Award Management Process
Award management occurs after the grants, contracts or cooperative agreements have been set up in our financial system (IRIS). Award Management includes policies and procedures of the university, school, and sponsor to ensure compliance with the award's terms and conditions, often referred to as the post-award phase of the award life cycle.
Proper management of sponsored programs is crucial to maintaining public trust in research outcomes. Our Sponsored Program Analyst(s) undertake the analysis and interpretation of agreements and associated documents for new sponsored projects. This ensures an accurately structured setup to meet billing and reporting requirements and coded correctly to facilitate accurate financial reporting. Furthermore, our analysts ensure that the sponsored projects comply with the university and sponsor parameters.
The success of a sponsored project is contingent on both the ability of the PI(s) and department administrators to follow through the project and the Office of Sponsored Programs to ensure proper stewardship of the awarded funds. To successfully manage an award and be compliant, the PI and department administrator need to:
- Ensure personnel on the project understand their responsibilities.
- Abide by the terms and conditions of the award, such as approved scope of work and budget, required prior approvals, reporting, and publication rights.
- Understand the sponsor’s and university’s policies and work with the Office of Sponsored Programs for guidance.
- Use Cayuse to route sub-award documents to other institutions.
- If the award is funded under multi-campus, provide an approved internal budget to create an internal award notification for the child account.
- Ensure that charges to grants benefit the award. It is inappropriate to average the costs of research supplies across all the principal investigator’s grants, without considering supply usage. The costs charged to a sponsored project must be necessary, reasonable, and allowable. The University audits are to ensure consistent treatment of similar costs across the institution.
- Items included in our indirect cost base cannot charge directly to the award under direct cost. However, there may be exceptions with prior approval within the proposal application.
ACCOUNT SET-UP
Sponsored program accounts creation occurs upon receipt of a fully executed contract
or award letter from a sponsor. Sponsored Programs will set up new or modify advanced
or existing accounts. We will ensure compliance with federal, state, and university
rules and regulations by creating a settlement rule, if applicable, and accurately
complete the budget entries. We will review line-item variances between budgets and
actual expenditures to prevent any non-compliance with the sponsor's regulations.
Under multi-campus funding, each campus is responsible for setting up their child account under the primary campus’ account. Assignment of the child account is to the responsible PI affiliated with the internal award. The child account’s Sponsored Programs office is responsible for managing and tracking the budget and expenditures to ensure compliance with the primary award. All financial reporting and invoicing for both accounts is the responsibility of the primary campus.
After account creation and release, the IRIS system will generate an automatic e-mail sent to the PI and the Department Administrator on the project alerting them of the WBS account number.
Under multi-campus funding, each campus is responsible for setting up their child account under the primary campus’ account. Assignment of the child account is to the responsible PI affiliated with the internal award. The child account’s Sponsored Programs office is responsible for managing and tracking the budget and expenditures to ensure compliance with the primary award. All financial reporting and invoicing for both accounts is the responsibility of the primary campus.
After account creation and release, the IRIS system will generate an automatic e-mail sent to the PI and the Department Administrator on the project alerting them of the WBS account number.
ADVANCE ACCOUNT
An advance account provides PIs an opportunity to initiate an activity and begin incurring
associated expenses prior to institutional acceptance of an award. Limit an advanced
account to when there is reasonable evidence from a sponsor that an award is imminent
(e.g., notification from sponsor). Approval from the department head and Dean is necessary
to incur program expenses prior to receiving an award due to the added risk.
Advance accounts requested prior to the university’s receipt and acceptance of a sponsored award allows the department the ability to incur allowable costs to an appropriate account, reducing the need for cost transfers upon award acceptance. All expenses on an advance account are “at risk” with the department assuming all responsibility.
To request an advance account, please submit an Advance Account request form . The sponsor must provide adequate documentation to demonstrate a negotiating agreement is in process.
Note: The process may delay, if the funds contain PHS, DHHS, or NIH funding either direct or indirectly, until we receive official confirmation that the Financial Conflict of Interest (FCOI) compliance has been satisfied.
Advance accounts requested prior to the university’s receipt and acceptance of a sponsored award allows the department the ability to incur allowable costs to an appropriate account, reducing the need for cost transfers upon award acceptance. All expenses on an advance account are “at risk” with the department assuming all responsibility.
To request an advance account, please submit an Advance Account request form . The sponsor must provide adequate documentation to demonstrate a negotiating agreement is in process.
Note: The process may delay, if the funds contain PHS, DHHS, or NIH funding either direct or indirectly, until we receive official confirmation that the Financial Conflict of Interest (FCOI) compliance has been satisfied.
REBUDGETING
Rebudgeting is the transfer of funds from one budget line to another. The budget is
the financial expression of the project or program as approved during the award process.
If the original project budget does not reflect the current spending plan for the
sponsored project, the PI and/or Department Administrator should review the project
award terms and conditions to determine the appropriate process for requesting changes
to the awarded budget.
The University has a certain degree of latitude to rebudgeting within and between budget categories to meet unanticipated needs and to make other types of post-award changes. Changes occur at the University’s discretion if they are within the limits established by the sponsor. For certain budget modifications or activities, you will need to obtain written permission before proceeding.
Informal rebudgeting occurs when actual expenditures exceed or fall short of the allocated amount budgeted in a GL code or when actual expenditures occur in a GL code that has no budget allocation. If no prior approval is necessary, then formal rebudgeting is not necessary but requested to assist in budget management.
Note: Rebudgeting may affect Facilities and Administrative (F&A) Costs.
To request rebudgeting of funds on an award or contract agreement:
The University has a certain degree of latitude to rebudgeting within and between budget categories to meet unanticipated needs and to make other types of post-award changes. Changes occur at the University’s discretion if they are within the limits established by the sponsor. For certain budget modifications or activities, you will need to obtain written permission before proceeding.
Informal rebudgeting occurs when actual expenditures exceed or fall short of the allocated amount budgeted in a GL code or when actual expenditures occur in a GL code that has no budget allocation. If no prior approval is necessary, then formal rebudgeting is not necessary but requested to assist in budget management.
Note: Rebudgeting may affect Facilities and Administrative (F&A) Costs.
To request rebudgeting of funds on an award or contract agreement:
- Determine if the sponsor of the award allows rebudgeting and whether prior approval is necessary. Note: If the sponsor requires prior approval for rebudgeting that exceeds a certain percentage of the budget, you must monitor all budget reallocation to ensure not to exceed this limit when multiple rebudgeting occurs in a single budget period. According to NIH, significant rebudgeting takes place 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.
- If sponsor approval is necessary:
- Forward an official request letter with detailed justification for the proposed change and a R&R budget form with justification to the Office of Sponsored Programs
- If the sponsor does not require prior approval for rebudgeting:
- Complete the Budget reallocation form and email it to the assigned Sponsored Program Analyst (SPA) in the Office of Sponsored Programs.
OSP responsibilities:
- The assigned SP Analyst will review the rebudgeting request to determine if it is allowable, based on sponsor regulations or contractual agreements in the award documents.
- If prior sponsor approval is necessary, OSP’s Associate Vice Chancellor for Research will submit the documentation to the sponsor.
- The assigned SP Analyst will notify the department about the status of the request.
COST TRANSFERS
A cost transfer is a reallocation of costs after the initial transaction has occurred.
Cost transfers occur in the regular course of business for two reasons: (1) to properly
allocate multi-business unit expenses, and (2) to correct clerical or bookkeeping
errors. Cost transfers are not appropriate for (1) spending out an unused award budget,
(2) covering cost overruns, (3) avoiding restrictions imposed by law or other agreements,
or (4) other reasons of convenience.
Federal regulations stipulate that appropriate justification and documentation for
all correcting entries (CE). Sufficient documentation includes the following: (1)
justification as to why the transfer is necessary; (2) that the charge is allowable
and allocable, directly benefits the award, and is within the period of availability;
(3) that appropriate approvals are secured; and (4) in the case of error, how the
error will be avoided in the future.
Inappropriate transfers could result in the disallowance of certain expenditures and/or
a reduction in funding from the sponsoring agency. Inappropriate transfers could also
jeopardize the reputation of the University and result in fines and sanctions.
The shifting of previously incurred costs from one account to another, i.e., Cost
Transfers, continues to be one of the top audit risks for sponsored awards and is
frequently cited in financial audits of Higher Education institutions across the nation.
Below are the policy links to review the Cost Transfer Policy and Cost Transfer Explanation
Form. The policy will assist preparers and approvers with the tools necessary to identify
the elements critically important for their cost transfer submission and how to properly
document and justify the transfer of an expense to a sponsored award.
COST SHARING
The expectation is that the sponsor would cover the costs incurred in conducting the
proposed project. However, there may be times that requires the University by law,
sponsor guidelines, or may voluntarily commit to share in the total cost of conducting
work under a sponsored award. This is known as cost sharing or matching. Cost sharing
defines as a portion of the total sponsored award costs provided by someone other
than the sponsor—usually represented by university funds or third-party commitments.
OMB Uniform Guidance (“Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards”) provides guidance on what costs considered as cost
sharing.
There are three main types of cost share: (1) mandatory, (2) voluntary committed,
and (3) voluntary uncommitted.
Mandatory cost share defines as a contribution required by the sponsor as a condition of obtaining the
award. These funds require tracking and reporting by the University.
Voluntary committed cost share is not a requisite by the sponsor but occurs when a proposal submission in which
the budget or budget justification/narrative quantifies or implies a financial contribution
to the project by the university. These funds require tracking and reporting in a
comparable manner to mandatory cost share.
Voluntary uncommitted cost share is a contribution to a sponsored award that is neither required by the sponsor nor
implied in the proposal. These funds do not require tracking or reporting to the sponsor.
If cost share requirements fail to meet expectations, the sponsoring agency may require
that we return sponsor funds. Additionally, failure to meet our cost share requirements
results in non-compliance with our award agreement, the Uniform Guidance, and university
policy.
Cost Sharing Policy
Uniform Guidance 200