Post-Award basicsMATTHEW MOORE

ASSOCIATE DIRECTOR, POST-AWARD OPERATIONS

Objectives Key Concepts

Rules & Regulations Governing Sponsored Projects

Process

Review Strategies

Special Considerations

Types & Sources of Sponsored Projects

Types◦ Grants◦ Cooperative Agreements◦ Contracts

Sources◦ Federal agencies◦ State agencies◦ Sub-awards◦ Foundations◦ Industry◦ Non-Profits

Types of Sponsored Projects Grants

◦ Legally binding agreements that provides financial support for a specific activity, project, or program.

◦ Used when: Goals are to accomplish a public purpose, no substantial involvement between sponsor and awardee, and project is conceived by awardee

◦ General Requirements◦ Period of performance◦ Unspent funds are returned◦ Spent in accordance with budget◦ Terms & Conditions◦ Financial & Programmatic Reports

Types of Sponsored Projects (Cont.)

Cooperative Agreements:◦ Legally binding agreements that provides financial support for a specific activity, project, or program. ◦ Used when: Goals are to accomplish a public purpose, substantial involvement is anticipated between

sponsor and awardee, funding is on a cost-reimbursement basis, and sponsors are typically federal agencies.

Sponsored Project Contract (cost-reimbursable or fixed price)◦ Legally binding agreement that consists of promises made by each party, including a Scope of Work

usually driven by the sponsor, rather than proposed by the PI/Project Director.◦ The agreement is mutually beneficial, where the sponsor’s support is with the expectation of directly

benefiting from its results. ◦ Results include research reports/publications and tangible items, such as data sets, software, or

fabricated equipment.

Rules & Regulations Each type of sponsored project follows a number of rules and regulations:◦ Federal: Office of Management & Budget (OMB) Circulars (Guidance 2 CFR

200)◦ Sponsor specific guidelines◦ BSU Policies◦ Award-specific Terms & Conditions

Rules & Regulations General concepts for charging to sponsored projects:

◦ Costs must be◦ Allowable: during the funding period, applied uniformly across the university, and supported by policy◦ Allocable: specifically benefits the project, and are distributed between benefiting projects/awards◦ Reasonable: prudent person test, necessary for the award, and meets generally accepted business

processes◦ Certain costs require prior approval

◦ Include in the approved budget = prior approval◦ If not in the approved budget, request must be submitted to the sponsor◦ Could include: foreign travel, equipment, participant support costs, or subawards

◦ Certain costs are unallowable◦ Some include: fundraising/lobbying, entertainment (unless pre-approved), fines/penalties, and those

specifically stated by the sponsor’s guidelines or terms/conditions

Post-Award Process1. Funded – great! Share all award documents with SPA. In some cases, SPA is contacted directly

2. SPA Compliance Operations will review the award documents to determine whether or not a contract is included or required, as well as any required subrecipient agreements.

3. If a contract is required, SPA’s Contract Compliance Analyst (Ted Kolodka) and BSU’s Contracts & Grants Attorney (Carol Clendening) will work on reviewing the document and interacting with the sponsor on any concerns prior to sending to Business Affairs for signature.

4. Once the agreement is finalized, SPA continues the account opening process, with the Associate Director of Compliance Operations (Sheila Shafer) reviewing the award documents.

5. Next, the Associate Director for Post-Award Operations (Matt Moore) assigns the award to a Grant Manager, who requests the Banner Fund code and contacts the PI, their Chair, and Administrative Coordinator to discuss the award, budget, dates, and important terms & conditions.

Post-Award Processes: Making ExpensesSalaries

Assigned time and summer/supplemental pay-Grant Manager does the EPAFIf you need to hire someone (staff, students, GA’s)-follow your department’s policy (Please include the

Grant Manager as an approver on the EPAF)

SuppliesCharge items directly to the grant accountsMost preferred method- order through Sci-Quest

TravelBe sure travel authorization is completed and approved (include the Grant Manager) before the travel

occurs

Contractual-talk to your Grant Manager

Strategies for Managing your Award

Read the documents forwarded by your Grant Manager, including◦ Account information◦ start/end dates◦ Highlighted terms & conditions◦ Budget, including spending restrictions or prior approvals◦ Award document

Budget considerations as you make expenditures:◦ If actual expenses are different than those budgeted, might there be a scope

of work change required?◦ Do the award documents require approvals for % changes in budget category

spending?

Audit Considerations What do Auditors Look For?

◦ Salaries: ◦ Is everyone being charged doing the work – at least at the budgeted effort?

◦ Supplies◦ Do the purchased supplies support the scope of work funded by the specific project?◦ If costs are shared between projects (funded or otherwise) are they allocated appropriately?

◦ “Spending Down”◦ Try to ensure consistent spending throughout the project: high volumes of spending in the last 90

days are a red flag.◦ High dollar purchases in the last 90 days are a concern: How do these benefits the project so late in

the project period?

Special Considerations Period of Performance:

◦ Expenses must occur within the start and end dates◦ Early Account Form is a good option if:

◦ You need to start 90 days prior to the start of the award (if allowed)◦ There are paperwork delays with the sponsor in finalizing the award. ◦ Check w/SPA if need – requires chair approval and a back-up account for charges if funding falls

through◦ Expenses may be charged after the end date, but cannot be incurred after the

end date.◦ Final reports are typically required 30-120 days after the end date.

Special Considerations (cont.) Considerations for awards expiring within 90 days

◦ If a large balance is available, please consider:◦ Have all the costs been charged to the correct grant fund?◦ Did the project cost much less than anticipated? Could their might be an option to expand the scope of work with

the sponsor?◦ The work might not be close to being completed – and a No Cost Extension (NCE) should be requested. These are

often required at least 30 days prior to the end of the award.◦ NCEs

◦ SPA can, with some sponsor, internally authorize a NCE – or we might have to contact the sponsor.◦ Consider:

◦ Request must be work driven◦ Asking for NCE to spend down funds only is never a valid reason◦ What is your justification? How does the use of the remaining funds help to accomplish the specific aims of the

grant?

Special Considerations (cont.) Cost Transfers: Costs should be charged to the appropriate account at the time an expense is incurred.

◦ Red flags:◦ Frequency of transfer requests from a particular individual or unit ◦ Late cost transfers (greater than 90 days after the cost was first incurred) ◦ Transfers onto awards in the last 90 days of the period of performance

Don’t forget the (new) BSU Policy on Reimbursed Expenses. ◦ Requests for reimbursements must be placed within 60 days of the expense, including travel, personal

purchases, etc.

Need to use the departmental purchasing card for specific purchases? Just ask! Touch base with your Grant Manager in advance of purchases.

Questions?

Matthew MooreAssociate Director, Post-Award Sponsored Projects Administrationmjmoore@bsu.edu