Administration of Sponsored Projects (Part 2) Office of Research and Sponsored Programs The University of Mississippi 100 Barr Hall ~

Updated October Part 2 of Module 4 provides detailed information on some of the most common post-award administration activities including: Changes to an existing award Subawards Regrants Reporting Closeout Beyond closeout

Updated October Changes to an existing award

Updated October Changes to an existing award Some changes can be approved by the institution (through the ORSP) – this is called “Expanded Authorities” (not applicable to federal contracts) Other changes require prior approval from the sponsor The award terms and conditions will tell you how to handle changes to an existing award Any change that is subject to Expanded Authorities or that requires sponsor prior approval should be processed through the ORSP

Updated October Changes that always require sponsor prior approval Written prior approval from the sponsor is always required for any of the following: Change in the project scope or objectives Absence of the principal investigator for more than three months or a reduction of 25% or more in effort devoted to the project Change in key personnel The transfer of funds allotted for training allowances (direct payment to trainees) to other categories of expense Transfer the performance of “substantive work” on the project to a third party (subcontract, subaward)

Updated October Changes that sometimes require sponsor prior approval Written prior approval from the sponsor is sometimes required for any of the following: Purchase of equipment not in the approved budget Use of consultants Rebudgeting between direct and F&A costs

Updated October Changes that do not require sponsor prior approval OMB Circular A-110 permits federal granting agencies to waive certain sponsor prior approval requirements and gives the grantee institution the authority to approve actions such as: Incurring pre-award costs (if allowed by the agency) First-time no-cost extension of up to one year (but you cannot extend just to spend out remaining funds) Carry forward of unobligated balances

Updated October How do I obtain prior approval? It depends on whether your award is: Federal or Non-federal

Updated October Obtaining prior approval on federal awards To obtain institutional prior approval, the investigator should complete a UM Prior Approval System for Federal Grants and Agreements form and forward it to the ORSP then… The ORSP will request prior approval from the sponsor if sponsor approval required or.. The ORSP will notify the sponsor of the change if institutional approval required

Updated October Obtaining prior approval on non- federal awards Contact the ORSP The ORSP will request prior approval from the sponsor if sponsor approval required or.. The ORSP will notify the sponsor of the change if institutional approval required

Updated October Subawards

Updated October Subawards Need for a subaward Initiating subawards Monitoring subawards Changing subawards Closing subawards

Updated October Need for a subaward The potential need for a subaward should be considered by the investigator at the proposal stage. Why?  Because most funding agencies require written approval before a subaward is issued  Because (depending on sponsor guidelines) other information may be required such as: Letter of intent Biographical sketch Current and pending other support Available facilities information

Updated October Initiating subawards The steps to be taken in initiating a subaward depend upon whether: The subaward was included in the approved award budget, or The subaward was not included in the approved award budget

Updated October Initiating subawards: Subaward included in approved budget – investigator responsibilities The investigator should forward the following to the ORSP: Request to Issue Subcontract or Subcontract Modification Under an Externally Funded Program form Statement of Work (approved by subaward institution) Budget (approved by subaward institution) Copy of the subrecipient’s F&A Rate Agreement (if F&A is being requested) then…

Updated October Initiating subawards: Subaward included in approved budget – ORSP responsibilities The ORSP will: Determine that the subrecipient is not debarred or suspended from receiving federal awards Develop the subaward in compliance with sponsoring agency guidelines, UM and subrecipient policies and procedures Obtain subrecipient A-133 Compliance Certification, if applicable Obtain signatures of the UM investigator, the subrecipient authorized official, and the VC/ORSP to execute the subaward Create a purchase order to encumber funds Provide a copy of the fully executed subaward to the UM investigator Annually, ensure that the subrecipient remains compliant with A-133 audit requirements throughout the life of the subaward Perform desk audits as necessary for review of subrecipient fiscal records

Updated October Initiating subawards: Subaward NOT included in approved budget – investigator responsibilities The investigator should: Obtain sponsor approval to issue the subaward (concurrence of the technical manager, then approval of the grant/contract manager) Document the basis for subrecipient selection Forward the following to the ORSP:  A Request to Issue Subcontract or Subcontract Modification Under an Externally Funded Program form  Statement of Work (approved by subaward institution)  Budget (approved by subaward institution)  Copy of the subrecipient’s F&A Rate Agreement (if F&A is being requested)  Documentation of sponsor approval of the subaward then…

Updated October Initiating subawards: Subaward NOT included in approved budget – ORSP responsibilities The ORSP will: Determine that the subrecipient is not debarred or suspended from receiving federal awards Develop the subaward in compliance with sponsoring agency guidelines, UM and subrecipient policies and procedures Obtain subrecipient A-133 Compliance Certification, if applicable Obtain signatures of the UM investigator, the subrecipient authorized official, and the VC/ORSP to execute the subaward Create a purchase order to encumber funds Provide a copy of the fully executed subaward to the UM investigator Annually, ensure that the subrecipient remains compliant with A-133 audit requirements throughout the life of the subaward Perform desk audits as necessary for review of subrecipient fiscal records

Updated October Monitoring UM subawards: Investigator responsibilities Provide ongoing monitoring of subrecipient’s programmatic and fiscal compliance throughout the life of the subaward Maintain regular contact with subaward principal investigator regarding technical aspects of project Review and approve subrecipient invoices Perform site visits as necessary to review fiscal and program- matic records and/or observe programmatic activities of the subrecipient Ensure that all deliverables (e.g., technical, equipment, and invention reports) required under the subaward are being provided before approving invoice payment

Updated October Monitoring UM subawards: ORSP responsibilities Inform each subrecipient of the Catalog of Federal Domestic Assistance (CFDA) title and number, award name and number, and name of the federal agency providing funding, if applicable Advise subrecipients of the requirements imposed on them by federal laws, regulations, the provisions of the prime award, or provisions of UM Ensure that non-profit subrecipients expending $500,000 or more in federal awards during the subrecipient’s fiscal year have met the audit requirements of OMB Circular A-133 and…

Updated October Monitoring UM subawards: More ORSP responsibilities Issue a management decision (when subrecipients have A-133 audit findings) within six months after receipt of the subrecipient’s audit report and ensure that the subrecipient takes appropriate and timely corrective action Consider whether subrecipient audits necessitate adjustment of UM’s own records Require each subrecipient to permit UM and auditors to have access to the records and financial statements as necessary for audit purpose and…

Updated October Monitoring UM subawards: More ORSP responsibilities Review and approve subrecipient invoices and forward them to the investigator for final review and approval Perform desk audits and/or site visits as necessary for review of subrecipient financial records Obtain a Small Business Subcontracting Plan from the subrecipient if a subaward is on a federal contract incorporating the Small Business Subcontracting Plan requirement, the amount of the award is ≥$500,000 AND the subrecipient is not a small business

Updated October Changes to existing subawards A formal amendment or modification should be issued to make one or more of the following changes to an existing UM subaward: Change in period of performance Significant change to the budget Change in scope of work Change of key personnel Acquisition of equipment not in the budget Issuance of a lower-tier subaward

Updated October Initiating a change to an existing subaward To initiate a change to an existing UM subaward, the investigator should: Obtain prior approval of the sponsor, if required (concurrence of the technical manager, then approval of the grant/contract manager) Forward the following to the ORSP:  Request to Issue Subcontract or Subcontract Modification Under an Externally Funded Program form  Description of the change  Approved budget (if changing funding)  Documentation of sponsor approval (if prior approval required)

Updated October Closing subawards Subawards must be closed by UM before the prime award close date (ORSP recommends 30 days before) Subawards typically have closeout requirements similar to those of the prime award The investigator is responsible for insuring that the subrecipient has submitted all required closeout reports and a FINAL invoice to UM

Updated October Regrants

Updated October Regrants On occasion, a sponsored program will require contracting with a UM faculty member who has been selected to perform a portion of the statement of work, but who was not included in the approved budget as program personnel. Funds for the faculty member’s effort are provided in the form of a regrant.

Updated October Regrants In order to initiate the process of transferring funds for the faculty member’s use, a Request to Issue Regrant form, along with a Transmittal Sheet, statement of work and budget, should be submitted to the ORSP. Work performed under a regrant is subject to the same terms and conditions as the original award.

Updated October Reporting

Updated October Reporting: Technical Investigator is responsible for preparation and submission to sponsor Frequency and format specified in award terms and conditions Timely submission is important Failure to submit in a timely manner could jeopardize future funding from the sponsor Sponsor uses technical report to monitor and evaluate project performance

Updated October Reporting: Financial Accounting Department is responsible for preparation and submission to sponsor BUT investigator is responsible for submitting to Accounting the following information to be used in financial reports:  Effort reporting and certification (see Module 6 for more information)  Cost sharing documentation (see Module 5 for more information) Frequency and format specified in award terms and conditions

Updated October Reporting: Patent/invention Investigator is responsible for preparation and submission Frequency and format specified in award terms and conditions Work with ORSP Division of Technology Management if patents are involvedORSP Division of Technology Management

Updated October Reporting: Other Investigator is responsible for preparing and submitting Frequency and format specified in award terms and conditions Investigator is responsible for preparing and forwarding to ORSP if institutional signature is required

Updated October Closeout

Updated October Closeout What is closeout? Where can closeout instructions be found? What reports are typically included in closeout and who is responsible for submitting them?

Updated October What is closeout? Closeout is the process that must be followed when a sponsored project ends to ensure that sponsor reporting requirements have been met

Updated October Where can closeout instructions be found? OMB Circular A-110, Subpart D establishes general procedures for closeout of federal grants and cooperative agreements Agency-specific closeout instructions can be found in the award terms and conditions

Updated October The closeout process Approximately 60 days before project end date, ORSP sends an reminder to investigator The investigator should:  Ensure that all project costs have been appropriately charged  Ensure that cost sharing is on track  Review personnel on sponsored project and decide whether to transfer to another project or terminate  Remind subrecipients of required reports, if applicable

Updated October What reports are typically included in closeout? Federal grants and cooperative agreements:  Final technical report  Final financial report  Final patent report Due within 90 days from project end date

Updated October What reports are typically included in closeout? Federal contracts:  Final technical report  Final financial report  Final patent report  Final property report  Contractor’s release form Generally due within days from project end date

Updated October Final technical report Sponsor requirements are usually defined in the award terms and conditions If an authorizing official signature is required, investigator should forward report to ORSP for VC/ORSP signature Investigator is responsible for submitting report to agency and sending a disk copy (CD) to ORSP along with documentation of date report was submitted to agency

Updated October Final technical report: Content The investigator should follow agency instructions regarding the content and format of the final technical report. When required, the final technical report should generally contain brief information on each of the following: 1.A comparison of actual accomplishments with the goals and objectives established for the period, the findings of the investigator, or both. Whenever appropriate and the output of programs or projects can be readily quantified, such quantitative data should be related to cost data for computation of unit costs. 2.Reasons why established goals were not met, if appropriate. 3.Other pertinent information including, when appropriate, analysis and explanation of cost overruns or high unit costs.

Updated October Final financial report Accounting prepares with assistance from the investigator Accounting usually submits to sponsor, but may work with investigator to submit if investigator signature is required and/or if financial report is to be submitted with technical report

Updated October Final patent/invention report Investigator is responsible for preparing report and submitting to sponsor (with assistance from ORSP, if needed and/or from ORSP Division of Technology Management, if patents/inventions are involved)*ORSP Division of Technology Management If an institutional signature is required, investigator should forward report to ORSP *Please note that patents should be discussed with staff in the ORSP Division of Technology Management as early as possible, even at the proposal stage. Technology Management staff are available to assist faculty and other personnel in identifying proposed project activities that may potentially result in patentable inventions. This ensures that faculty are informed at the outset concerning what to do to protect the inventions that may arise from the sponsored project, and also ensures that appropriate language is included in the sponsored research agreement establishing the relationship between the university and the sponsor should an invention arise from the sponsored project.

Updated October Other final reports Investigator is responsible for submission to sponsor and for sending a copy to ORSP If an institutional signature is required, investigator should forward report to ORSP

Updated October Beyond closeout

Updated October Beyond closeout Over/under-spent funds Project records

Updated October Beyond closeout: Over/under-spent funds If a project has significant over-spending or under-spending, it reflects negatively on the university Remember, the budget is the financial expression of the project

Updated October Beyond closeout: Over-spent funds Over-spent funds indicate: Inadequate planning Inadequate financial management And the investigator/department pays…

Updated October Beyond closeout: Over-spent funds Costs charged to sponsored projects that cannot be collected from the sponsor for reasons such as unallowability, unallocability, dispute with or bankruptcy by the sponsor, or other reasons, must be paid for with principal investigator or departmental funds. UM Policy ADM.AC (Transfer of a deficit balance to another grant account is generally unallowable.)

Updated October Beyond closeout: Under-spent funds Under-spent funds indicate: Inadequate planning Inadequate financial management Goals of the project not being met

Updated October Beyond closeout: Under-spent funds For cost-reimbursement awards, funds remaining at the end of the project must be returned to the sponsor For fixed price awards, funds remaining at the end of the project remain available to the investigator Remember, the budget is the financial expression of the project – under-spent funds are an indication of inadequate planning and inadequate financial management

Updated October Beyond closeout: Project records Records retention requirements Exceptions to records retention requirements Other requirements Who is responsible for retaining what?

Updated October Beyond closeout: Records retention requirements-federal Financial records, supporting documents, statistical records, and all other records pertinent to an award shall be retained for a period of three years from the date of submission of the final expenditure report or, for awards that are renewed quarterly or annually, from the date of submission of the quarterly or annual financial report. OMB Circular A-110, Subpart C: Post-Award Requirements

Updated October Beyond closeout: Exceptions to records retention requirements If any litigation, claim, or audit is started before the expiration of the three-year period, the records shall be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken Records for real property and equipment acquired with federal funds shall be retained for three years after final disposition When records are transferred to or maintained by the federal awarding agency, the three-year retention period is not applicable to the recipient

Updated October Beyond closeout: Other requirements Health Insurance Portability and Accounta- bility (HIPAA) documentation should be retained for six years from the date of its creation or the date when it was last in effect, whichever is later Select agent regulations require the retention of administrative as well as scientific data for three years and…

Updated October Beyond closeout: More requirements Export control regulations require that all records required to be kept by the EAR must be retained for five years from the latest of the following:  The export from the U.S. of the item involved in the transaction, or  Any known re-export, transshipment, or diversion of such item and…

Updated October Beyond closeout: More requirements For projects involving patent applications, lab notebooks and supporting information related to the patent should be retained for the life of the patent (20 years) Misconduct records should be retained for seven years

Updated October Who is responsible for retaining what records? The Investigator is responsible for retaining and disposing of all project data and materials as specified in the applicable regulations Accounting is responsible for retaining and disposing of all project financial records as specified in the applicable regulations The ORSP is responsible for retaining and disposing of all award records as specified in the applicable regulations

Updated October Resources Post-Award Resource Guide for Principal Investigators ORSP Subaward Policies and Procedures Subaward Checklist – Primary and Supporting Roles (scroll down to bottom of page for subaward forms) Request to Issue Subcontract or Subcontract Modification under an Externally Funded Program form (scroll down to bottom of page for subaward forms) Office of Research and Sponsored Programs — x7482 Office of Research and Sponsored Programs