Roles and Responsibilities in the Administration of Grants at UMSL

Roles and Responsibilities in the Administration of Grants

at UMSL

University of Missouri Policies & Procedures

Responsible Parties

• Principal Investigator (PI/Co-PI)

Named by sponsor on award document with overall responsibility to manage the award.

• Department Administrator (Dept Admin)

Individual in the department assisting PI with the fiscal management of an award.

• Office of Research Administration (ORA)

Campus office monitoring compliance with applicable regulations, policies, and terms and conditions of the award.

See Business Policy Manual, BPM 210 Sponsored Programs

High Level Roles & Responsibilities

Principal Investigator

The University of Missouri assigns primary responsibility for fiscal management to the Principal Investigator (PI), which is in the spirit of both federal regulations, individual sponsor guidelines, and university policies and procedures.

Per current UM System policies, PIs are responsible for:

All expenditures made against a sponsored project

Knowing and adhering to the specific limitations and restrictions of the sponsor and of the award documents

Knowing and adhering to all administrative and financial compliance requirements of sponsors, regulators and the University

Department Administrators are responsible for:

Providing support to PIs in the administration of awards

Knowing and adhering to all administrative and financial compliance requirements of sponsors, regulators and the university


Department Administrator

The Office of Research Administration (ORA) is responsible for:

Reviewing proposals to ensure they meet agency requirements before submission

• Overall budget within the guidelines

• Risk-assessment if budget exceeds $3 million

• Evaluation of sources of cost share, if any

Overseeing regulatory compliance of proposals

• IRB, IACUC, conflict of interest, and export control compliance

Ensuring fiscal compliance with sponsor and University policies and procedures (e.g., financial reporting, milestone tracking, invoicing)


ORA

Roles & Responsibilitiesin Proposal Development and Submission

(Pre-award)

Development of proposal• Proposal narrative, scope of work

• Financial budget and justifications

• Approvals – Proposal Signature Routing Sheet, PSRS (aka, signature page)

• Refer to ORA website for institutional information

Proposal Submission to the ORA• Minimum of two weeks prior to deadline• Extra week if budget is above $3 million

ORA reviews and submits – PI does not submit

directly

Roles & Responsibilities

Principal Investigator< General Pre-Award Responsibilities >

The PI’s general responsibilities in proposal development include the following:

Ensure sponsor requirements and guidelines are met

• Forms• Unique allowability restrictions• Submission deadline

Compliance with University policies• Accounting Policy Manual (APM) – Section 60• Business Policy Manual (BPM) – Section 210


Principal Investigator< Pre-Award Responsibilities: Proposal Development >

Allowable direct costs per A-21 and sponsor• Reasonable• Allocable• Consistent treatment• Conform to limitations or exclusions of sponsor

Justify any unlike circumstances

Reasonableness of effort commitment• Evaluate with existing commitments


Principal Investigator< Pre-Award Responsibilities: Budget >

Use of subawards• Include in budget and scope of work• Properly identified• Subject to same compliance requirements• Obtain letter of commitment and budget from

sub-awardee grants office

Use appropriate F&A rate• Approval required for any waivers from VPR

(rarely approved)



Cost sharing requirements

• Cost share should be included only when required or suggested

• Must be an allowable direct cost

• Committed cost share must be approved

• Evaluate for reasonableness

• Ensure all cost sharing is clearly identified – direct or implied

• If award is received, all committed cost share must be allocated and documented appropriately



Conflict of Interest disclosures

Human Subjects – Institutional Review Board (IRB)

Institutional Animal Care and Use Committee (IACUC)

Export Control regulations

Intellectual property potential

Responsible conduct of research training


Principal Investigator< Pre-Award Responsibilities: Compliance >

The Department Administrator:

Assists with review of proposal for compliance

Reviews budget for allowable costs• Identifies need to justify unlike circumstances

Ensures PSRS is signed by appropriate individuals


Department Administrator< Pre-Award Responsibilities: Proposal Development >

Before submission, the ORA reviews for: Compliance with submission requirements

Proposal budget calculations

Allowable costs and budget justification

Risk assessment if budget is over $3 million

Appropriate approvals on the PSRS• The ORA obtains institutional endorsement

The ORA is responsible for formally submitting the proposal.


ORA< Pre-Award Responsibilities: Review & Submission >

The PI evaluates need for a Pre-Award Project Account and submits a request to the ORA

Criteria to establish an account prior to award:

• Proposal must be under review

• PI, Department Head and/or Dean guarantee costs

• Justification to begin work before award receipt

• Other approvals required (e.g., human subject)


Project Establishment

The ORA monitors Pre-Award Projects that are:

• Older than 90 days (discusses status with PI)

• Older than 6 months (determines appropriate action)

Upon award execution, the ORA:

• Changes status from Pre-Award to Awarded

• Reviews pre-award projects to ensure spending is properly reflected


Project Monitoring

Roles & ResponsibilitiesAccepting & Establishing an Award

for Sponsored Programs

(Post-Award)

Upon receipt of the Notice of Grant Award (NGA), the PI:

Notifies all appropriate individuals (e.g., ORA, sub-awardees, CoPIs, Dept Administrator)

Determines whether to accept award

Reviews and approves the NGA

Creates a revised budget if necessary

Conducts technical and programmatic negotiations


Principal Investigator< Post-Award Responsibilities: General >

Once award is fully executed, the PI: Delegates authorization to:

• Dept administrator or other applicable persons who are university employees with direct knowledge of the award and related compliance requirements

Determines payroll distribution

Identifies non-owned assets/equipment in the award

Reviews expenditures posted to the grant on monthly basis

The PI has overall responsibility to manage the award.


Principal Investigator< Post-Award Responsibilities: General >

The PI ensures regulatory requirements are in place: Conflict of Interest disclosures

Human Subjects – Institutional Review Board (IRB)

Institutional Animal Care and Use Committee (IACUC)

Export Control regulations

Intellectual Property

Responsible Conduct of Research training


Principal Investigator< Post-Award Responsibilities: Regulatory >

Upon receipt of the NGA, the Department Administrator assists with:

Notifying all appropriate individuals

Creating a revised budget if needed

When the fully executed award is established, the Dept Admin:

Verifies the budget information in the financial system

Sets up payroll distributions

Ensures award funded non-owned assets/equipment are identified

Reviews expenditures on monthly basis and issues reports to the PI as deemed necessary


Department Administrator< Post-Award Responsibilities: General >

Upon receipt of the NGA, the ORA reviews for: Award consistency with proposal

Compliance with University policies

PI approval and acceptance of NGA

Completion of regulatory approvals


ORA< Post-Award Responsibilities: General >

Before award acceptance, the ORA:

Conducts fiscal, business, and legal negotiations

Notifies sponsor of changes in:• Project scope• Budget• Cost sharing• Facilities and Administrative (F&A) rate• Other legal clauses• Other changes at PI‘s direction



After award is fully executed, the ORA: Notifies appropriate individuals

Establishes award in the financial system including• Project ChartField string

• Budget information

• Subawards

• Cost sharing commitments

• Catalog of Federal Domestic Assistance (CFDA) and Schedule of Expenditures of Federal Awards (SEFA) cluster

• Billing information

• Milestones for report due dates

Ensures award funded non-owned assets/equipment are identified and tracked



Roles & ResponsibilitiesAllowable Costs: A-21

Effort Verification Reporting (EVR)

Cost Sharing

General

Cost Transfers and PCEs


A-21: Allowable Costs


EVR


Cost Sharing

Activity PI Dept Admin

Overall Compliance Responsibility XAttend Compliance Training X XAdministrative Financial Management X XMonthly Mangerial Review X XAllowable Costs X XDocumentation to Support Costs X


General


Cost Transfers & PCEs

Roles & ResponsibilitiesClosing Sponsored Awards

Ensures all costs charged to award are: • Allowable• Within period of availability• Documented

Identifies outstanding charges• P-card• Feeder systems (e.g. telecommunication)

Clears deficits

Ensures cost transfers are made timely


Principal Investigator< Closing Sponsored Awards: Final Review >

Ensures compliance requirements are met for: Committed Effort - PI and key individuals

• Example: PI - 25% reduction in effort or 3 month absence

• Significant changes of key individuals

Subawards – final invoices and deliverables received

Cost sharing commitments• Mandatory and voluntary• Changes in category of cost share from award

Other requirements per award agreement• Program income



Evaluates need for no-cost time extension

Completes PI Certification• Signifies all costs are allowable per A-21 and/or

sponsor

Submits technical and programmatic reports• Reporting period will vary by sponsor

Provides intellectual property notices



Updates payroll distribution (PAFs)

Cancels P-cards and feeder systems

Retains documents for required period• PI retains scientific data• Department retains transactional data

Returns non-University owned assets to sponsor


Principal Investigator< Closing Sponsored Awards: Administrative >

Assists PI in closing of award: Ensuring costs are allowable and documented

Timely addressing items such as:• Cost transfers, Payroll Correcting Entries (PCEs)• Updating payroll distribution (PAFs)• Cancelling P-cards and feeder systems• Closing purchase orders, open encumbrances• Returning non-University owned assets to sponsor


Department Administrator< Closing Sponsored Awards >

Works with unit to close out award

Conducts high-level compliance review to ensure:

• Terms and conditions met• Subaward invoices received and paid• Deficits cleared• Technical report completed• Reasonableness of cost transfers • Costs are allowable and inline with budget


ORA< Closing Sponsored Awards: Final Review >

Submits final invoice to sponsor• Excess funds de-obligated• Reconciliation of program income

Documentation for permanent file• Proposal, Award, EVRs, invoices, programmatic, technical

and financial reports, sub-award documentation, etc.

Confirms non-owned assets/equipment returned to sponsor

Completes transfers on fixed-price contracts

Inactivates project in financial system

Submits final financial report to sponsor


ORA< Closing Sponsored Awards: Administrative >

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MORE INFOOffice of Research Administration

www.umsl.edu/services/ora

314-516-5899

http://www.umsl.edu/services/ora

Documents

Roles and Responsibilities in the Administration of Grants at UMSL