Award Management - G01

Purpose

Award Management is a process that encompasses Sponsor and University policies and procedures pertinent to the project. It is referred to as the “post award” phase of the life cycle of an award. Sound monitoring of sponsored funds is critical in maintaining the public trust in research results and outcomes, its trust as research participants, and its trust in how public and private funds are spent.

Scope

This procedure applies to all sponsored projects subject to OU Policy 19.045 Administering External Grants and Contracts set up as separate accounts in the OHIO Financial Management System (FMS).

Procedure 

Once awarded funding for your project; here’s what you need to know to manage it successfully:

• Ensure that your research/program staff are cognizant of their responsibilities and those of the University’s administrative offices.
• Abide by the key terms and conditions of your award, such as the approved scope of work and budget, required prior approvals, reporting, payment, equipment ownership, and publication rights.
• Know and work within your Sponsor’s rules and regulations and the University’s research and business policies, guidance, and procedures.

General Guidance on the Management of Sponsored Project Funds

Review your award budget in OBI at the outset of the project and immediately notify Office of Research and Sponsored Projects (ORSP) if changes are required. Review of ongoing expenditures should occur at least monthly to ensure proper allocation of funds in accordance with the approved budget and budget justification. Do not wait until the annual report or close out to examine your account balance. This achieves the following:

• Ensures that costs are consistent with the project schedule and incurred between the start and end dates of the project.
• Allows you to discover any errors in your budget, encumbrances, or expenditures. Errors can be caused by the department, an end user, a data entry error, or a system-generated issue (something does not post because it failed a system check). The longer an error remains 
  uncorrected, the harder it is to show that allowability and allocability. All university departments with grants must also follow our cost transfer or correction process in compliance with Uniform Guidance (reminder: all payroll and accounting corrections must be done within 90 days).
• Avoids overspending, which may cause a deficit and limit further spending or require a department to absorb the over-expenditure into their unrestricted funds.
• Verifies that corrections and cost transfers have been made or are made in a timely manner and in accordance with Uniform Guidance (within 90 days).
• Maintains good audit documentation should an audit occur for the grant.

Equipment purchased with federal funds requires advance coordination with Ohio's Purchasing Office in order to meet the Uniform Guidance purchasing standards.

The following transaction types are frequently cited by Auditors as higher risk practices. Should you have any questions please contact your Grants Accountant. 

• Equipment purchases at the end of a project period; 
• Equipment purchases on multiple awards without a sound cost allocation methodology;
• Travel expenses incurred by individuals who are not paid by the award;
• Personal travel costs before or after the business purpose of a trip;
• Foreign travel not previously included in an approved budget;
• Expenses charges to 'spend down' an award; 
• Re-certification of Effort Certification Report(s);
• Expenses charged to award after period of performance; 
• Cost Transfers

Direct Charging

In accepting federal funds for sponsored projects Ohio University agrees to abide by government regulations regarding the use of those funds. Direct costs are those costs that can be identified specifically with a particular sponsored project, or that can be directly assigned to such activity relatively easily with a high degree of accuracy. In general, these costs fall into broad categories such as effort, materials, travel, equipment, etc. Direct cost items should be necessary, and essential for project success. The items and/or services charged must reflect the amount that a reasonable person would pay and must be directly allocable to the needs and purposes of the project. These charges also need to be determined in accordance with generally accepted accounting principles (GAAP) and not included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. The cost must also be adequately documented.

Direct Charging follows the Office of Management and Budget (OMB) Uniform Guidance for any Notice of Award issued to Ohio University on or after December 26, 2014. 

Allocability of Costs - Publication Costs

Publication costs must be allocated to all Ohio active awards cited in the publication on the assumption that the cited awards contributed to and benefitted from the publication. Otherwise, any Ohio awards not contributing to or benefiting from the publication should not be cited or be charged for publication costs. It may not always be appropriate to charge publication costs to a single Ohio award when other active Ohio awards are cited in the publication. Be sure to evaluate the contributions of each award and support all cost allocations with a well-documented cost allocation methodology.

End of Award Expenditures

It can be difficult to demonstrate how expenditures near the end of a project period benefited the award in a limited amount of time. All purchases incurred within the last 30 days of a project period should be reviewed to:

• Ensure the item/service was received during the project period; and
• Determine how the item/service provided benefit during the project period, given that it was purchased close to the applicable end date. Providing benefit means having a reasonable amount of use during the project period. 

End of Award Equipment Expenditures

In addition to the above, it is recommended that equipment expenditures near the end of the project 
period should be reviewed to determine:

• If the equipment was included in the original budget proposal. Include this information with the purchase documentation. If the equipment was identified but not purchased until the end of the award, document how the equipment benefited from the award given the limited amount of time left on the award. Failure to do this could make this cost unallowable by the sponsor.
• If the equipment was not included in the original budget proposal, determine and document how it benefited the award, given the limited time remaining.
• If Sponsor approval, as required, was obtained for the purchase of the equipment, document that the approval was received in the purchase documentation (documentation must be directly from the sponsor approving this). 
• If the equipment will not be used exclusively for this award, document how the cost was allocated to other funding sources.
• If applicable, document why the purchase was necessary when the proposal indicated that the project had access to necessary equipment and/or facilities.
• If the equipment was purchased to replace existing equipment, provide details of the equipment being replaced and ensure that this is an allowable expense on the award. 

Cash Management

The Grants Accounting team manages the cash-related activities of Ohio’s sponsored projects. The goal is to maintain appropriate levels of cash flow for Ohio’s sponsored projects while ensuring financial compliance with Federal regulations, sponsor requirements, and University policies.

Essential responsibilities include:

• Process Letter-of-Credit (LOC) cash draws and web-based invoicing for Federal awards.
• Prepare and file the quarterly Federal Financial Report (FFR) for the LOC awards, and perform funding, cash, and expenditure reconciliations.
• Process installment or cost reimbursement invoices for Non-Federal or Federal Pass-Through grants and contracts and act as the point of contact for billing inquiries.
• Assist with the processing of receipts of sponsor payments and ensure they are credited to the correct award and invoice.
• Track sponsored project receivables and initiate collection communication.
• Reconcile sponsored project receivable and follow up on unbillable issues.

Cost Transfers

A cost transfer (aka accounting correction) is defined as an expense that is transferred from one account to another after the expense was initially recorded in the financial accounting system. The Principal Investigator and their department are responsible for initiating and processing cost transfers and ensuring that cost transfers are completed in compliance with Uniform Guidance, University guidelines and the sponsored award. The federal government requires that the university, as a recipient of federal monies, processes any necessary cost transfers/accounting corrections within 90 days of the original transaction date, regardless of the funding source as we cannot have different rules for federal money than those rules that apply to all other sources of funds. 

Uniform Guidance (2 CFR 200.405) states what costs can be allocated to an award if; 

A cost is allocable to a particular award or other cost objective if the goods or services involved are chargeable or assignable to that award or cost objective in accordance with relative benefits received. This standard is met if the cost:

• Is incurred specifically for the Federal award.
• Benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods; and
• Is necessary to the overall operation of the non-Federal entity and is assignable in part to the award in accordance with the principles in this subpart.
• All activities which benefit from the non-Federal entity's indirect (F&A) cost, including unallowable activities and donated services by the non-Federal entity or third parties, will receive an appropriate allocation of indirect costs.
• Any cost allocable to a particular Federal award under the principles provided for in this part may not be charged to other Federal awards to overcome fund deficiencies, to avoid restrictions imposed by Federal statutes, regulations, or terms and conditions of the Federal awards, or for other reasons. However, this prohibition would not preclude the non-Federal entity from shifting costs that are allowable under two or more Federal awards in accordance with existing Federal statutes, regulations, or the terms and conditions of the Federal awards.

Therefore, the reason for the allocation to the award cannot be due to an award being overspent or due to costs not being allowed for a specific award. Overspent balances and unallowable costs must be charged to an unrestricted account.

Financial Reporting and Closeout

The goal of Financial Reporting is to provide Principal Investigators and department administrators with quality support services and financial compliance guidance along with effective stewardship of sponsored awards.

Most sponsors require financial reporting to determine the use of sponsored funds on either a monthly, quarterly, annual, or other reporting basis. The Grant Accounting team is responsible for ensuring that the deadlines for financial reporting are met and are in compliance with the federal, state, sponsor specific and/or Ohio University’s policies and procedures. Ohio University shall submit timely financial reports to the sponsors of research and other scholarly activity that:

• Accurately reflect the actual use of sponsored funds as recorded in the financial records of the University.
• Ensure that all reports are in compliance with the sponsor’s terms and conditions.

Each department is assigned a Grant/Contract Accountant from Finance that will provide guidance and assistance as well as answer any questions that may arise on a day-to-day basis.

At the conclusion of the award, after the financial report is filed with the sponsor, and all financial obligations are satisfied, the Grant/Contract Accountant is responsible for closing the award within the University’s financial system.

The University expects the Research Community to perform the necessary tasks associated with the timely submission of final deliverables and the prompt closeout of expired sponsored projects. Federal agencies have become increasingly stringent about the timely submission of required reports as this is considered a key mechanism reflective of proper accountability and good stewardship of funding. Non-compliance with sponsored project reporting term and closeout of award record has adverse consequences including but not limited to, forfeiture of final payment, delayed or reduced future funding, less favorable award terms and conditions, and audit finding risks. The submission of final financial, performance, and other reports to the sponsor and the closeout of completed projects within 90 days of expiration help mitigate risks and potential negative consequences.

Closeout Checklist

Cost Sharing

The University must ensure that cost sharing requirements of sponsored agreements are proposed, approved, accounted for, and reported in a manner consistent with the requirements of the sponsor and the University. Cost sharing can be of the following types: Mandatory, Voluntary committed, Voluntary uncommitted. Committed cost sharing must be identified, administered, and accounted for consistently throughout the University within the financial system for mandatory cost share through the creation of a cost share award within OU’s ERP system. Voluntary uncommitted cost sharing does not need to be identified and is not covered by this policy.

Federally funded projects must meet the requirements in the OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements (“Uniform Guidance”), Sections 2 CFR 215.23(a)(5), 200.29, 200.306. And the University follows the same requirements for non-Federal awards involving cost sharing requirements.

The Cost Sharing Procedure establishes requirements for the identification, approval, funding, accounting, and reporting of mandatory and voluntary committed cost sharing, and matching requirements associated with sponsored projects. Cost sharing represents a binding obligation of the University once the award has been granted.

Cost Sharing on Sponsored Projects Procedure

Effort Reporting

The Office of Management and Budgets’ (OMB) Uniform Guidance: Cost Principles, Audit, and Administrative Requirements for Federal Awards includes regulatory requirements for the planning, confirmation, and certification of effort associated with organized research projects and other activities. Effort directly charged to sponsored projects and any mandatory cost shared effort (i.e. committed effort that is not directly charged to the award) must be identified in the University’s effort distribution/reporting system. The principles that govern how the University must document time and effort on federal awards are in OMB Uniform Guidance 2 CFR 200.430. The Uniform Guidance requires each grantee to maintain a system of distributing salary charges to all awards that results in a reasonable allocation of salary charges to each award. The salary distribution system also must include a periodic review to confirm the reasonableness of salary charges to the projects.

The University primarily employs an After-the-Fact effort reporting system that provides the principal means for certifying that the salaries charged or contributed to sponsored projects are reasonable and consistent with the portion of total professional activity committed to the projects. The salaries of administrative and clerical staff should normally be treated as indirect (F&A) costs. Direct charging of these costs may be appropriate only if all the following conditions are met:

1. Administrative or clerical services are integral to a project or activity;
2. Individuals involved can be specifically identified with the project or activity;
3. Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and
4. The costs are also not recovered as indirect costs.

Proposal coordinators and grant administrators will consider information that pertains to a specific proposal and these guidelines when determining direct charging to a sponsored award. See Budget-Direct Charge Administrative and Clerical Staff Procedure for guidance.

The following categories of University employees are certified on University generated reports:

1. All salaried faculty, graduate students, administrative and professional employees paid on sponsored projects (Frequency – Semesterly). 
2. Hourly Non-exempt support staff, undergraduate students, and limited duration employees paid on sponsored projects (Frequency - Monthly), if applicable. Wages for administrative and clerical staff are not normally allowed to be charged to sponsored projects as those costs are part of the University overall recovery of indirect costs from external sponsors.

NIH Salary Cap

As part of the budget appropriations of the National Institutes of Health (NIH), Substance Abuse and Mental Health Services Administration (SAMHSA), and Agency for Healthcare Research and Quality (AHRQ), the US Congress legislatively mandates a salary cap. The salary cap applies to grants, cooperative agreements, and contracts (with the exception of those that are clearly defined to be exempt from the cap). You can view the salary cap for current and previous years. The salary cap limits the rate of academic and summer salary that may be charged to NIH, SAMHSA, and AHRQ awards. Ohio University will comply with all salary cap requirements of sponsors making awards to the University in support of research or other activities. Where an agency specifies a maximum rate at which an individual may be paid from that agency’s funds, Ohio will ensure that any salary above that rate will not be charged against the grant, contract or cooperative agreement issued by that agency. Salary in excess of the NIH Salary Cap is considered mandatory cost sharing and should be identified during the proposal phase of an award and tracked in the financial system. OU considers academic or calendar year salary in excess of the imposed cap as mandatory cost sharing. The amount in excess of the cap cannot be used as matching funds. The University may pay an employee’s salary amount in excess of the salary cap from non-sponsored project funds. 

Participant Support Costs

This guidance applies to all funding and individuals that are in the role of receiving instruction or training from a federal award. Departments are responsible for developing proposals and managing awards in compliance with this guidance and the guidance provided by the sponsor regarding Participant Support Costs. This includes posting relevant Participant Support Costs and retaining related documentation/records in accordance with the terms of the award. 

Participant Support Costs (PSC) as defined are direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects. (2 CFR §200.75)

Participant support costs are allowable with prior approval from the Federal awarding agency. (2 CFR §200.456) 

• Participant support costs are excluded from modified total direct costs. (2 CFR §200.68)
• The transfer of funds budgeted for participant support costs to other budget categories requires the approval from the Federal awarding agency. (2 CFR §200.308)

Summer Salary

Summer salary is defined as any compensation paid during the summer period to a faculty member in excess of his or her academic year salary. The summer period is defined to be the period outside Institutional Base Salary of the academic year appointment. 

A request for summer salary indicates a commitment to put forth a comparable effort on the project(s) during the summer, not the academic year. Effort expended during the academic year does not satisfy a commitment related to the receipt of summer salary.

All effort devoted and corresponding salary charged to sponsored projects must be in compliance with sponsor and University policies. Committed effort on a sponsored project should be devoted exclusively to the activity supported by that sponsored project. Other activities performed during the summer months, e.g. any administrative or academic activities, vacation, writing new proposals, may not be charged to sponsored projects. Note that sponsors may have restrictions on summer salary. Faculty should therefore consult their grant terms and conditions prior to committing to a summer effort. Any questions regarding sponsor terms or conditions should be directed to the Office of Sponsored Projects.

Sponsor Travel Guidance

There are specific rules relating to travel charged to Federal Awards. This guidance is an extension of the University Travel Policy.  This provides information to ensure the University and the traveler are in compliance with the regulations and restrictions placed on the use of the funds by the sponsor and the Fly America Act.

Facilities and Administrative Costs (F&A)

Ohio's current approved rates are for use on grants, contracts and other agreements with the Federal Government.

Questions

Questions regarding this procedure can be sent to orsp@ohio.edu. 

Forms/Templates

There are no forms or templates for this procedure.