Introduction to Grant Management

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• Sponsored Programs Structure
• Budget Management
• Audit Requirements
• Cost Principles (CFR 45)
• Case Studies

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Outline

Office of Research Responsibilities

• Proposal Development & Submission, terms & conditions

• Budgets

• No-Cost Extension

• Subawards

• Progress reports, Human Subjects, Animal Protection, Environmental & Safety, Export/Tech Transfer

• Cayuse is the system of record

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Grants Accounting Responsibilities

• Award Setup, new fund & location codes assigned

• Financial Oversight, review of expenditures, financial forecasts

• Invoicing and reimbursement requests

• Financial Reporting, Effort Certification, Cost Share Tracking

• Subaward invoices and monitoring

• Award Close out

• Banner is the system of record

Sponsored Projects Structure

Life Cycle of a Grant

Life Cycle of a Grant

Regulatory Landscape�Spending Regulations

Public Laws

Institutional Rules and policies

All Grant expenses must be:

• Necessary
• Reasonable
• Allocable
• Compliant with all rules, regulations, policies & procedures

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Budget Management�

• Review your budget, expenses, and balance on a monthly basis
• What to look for/notice.
• Understand the “burn rate”
• Check each line item
• Example: payroll

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Rebudgeting of Funds

Significant rebudgeting occurs when expenditures in a single direct cost budget category deviate (increase or decrease) from the categorical commitment level established for the budget period by 25 percent or more of the total costs awarded (NIH 8.1.2.5).

Carryover Authority

Unless otherwise noted by a specific term of award, Individual CDAs have automatic carryover authority. However, for most Institutional CDAs, carryover requires prior approval. The NoA will specify whether or not the recipient must obtain prior approval to carry over funds (NIH 12.10).

No-Cost Extension

The NIH Standard Terms of Award provide the recipient the authority to extend the final budget period of a previously approved project period one time for a period of up to 12 months beyond the original completion date down in the NoA. Any additional project period extension beyond the initial extension of up to 12 months requires NIH prior approval (NIH 8.1.2.1).

Where to Find Answers

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• Funding Opportunity Announcement (FOA)
• Notice of Award (NOA)
• Office of Research and Sponsored Programs at your institution (ORSP)
• NIH Grants Policy Statement
• Grants Officer

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Audit Requirements

All NIH grant recipients that expend $750,000 or more within a year in Federal awards are subject to an audit requirement.

Audits are due within the earlier of 30 days after receipt of the auditor’s report(s) or 9 months after the end of the recipient’s audit period.

Recipients delinquent in submitting audits risk the imposition of sanctions and potential loss of Federal funds.

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Cost Principles-45 CFR Part 75

As the NIH exists under the oversight of the Department of Health and Human Services, NIH grants are subject to federal regulation: 45 CFR (Code of Federal Regulations) Part 75 – Public Welfare, Uniform Administrative Requirements, Cost Principles and Audit Requirements for HHS Awards (which can be read in its entirety in the link here). We'll concern ourselves with Subpart D: Post Federal Award Requirements (§ 75.300 –§75.391), which deals with the following:

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Cost Principles-45 CFR Part 75

The following are covered under 45 CFR Part 75 Subpart D: Post Federal Award Requirements (§75.300 – §75.391),

-Standards for Financial and Program Management

-Property Standards

-Procurement Standards

-Performance and Financial Monitoring and Reporting

-Subrecipient Monitoring and Management

-Record Retention and Access

-Remedies and Noncompliance

-Closeout

-Post-Closeout Adjustments and Continuing Responsibilities

-Collection and Amounts Due

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Case Studies

Case Study #1

Dr. Miller purchases a much needed piece of specialized, scientific equipment for her research on hypertension. When preparing the purchase request, she realizes that the only account with enough money is her grant for research on sleep disorders. Because both grants are funded by NIH, she charges the equipment to the sleep disorder grant.

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Is this appropriate?

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Case Study #1

The NIH Grants Policy Statement addresses four tests to determine allowability of costs:

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Allocability

• A cost is allocable to a specific grant if it is incurred solely to advance work under the grant and is deemed assignable, at least in part, to the grant.

Reasonableness

• A cost may be considered reasonable if the nature of the goods or services acquired reflect the action that a prudent person would have taken under the circumstances prevailing at the time the decision to incur the cost was made.

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Case Study #1

Consistency: Recipients must be consistent in assigning costs.

• Although costs may be charged as either direct costs or F&A costs, depending on their identifiable benefit to a particular project or program, they must be treated consistently for all work of the organization under like circumstances, regardless of the source of funding.
• Conformance: Conformance with limitations and exclusions as contained in the terms and conditions of award.

Varies by type of activity, type of recipient, and other specific requirements of individual awards.

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Case Study #1

For further reading:

NIH GPS 2017: Chapter 7.2 The Cost Principles.

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Case Study #2

A university employee transfers expenses from one account another and annotates the cost transfer “to correct an accounting error.”

Internal Audit takes exception.

Why?

Case Study #2

Errors should be corrected within 90 days of when the error was discovered.

Transfers must be supported by:

Documentation that fully explains how the error occurred

Certification of the correctness of the new charge (by a responsible organizational official)

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Transfers of costs from one project to another or from one competitive segment to the next solely to cover cost overruns are not allowable.

All charges to grants must be reasonable, allowable, allocable, and consistently applied.

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Case Study #3

You are asked by a PI to stop at an office supply store on your way to work and pick up a few items (pens, envelopes and paper clips). The PI also asked you to get some donuts for a lab meeting that morning. When you arrive at work, the PI tells you that all of the items should be charged to the grant.

Your Departmental Administrator tells you that

these purchases must come from Departmental

funds. Why?

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Case Study #3

Meals are allowable on a research grant when:

1. they are provided to subjects or patients under study provided that such charges are not duplicated in participant’s per diem or subsistence allowances, if any;

2. such costs are an integral and necessary part of a meeting or conference (i.e., a working meal where business is transacted), and

3. such costs are specifically approved as part of the project activity, consistent with the terms of award.

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Case Study #3

An institution should have a written and enforced policy in place that addresses the following:

• Ensures consistent charging of meal costs
• Defines what constitutes a meeting for the dissemination of technical information
• Specifies when meals are allowable for such meetings
• Establishes limitations and other controls on this cost to meet the test of reasonableness

Remember: Recurring business meetings, such as staff meetings, are generally not considered meetings to disseminate technical information.

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Story time!

• Charging “flights of beer”
• “Staff meetings” at various restaurants
• Questionable advertising
• Order supplies and equipment during the final days

In Conclusion

A PI’s role in oversight of a grant is just as important as their role in research, creative activity, or program delivery.

Find your support team.