Manage Your Award
Post Award Administration involves a broad set of activities regarding the management of sponsored funds, compliance with federal regulations and adherence to VCU policies and procedures. At VCU, these processes are overseen by Grants and Contracts Accounting (G&CA). Specifically, G&CA provides financial reports to sponsors, interprets rules and regulations of the financial operation for the research community, acts as a depositor of federal and nonfederal funds and operates VCU’s Effort Reporting System.
The Grants and Contracts Accounting is responsible for maintaining the official accounting records of all sponsored programs held by VCU and for preparing all financial reports for submission to the sponsor. The VCU Banner System constitutes the official accounting records of the University. However, it is the PI’s responsibility to review the appropriate monthly financial reports and work with the appropriate department/division personnel to ensure appropriate use of funds, as well as identify and correct any errors or omissions in the award expenditures.
This is not meant to be an exhaustive list of responsibilities but rather an overview of the most important aspects of managing a newly awarded grant or contract.
Sponsors typically notify both the Principal Investigator (PI) and the Office of Sponsored Programs (OSP). Upon receipt of the sponsor’s Notice of Award, OSP sets up the initial award and turns over to G&CA to manage the financial reporting aspects of the project for the duration of the grant period. The PI and the grant fiscal administrator (FA) receive notification of the new index/account number upon creation, amount of the newly loaded budget and work may begin on the project, as long as all institutional and sponsor conditions have been met.
In some cases, a PI may need to incur expenses prior to the establishment of the new index. If pre-award costs are allowed by the sponsor, the PI may work with the DOIM RSO to establish an index in advance of the receipt of the formal award notice.
Positions that are to be established upon receipt of grant funding must comply with federal, state and VCU employment laws, policies and practices. Subsequently, the creation of new positions and their recruitment can be a lengthy process. So PIs are asked to plan ahead to the best of their abilities in anticipation of these requirements.
In the Department of Internal Medicine, all requests to create new positions are submitted by the appropriate division administrator to the Associate Administrator for Human Resources (Lydia Zirkle Lloyd, (804) 828-9691, firstname.lastname@example.org) for review and action.
If a newly awarded grant will be supporting division existing personnel, a payroll transaction (called Labor Distribution) is required. To submit a change in Labor Distribution, the PI should contact the grant FA to make the request. As part of the request, the PI should provide the employee name, amount of payroll, time period of the payroll and the account/index number.
- Purchases of goods and services in support of a grant project are managed by VCU Procurement Services. They are responsible for all procurement, vendor payment, travel, reimbursement, real estate acquisition/leasing and risk management activities at Virginia Commonwealth University.
Capital equipment purchases (unit cost > $5,000 and having a useful of more than 1 year) may be subject to sponsor regulations. PIs should read Notice of Award to determine what authorization may be required in advance of the purchase.
PIs should contact the grant FA or division administrator to identify division personnel available to assist them with purchase and travel processes.
It is the responsibility of the PI to ensure the sub-awardee is capable of performing the required work. The PI holds all the final approval rights for all technical components of the sub-contract/sub-award and is expected to monitor all work in progress as well as expenditures to determine if costs are in accordance with the negotiated budget.
Upon receipt of an award with a budget sub-contract, the PI and/or grant FA should initiate the “SubAward Request Form” and submit to VCU OSP.
Once the sub-contract has been established, the PI will receive invoices from the sub-contractor. Upon receipt of a copy of the sub-contractor’s invoice for payment, the PI should review for appropriateness and accuracy and then forward to the grant FA, who will prepare the Direct Pay/General Encumbrance form for submission to Accounts Payable.
PIs are expected to review expenditures to ensure they are made in accordance with sponsor and university regulations, policies, and procedures by reviewing their status of their grant index accounts at least monthly. PIs may work through the grant FA or monitor the status of their indexes via the VCU Research Dashboard, accessed through the MyVCU portal (requires eID).
A note about industry sponsored clinical trials indexes – Because industry sponsors generally reimburse VCU based upon the completion of certain patient milestones (not actual expenses incurred), only the amount of actual cash received to date from the sponsor will be loaded as part of the project’s budget. So in addition to reviewing expenditures, PIs should also monitor the project budget, which is based upon payments received from the sponsor, to ensure the timely and accurate in the submission of patient study data to the sponsor (e.g. Case Report Form) and updating the grant FA accordingly so an invoice to the sponsor may be generated.
If an expense has been incorrectly charged to a grant index, an expenditure transfer must be made to correct the charge by way of a cost transfer. Cost transfers to sponsored program indexes may be made only within 60 days from the date of the month end financial report (Banner system) report on which the charge first appears. Any erroneous charges identified after 60 days can only be transferred to a non-sponsored program index. In addition, once an index closes and the final financial report has been submitted to the sponsor, no expenses may be charged to the closed index but must be funded elsewhere. PIs may request needed cost transfers by working through the grant FA.
Federal regulations require additional documentation to support cost transfers to sponsored program indexes. Costs may not be shifted to other research projects or from one budget period to the next period solely to cover cost overruns. Cost transfers based on funding considerations are prohibited (i.e., cannot transfer costs to use up remaining funds). The full policy regarding cost transfers may be found on the G&CA website.
DEPARTURES FROM THE AWARD
Federal regulations require prior approval from an awarding agency for a variety of project changes. In an effort to streamline grants management, the federal government's Office of Management and Budget (OMB) reduced the number of required prior approvals by issuing “expanded authorities”.
Many federal agencies have waived cost-related prior approvals and permit an institution to decide budget changes under their "expanded authorities" to include:
- Pre-award costs up to 90 days prior to award
- No Cost Extension: A one-time expiration date extension of up to 12 months
- Carryover of unobligated balances to subsequent funding periods
Please note that while expanded authorities do apply to most federal grants, they do not apply to all and can vary somewhat by agency. Any terms included in the Notice of Grant Award from the agency supercede expanded authorities.
Certain other changes, however, still require prior approval of the awarding agency:
- Changes in project scope or objective
- Change of PI or other key personnel
- Absence of the PI for more than three months, or a 25 percent reduction in effort spent on the project by the PI
- Need for additional funds
- Other changes specifically cited in the award or in agency-specific guidelines
Please contact the DOIM Research Services Office or grant FA for guidance for items requiring sponsor approval.
Typically, grant sponsors require two reports upon the completion of a grant – a final technical/progress report to be prepared and submitted by the PI, and a final expenditure/financial report, which is prepared and submitted by VCU Grants & Contracts Accounting. In most cases, all final reports are due to the sponsor within 90 days of the grant’s end date.
The contents and format of a final technical/progress report are set by the sponsor and are typically contained in the Notice of Grant Award document or sponsor guidelines.
Final reporting for many NIH grants are done through the NIH Common’s RPPR module. PIs should check to see if their grant is eSNAP-eligible (indicated on the Notice of Grant Award).
Multi-year grants generally require the submission of annual reports before the subsequent year is funded. For NIH grants, annual technical reports generally are due two months prior to the start of the next award period. Contracts, including clinical trials agreements, have specific reporting, invoicing, and reimbursement schedules. Annual reports are required of animal and human use protocols. Information about sponsor-specific reporting requirements are typically found in the Notice of Grant Award or program guidelines.
Be aware of deadlines for competitive renewals, and prepare accordingly (NIH deadlines). PIs should be prepared to submit the renewal proposal to the VCU Office of Sponsored Programs at least five working days prior to the sponsor’s deadline.
Timely reporting is essential to the proper stewardship of sponsored funds. The PI is solely responsible for meeting all technical and programmatic reporting required by the sponsor, while the Office of Grants and Contracts Accounting (G&CA) is generally responsible for submitting financial reports and invoices. When unique financial reporting requirements are required, the department will assist the G&CA in meeting these additional report requirements.
A Sponsored Program Closeout Checklist is available from the VCU OSP website to assist PIs and FAs.
VCU receives funding for research and other sponsored programs through grants and contracts provided by the federal government and other sponsoring agencies. As a condition of accepting such funding, VCU must ensure that the effort expended on sponsored program activities justifies the salary charged to them.
VCU fulfills the federal effort reporting requirement through the use of eCRT, a web-based tool that calculates the distribution of effort for all employees paid from sponsored program funds. eCRT Training may be done on-line or instructor-led classroom training.
PIs are responsible for understanding the principles of accurate Effort reporting and salary allocation for all personnel funded from their grants and are expected to remain current on any mandatory training.
In the performance of a sponsored program, intellectual property may be created. This includes inventions which may be patentable, and writings and other expressions that may be copyrighted. Under VCU policies, ownership of such properties is typically determined by the sponsorship agreement or the applicable VCU policy.
When a PI moves to another institution, the sponsor may allow for the transfer of the award to VCU. This is typically done by formally closing out the existing VCU award and making a new award to the PI’s new institution.
To accomplish such a transfer, the PI should contact the Department’s Research Services Office (Rashmi Pershad or (804) 828-0404) for assistance, preferably 60 or more days in advance.
Full policies and procedures regarding the transfer of a grant to another institution may be found on the G&CA website.