After grant application is approved for funding, a “Grant Award” letter or notice is ordinarily issued by the sponsor to the Principal Investigator. At the time an award is received, the following procedures are to be followed:
- Upon receiving an award letter, the Principal Investigator is responsible to immediately provide the Office of Research Services (ORS) with a complete set of all award documents, including any agreements or contracts the need official University signatures.
- The ORS will carefully review the documents; execute any accompanying contracts or agreements; complete a formal Notification of Award, summarizing the terms and conditions of the award; and code the agency approved budget for execution by the Principal Investigator. With the endorsement of the ORS Director, the Notification of Award authorizes the establishment of an SJU grant fund. A copy of the award notification will be forwarded to the Principal Investigator, the Department Chair, and the Dean of the School.
- When the approved budget has been entered into the University financial system, the Principal Investigator will be responsible for the following:
1. Executing the project in a timely manner that assures completion of the grant supported activity and related spending by the award termination date.
2. Preparing all technical reports to meet deadlines prescribed by the sponsor, and provide the ORS with copies of all technical reports.
3. Requesting no costs extensions. Request to the sponsor for a no-cost extension of the award period should be processed through the ORS in accordance with sponsor guidelines or no less than eight weeks prior to the award termination date.
After entering the award budget in the financial system, the Office of Research Services will be responsible for the following:
A. Implementing procedures for monitoring grant fiscal activity to ensure all grant spending is in keeping with the approved budget and the terms and conditions of the award.
B. Expediting invoicing/billing, fiscal and other reporting in accordance with OMB standards of fiscal accountability and in compliance with terms and conditions of funding.
C. Preparing and maintaining quarterly time and effort reports for each grant funded salary.
All payroll authorization forms for employees who will receive salary under a grant award or contract must be endorsed by the Office of Research Services. The availability of funds and allowability of costs for salary and wages of grant funded personnel require approval by the Office of Research Services. The University personnel policy should be followed when hiring a new employee. Project related staffing should be discussed with the Human Resources office.
Many of the federal programs involving educational institutions will require contributions from non-federal sources. This is known as “matching” or “cost sharing”. The most important source of information about how non-federal cost shares are to be treated is OMB Circular A-110.
The Principal Investigator must report to the Office of Research Services, with accompanying documentation, all cost sharing or in-kind matching obligated to the grant. Authorization for institutional matching must be documented on the Routing Form at the time the proposal is submitted for review by the ORS. The Approval for Matching Funds/Cost Share Form with original signatures must be on file in the ORS. All matching and cost sharing resources must meet the following criteria:
1. They must be verifiable from the recipient’s accounting records;
2. They may not be included as contributions for any other federally assisted project or program in either the current or any prior period;
3. They must be necessary and reasonable for proper and efficient accomplishment of project or program objectives;
4. They must be allowable under the applicable cost principles (OMB Circular A-21_. This is true even if the asset is derived from a third party contribution. Therefore, a matching contribution must be for something which the organization or institution could have spent federal funds;
5. They may not be paid by the federal government under another award except when authorized by the federal agency; and
6. They must be designated in an approved federal budget.
A. Cost sharing and matching with cash outlays is fairly simple. The university must be able to show that outlay from non-federal sources benefited the funded project, and that the funds used were not from federal money.
B. Third party in-kind contribution is more complicated. The rule associated with in-kind contributions is that the university may assert a value based on the current fair market value of the service or asset provided. The following are some standard in-kind contribution.
7. Volunteer Services - are services furnished by various persons to the project are valued according to the rates that are consistent with those paid for similar work at the university. This would not only include the salary but also the fringe benefits.
8. Donated supplies - the valuation of supplies is based on the fair market value of those supplies that were received.
9. Donated equipment - used in support of the project only depreciation for those assets may be used as cost sharing or matching.
10. Donated space - is donated for use to a particular project must not be owned by the grantee’s institution. The title of the space must be a third party owner.
Because of the potential audit vulnerability that an institution faces in the area of cost sharing and matching, it is critical that effective documentation be developed.
Program income can be defined as “income that is directly generated by an award.” Program income can include the following:
A. Income from fees and services performed;
B. The use or rental of real or personal property acquired under federally funded projects;
C. The sale of commodities or items fabricated under an award;
D. License fees and royalties on patents and copyrights; and
E. Interest on loans made with award funds.
The federal government has had a long standing policy that program income constitutes grant assets. Therefore, program income is to be used in accordance with the terms and conditions of the award. There are three options available for the use of program income:
1. Expand the scope of the project over and above the approved project budget.
2. Meet the requirements of cost sharing or matching.
3. Used to reduce the federal share of the project. Known as the deductive alternative.
The federal government prefers the deductive alternative, but most institutions prefer to expand the scope of the project. There are limits to the amount of income that can be used to add to the budget of the project. The federal government allows a maximum of $25,000 to be added to the project budget. Income over the $25,000 limit must be used to reduce the federal share of the project.
It is the responsibility of the Principal Investigator to monitor all expenditures to assure compliance with the award notification. As a double measure of protection the Office of Research Services also has the ultimate responsibility of assuring compliance with the grant award.
It is the policy of the university that all expenditures of grant funds must meet the following standards:
1. Must be for official university business only.
2. Are reasonable under the guidelines of the specific program or project.
3. Must contribute to the objectives of the specific program or project which they are being charged.
Please refer to the policy on Allowable Cost and Cost Principles for additional guidance.
Below is a list of common unallowable costs. For a full list please go here.
1. Any item for personal use.
2. Personal gifts of any kind.
3. Fees for any sporting event.
4. Political contributions.
5. Contributions to charitable organizations.
6. Donations to attend an event.
7. Membership or dues to a society, association, or organization unless specifically serving the need of the program or project.
8. Alcoholic beverages.
For additional guidance please see the policy on Unallowable Costs.
Prior to the termination of a grant the principal investigator should review the grant for available funds, deficit balances, accuracy of the expenditures and outstanding encumbrances. All requisitions must be submitted to the Office of Research Services before or by the termination date. If an extension of the grant beyond the ending date is needed, a written request should be submitted to the funding agency through the ORS, six to eight weeks before the termination date.
Generally all sponsors require a final, comprehensive report on completion of a project. Most sponsoring agencies require a final report prior to sending of the final payment. Therefore, undue delay in submission of the final report may cause the University’s image with the sponsor to be damaged and threaten any chance of receiving future funding.
It is the responsibility of the Principal Investigator to compete the final project report if required. The Office of Research Services is responsible for submitting any final financial reporting requirements.
Internal Prior Approval System Requirements
All requests for modifications to grants, contracts, or agreements are processed through the Office of Research Services (ORS).
The extent of permissible budget reallocation varies widely from sponsor to sponsor. Certain budgeted transfers may be accomplished using the established University prior approval system, whereas other budget transfers will involve agency approval. In all cases, authorization to deviate from the award budget must be approved prior to the expenditure, not after. Consult the ORS with specific issues.
a. A Project Change Form should be completed and submitted to the ORS for any changes to a sponsored project.
b. The nature of the request, i.e., budget reallocation, no cost extension, change of PI should be checked.
c. A detailed justification for the change(s) should be stated.
d. After review by the ORS, if the request can be approved internally, it will be endorsed by the ORS Director and processed.
e. If sponsor approval is required, a written request to the sponsor for approval of changes to approved budgets, personnel, project timelines or other project needs should be forwarded to the sponsor through the ORS. The requests should include a detailed statement of justification and a copy of the revised budget when appropriate. When written approval is received from the sponsor, the ORS Director will endorse budget reallocation form and process.
Effort Reporting Guidelines
What is Effort Reporting?
Effort reporting is a method of documenting the chares of personal services. OMB Circular A-21 requires that this documentation reflect the activity for which an employee is compensated. It also must recognize the principal of after-the-fact confirmation so that salary distributed represents actual cost, hence the term effort reporting.
OMB Circular A-21 requires that each institution maintain an acceptable effort reporting system. The purpose of this system is to provide a reasonable basis for distributing salary charges among direct activities, such as sponsored research and administration.
Effort reporting is done on an individual basis. The following must be certified:
A. The allocation of effort is appropriate and reasonable.
B. The distribution of effort is consistent with what was proposed.
C. The work was performed.
The effort report must show all effort for which the University compensates an individual. This includes sponsored research, instruction, and administration. It does not include compensation from and outside institution, such as consulting work.
Allocations of effort among different activities must be made on a reasonable, equitable, and consistent basis.
If a faculty member has effort on a sponsored research project but does not charge the project for all (or any) of his or her salary for the effort, the entire effort must still be allocated to the project. The unfunded effort is generally considered cost sharing and must be recorded under the section of “Unfunded Activity”.
For example, if a faculty member expends 50% of his or her total effort on a sponsored project, but the sponsor is charged on 25% of salary, then 25% effort should be shown for the project, with an additional 25% recorded as unfunded activity.
Responsibility for Accurate Reporting
The effort reports will be calculated electronically based on actual salary allocated. This will ensure the effort report reflects actual effort expended in the various categories for the reporting period. The effort report will require the signature of the employee for who the report is for.