Managing Sponsored
Projects
UM SPA, January, 2008 |
Chapter 3: The Award Process and Award Acceptance
Section 3.1: The Award Process and Award Acceptance
There are several aspects of an award which are essential to know before work
on the project begins:
- Before the award is made
- When work can begin
- Establishing preaward or advance accounts
- Site visits
- Education requirements
- The award process
- Electronic Grants Management System (EGMS)
- Review the NOGA
- Account establishment
Before the award is made
PIs may receive communication from the potential sponsor after the proposal
has been submitted and before any award is made. Some of these communications
may be informal budgetary or workscope discussions. Others may be a formal
part of the proposal review and award process. In particular, Federal
agencies have a "just in time" step for submitting proof of education and IRB
approvals. Agencies, including NIH, that follow this practice do not require
IRB approval at the time of submission or within sixty days of application receipt.
Instead, following peer review the investigator will be notified of the application's
score and if the application is in the fundable range. At that time, the
investigator must obtain IRB approval and verification of education.
When work can begin
Work can officially begin on a sponsored project:
- on or after the award's official starting date (indicated on the contract
or award statement), and when an agreement has been fully executed by both
parties, or
- when a binding commitment from a sponsor has been received (e.g., a unilateral
award from NIH or NSF) and the terms and conditions accepted.
Work may begin earlier when pre-award activities are allowed by the sponsor and
the PI has requested and received an account number (see "Establishing preaward
or advance accounts" below).
Charges that are made to a nonsponsored program and then transferred to the
sponsored project when the award is established must be transferred before the
cost transfer deadline.
STATE AWARDS:
PIs receiving awards from the State of Minnesota are often frustrated by
the long time between an agency's first expression of interest to fund a project
and the actual availability of the funds. This is largely due to a State law
(M.S.16C.05 subd.2) that prohibits grants or contracts from starting before
the date of final State signature. This means, regardless of the project period
requested in the original proposal, funds cannot cover costs incurred before
the date the award is fully executed. Since the overall award process (issuance
by State administrator, SPA review and signature, and obtaining two to four
State signatures) may take from several weeks to several months, this can
wreak havoc with project planning. SPA encourages PIs to submit proposals
as early as possible, and to raise this issue with their agency counterpart
early in the cycle, to see what remedies exist or what revisions may be expected.
Once all parties sign the award, only if state personnel invoke a special
waiver of the restrictive ordinance, will the award be retroactive to the
specified project start date. Some program officers are unaware of this provision;
others may refuse to cite it, as it has pejorative connotations in some agencies.
Contact your grant administrator for assistance in negotiating such arrangements.
This State provision also affects advance account establishment, which PIs
often request to get projects under way before the lengthy State award process
is resolved. Unlike the federal government, the State does not recognize "pre-award"
costs. In these situations, SPA is reticent to set up an account and promote
PIs incurring costs for which their department will be accountable. The University
needs assurance from the agency, i.e. the waiver, that the award, once executed,
will be effective from the original project start date. If agency assurance
remains uncertain, we may require explicit departmental acknowledgement of
the risks involved before we will establish an account.
Common Problem:
The applicant has not provided enough budget detail to allow grant administrators
to properly distribute the awarded funds into budget categories. The grant administrator
must request this information from the PI, thus extending the time it takes
to set up the award.
Establishing preaward or advance accounts
Occasionally, it is necessary to obtain a project number before the award process
is completed. For example, a PI may wish to begin a lengthy hiring process before
the project's start date.
- An advance project is used when the project start date occurs before the
award process has been completed, for example a contract has not been signed
by all parties.
- A preaward project is used when the PI needs to begin working on a project
before the project start date.
To obtain either of these accounts, prepare a "preaward or advance project request
form" according to the procedure on Establishing and Charging Preaward or Advance
Projects. The policy, Charging Sponsored Project Costs Outside the Project
Period, and procedure can be accessed through SPA's research policy web page.
Site visits
Sponsors considering proposals for research programs or facilities sometimes conduct
site visits or request program reviews by consultants. SPA staff are available
to confer with the site visitors.
Costs associated with a site visit are not allowable against existing contracts
or grants and must be charged to an authorized University program.
Education requirements
The Regents' policy on Submitting and Accepting Sponsored Projects requires PIs to participate
in an educational program on the Responsible Conduct of Research (RCR). The
RCR curriculum is divided into a series of workshops:
- RCR, part I, covers topics such as social responsibility, reporting misconduct,
authorship, and management of research data.
- RCR, part 2, covers fiscal responsibilities, conflict of interest, and intellectual
property.
- Additional topic-specific workshops include care and use of animals, protecting
human subjects, and issues in environmental health and safety.
New faculty or current PIs who have not attended an RCR workshop must attend both
parts of the RCR workshop, and any additional topic specific workshop that is
appropriate to their research within the first 12 months of their appointment,
or prior to receipt of additional external funds.
Continuing education is required a year after completing the RCR 1 and 2. PIs
must review an update of information each year and once every three years, they
must participate in “active learning” activities related to RCR topics.
Information about the program can be found at: http://www.research.umn.edu/training/.
The award process
The process of executing an agreement and authorizing work involves several
steps:
- Negotiation.
- Notification of the award.
- Officially accepting the sponsored grant, contract, or agreement.
Negotiation
On many bilateral agreements (both parties must sign), the sponsor and SPA must
come to an agreement regarding the budget, the scope of work, and other terms
and conditions of the award. These negotiations can take weeks or months, particularly
if the sponsor is slow to respond to questions or requests to revise clauses.
See the section earlier in this chapter regarding advance accounts for information
on establishing an account before the final contract is signed.
On unilateral agreements, usually grants which the University does not sign,
the sponsor will sometimes contact the PI directly to discuss the budget.
Generally, any changes must be reviewed by the PI or their representative
and SPA.
Items that may be subject to negotiation include:
- scope of work,
- budget,
- the reporting requirements, both technical and financial,
- start and end dates,
- audit requirements that do not conform to Federal OMB Circular A-110,
- indemnity and liability,
- F&A (indirect) costs,
- ownership of technical developments,
- limitations for publication,
- requests for secrecy (see the Regents Openness in Research policy),
- intellectual property issues such as use of results in later projects
and licenses,
- payment terms,
- adverse reaction,
- termination, and
- governing law.
Notification of the award
The award document is considered an official agreement of the scope of work,
the amount the sponsor will provide, and other terms and conditions that govern
the project.
Sponsors usually send SPA official notification of an award. However, if award
notification has been sent to the PI or to a department or college office, the
award notice and any agreements or contract materials must be forwarded immediately
to SPA. Remember that the award is made to the University and not to a PI.
PI notification:
- If it is a bilateral agreement (both parties must sign), SPA will send
the PI a copy of the notice along with a memo requesting PI confirmation
of technical terms, reporting requirements, and overall PI concurrence with
the document. The agreement cannot move forward without PI input.
- If SPA receives an electronic award transmission, staff members will forward
them to PIs.
- Final agreements which are fully executed must be copied to PI and their
representatives (i.e. administrators and/or the RSO, as appropriate).
Award notices typically contain the following information:
- title or description of the award,
- award beginning and ending dates,
- dollar amount awarded,
- the terms of payment, e.g., letter of credit vs. invoicing,
- programmatic deliverables,
- financial invoicing/reporting requirements,
- cost sharing or matching commitments, and
- a budget if it has changed from the proposed budget.
Officially accepting the sponsored grant, contract, or agreement
Through their policy on Submitting and Accepting Sponsored Projects, the Regents have delegated signatory authority
for accepting awards to designated individuals in SPA. Once an agreement has
been reviewed by SPA and the PI, it can be accepted and executed on behalf of
the University by SPA. Since awards are made to the University of Minnesota
and not to faculty, staff, or others, these individuals cannot accept grants
or sign contracts or agreements.
Review the NOGA
The NOGA and award notice must be read carefully for changes from the original
proposal.
Account establishment
After the award has been formally accepted, SPA staff members will perform the
following tasks so that work can begin:
- prepare the Notice of Grant/Contract Award (NOGA),
- assign a project number, and
- activate budget lines for the project.
Notice of Grant/Contract Award (NOGA)/Notice of Program Income (NOPI)
SPA prepares a "Notice of Grant/Contract Award" (NOGA) to provide information
regarding the award's important terms and conditions. It should be referred
to by PIs and departments to provide guidance in managing the project. It usually
contains the following information:
- the University account number
- award amount
- beginning and ending dates
- the F&A / indirect cost rate
- matching or cost-sharing requirements
- program income distribution requirements
- technical reporting requirements
- other terms and conditions
If program income occurs on a sponsored project and it is determined that the
income can be used under the additional alternative and/or add/deduct alternative,
SPA staff will assign a "child account" under the prime sponsor account to recognize
the income. This assignment will occur upon receipt of the initial check/payment
of program income. A NOPI will be prepared and distributed to the principal
investigator, department, college, certified approver, Sponsored Financial Reporting
(SFR) and External Sales. Any income received thereafter, for the identified
activity, will not generate a NOPI and instead be setup directly by SFR staff.
Assigning a project number
As soon as SPA receives the award notice or final agreement, a staff member
will assign a project number to the project. This number identifies the project
in the University's accounting system. When the project number is assigned,
SPA will notify the PI and the department and collegiate offices through email.
Interest-bearing accounts: For an account of this type to be used, the award
must require that an interest-bearing account be established. At the written
request of a grant administrator, the Office of Budget and Finance will set
up the account. The balance at the end of each trimester must be at least $15,000
for interest to be accrued. At the end of each trimester, the grant administrator
will transfer the interest revenue into the project's operating budget. Consult
SPA and the University financial policy Allocating
Temporary Investment Pool Income for details.
Activating budget categories for the project
When SPA establishes the project, an allocation of the awarded amount will be
made into the appropriate expense categories (expense budget lines, also known
as Object codes). The grant administrator will set up these categories in accordance
with the sponsor's approved budget. Some sponsor's categories, however, do not
correspond with the University accounting system. Therefore, it may be necessary
for the grant administrator, PI, and unit administrator to work together to
establish the budget, and monitor compliance with sponsor financial terms and
conditions.
The grant administrator will also create EB and RB (Revenue Budget) documents
that refer to anticipated expenses and collection of income. Copies will be
sent to the unit administrator and accountant, who should review them for accuracy
and retain them for auditing purposes.
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Januray 28, 2008.
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