Post-Award Processing

See also Policies, Procedures & Guidelines for additional topics.

GRANT AND CONTRACT RESPONSIBILITY,AWARD PROCESSING AND SPONSOR INVOICING

The management of externally funded projects (grants, consortia agreements, etc.) is a collaborative effort between the Principle Investigator(s) and the University. This document provides details of some of the general grant and contract responsibilities and requirements.

Upon acceptance of a grant or contract, a Coodinator is assigned by ORSP to assist the Principal Investigator with the administration of the award. The Coordinators provide services to facilitate the awards which include: establishing a university account in order process expenditures, interpreting sponsor guidelines, serving as intermediaries between project directors and the sponsor, reviewing all expenditure activity for compliance within university policies and sponsor guidelines. In addition, the Coordinators serve as intermediaries between Project Directors and the sponsor in all communications pertaining to administrative changes, including and not limited to budget revisions, renewal awards, no-cost extensions, and changes in key personnel.

1. GENERAL GRANT AND CONTRACT RESPONSIBILITIES

The Principle Investigator(s) (PIs) is responsible for upholding all sponsor regulatory or restriction requirements. Sponsor guidelines and any additional terms and conditions are provided to the PI(s) at the time of negotiation of the award for review and acceptance prior to execution by the University.

The Office of Research and Sponsored Programs (ORSP) is responsible for review, negotiation and acceptance of all contractual agreements on all research and sponsored programs (hereafter referred to as sponsored programs). In addition, ORSP is responsible for compliance with contracts and any federal certification requirements. The University is responsible for maintaining adequate fiscal controls and ORSP monitors all sponsored projects for consistency and appropriate application of sponsor guidelines as well as University policies and procedures.

While the University is the legal recipient of sponsored agreements and ultimately responsible for the performance of activities and the proper use of sponsor funds, the University cannot meet its responsibilities to the sponsor unless the Project Director(s)/Principal Investigator(s) meets his/her obligations. PI(s) are accountable for the proper conduct and performance of their project activities. The PI(s) must assure the technical performance and completion of any and all required technical reports in a timely manner. Failure to submit reports can delay future funding to the PI(s) as well as to the University as a whole. Additionally, only the PI(s) can truly know if expenses charged to a sponsored project are legitimate. Costs applied to a project account must be related costs and meet the test for being reasonable, allowable, allocable and consistently treated as defined in the Awards Management section.

2. AWARDS MANAGEMENT

2.1 Project Activity

Once an award agreement has been accepted and fully executed by an authorized University representative, ORSP will establish a University account number to be used to process expenditures. The awarded budget, based on the sponsor approved proposal and cost proposal, will be established in the University Datatel system. The account number, budget, general reporting and restriction information will also be provided on an internal New Sponsored Project Award Notice. This notice along with a copy of the award will be distributed to the PI(s) and Co-PI(s). Copies will also be distributed to Department Chair(s), Collegiate Dean(s), Office of Budget and Finance, PI(s) designated project support staff and any other appropriate administrative office. The PI(s) and/or their designated project support staff should be able to display their grant account(s) on the University’s Datatel general ledgers system.

The PI(s) is primarily responsible for making sure that all activity conducted on their project(s) is appropriate as prescribed in the sponsor approved proposal and budget and should be necessary for completion of the grant. Additionally, only the PI(s) can truly know if expenses charged to a sponsored project are legitimate. Costs applied to a project account must be related costs and meet the test for being reasonable, allowable, and allocable.

Again, PI(s) are expected to be familiar with award terms and conditions to ensure proper technical performance and financial activity on the project.

As mentioned above, frequently awards contain requirements and/or restrictions regarding publicity, confidentiality and/or issue specific restrictions (i.e. PI(s) or Key Personnel changes, level of effort changes, purchase of equipment, or foreign travel). ORSP should be contacted well in advance of the occurrence, if the PI(s) is contemplating program or budget revisions, or has any general questions concerning administration of the award. ORSP serves as the administrative contact with sponsorsand should the agency need to be contacted, sufficient time is required to contact and address any questions they might have.

2.2 Cost Share or Matching Costs Related to a Project

Some projects include a cost share or matching funds component that may include university funds as well as third-party contributions. Both typically represent a commitment that the University has agreed to contribute towards the project. In most cases, cost share activity must adhere to the same guidelines administered by the sponsor.

Often Release-Time salary for a project director is used as matching costs representing the time faculty devote to a project, usually during the academic year. Upon receipt of an award, Time and Effort Report Forms (see Time and Efforts link) should be initiated to document this activity. An Academic Year Time and Effort should be processed each year Release Time activity is involved.

Third-party or in-kind contributions must be fully documented, reported and certified in writing as they occur to ensure that the university’s obligations have been met as dictated by the approved proposal. Forms for documenting Third-party match are available in ORSP.

In all cases, commitments by the university must be approved by the area that has agreed to make the contribution. In addition, approval must be acquired by the appropriate Department Chair, Dean, and Director of Research and Sponsored Programs.

2.3 Expenditure Approval

The PI(s) and University of Tulsa agree to abide by the sponsor terms and conditions upon acceptance of the award. It is the responsibility of ORSP administration to monitor the cost activities of an award in accordance with the policies of The University of Tulsa as well as the regulations of the sponsor to ensure compliance. Costs must pertain to the project activity, be within the allowable performance period, and adequate award funds must be available. Unallowable expenditures become the responsibility of the PI(s) and their department.

Costs applied to a federal award must comply with the Office of Management and Budget (OMB) Circulars governing grants, contracts, and Other Agreements with Educational Institutions, specifically A-21, A-110 and A133, as well as any additional specific terms attached. Expenses are generally permissible on sponsored agreements, if they are:

Reasonable – A prudent person purchasing this item would have paid this price, are generally recognized as necessary for the performance of the sponsored agreement. Arm’s-length bargaining, federal and state laws and regulations as well as sponsor terms are imposed. The individuals concerned act with due prudence in the circumstances considering their responsibilities to the federal government. Costs are consistent with university policies(see OMB A-21, Section C(3).

Allocable – Expenses can be allocated to the government activity based on benefit derived, cause and effect, or other equitable relationship. Costs are allocable if incurred solely to advance the work, benefits the project, are necessary for the operation and deemed assignable to the project.

  1. Costs may not be shifted to other agreements in order to meet deficiencies, per OMB A-21. Section C(4)b.
  2. OMB A-21, Section C(4)c prohibits costs allocable to activities sponsored by industry, foreign governments or other sponsors being shifted to federally-sponsored agreements.

Allowable – Allowable costs and unallowable costs as specified by government regulations (OMB A-21, Section J) and any award restrictions.

Consistently Treated – Similar expenses charged to other entities by the University must be treated the same in like circumstances as with the government (see OMB A-21, Section C(3).

In order for expenditures to be charged to a sponsored project account, paperwork must be initiated, in accordance with University Purchasing Policies and Procedures, by the project director in the form of Purchase Orders, Check Requests, or Travel Reimbursements through the PI(s) designated department. Reimbursements may be submitted by Check Requests or Travel Expense Reports and should be submitted no later than thirty (30) days from the date the expenses occurred. Each expenditure is reviewed for proper documentation and appropriateness as stated above.

2.4 Sponsor Audits

Sponsors may request an audit of the project activity, both programmatic and budgetary, and in most cases the PI will be asked to participate in the audit. All external audits should be administered through ORSP. Activity deemed inappropriate by a sponsor could lead to disallowances, paybacks and/or fines.

2.5 Subawards

A Subaward is a formal written agreement between TU and a Subrecipient which will normally include a Statement of Work (SoW) and a budget under a TU sponsored project. Subrecipient is typically, though not always, a collaboration with another university. Subawards are distinguished from other procurement actions, such as payment for goods and services, as usually intellectually significant and necessary to complete a portion of the project.

All proposed Subrecipients must be clear of any debarment restrictions in accordance with Federal Executive Order 12549. Their status with the federal government should be reviewed prior to a proposed relationship with TU. A Subrecipient listed on the Denied Parties list with the U.S. government, may not participate in a TU sponsored project (see Restricted Party Screening and Debarment below).

The Subrecipient’s Statement of Work (SOW) is performed by its personnel, commonly performed at the Subrecipient’s site, using its own facilities and resources.

ORSP is responsible for issuing all Subawards, and a Subrecipient may not begin work without a fully executed Subaward in place. Subawards may only be issued upon receipt of:

  1. A clearly defined SOW and budget which has been endorsed by the Subrecipient’s appropriate administrative official.
  2. Typically, prior approval of the Subaward from the prime sponsor of the TU sponsored project.
  3. Receipt and acceptance of an award from the prime sponsor. 

In some cases, additional documentation may be required:

  1. Receipt of the Subrecipient’s approved F&A Rate proposal.
  2. Receipt of the Subrecipient’s most recent A-133 Audit Report or

The Subrecipient must usually adhere to the same terms and conditions issued under the TU sponsored project.

3. OTHER REQUIREMENTS

3.1 Publicity – Publication, New/Press Releases, Advertisements, etc.

Any public release of information concerning a sponsored project may require prior approval from the sponsor and should involve prior contact with University Relations. In most cases, sponsors may require that they receive credit for funding in any public release of the grant activity. Other awards may require a statement that the views expressed in the publication do not reflect that of the sponsor. Award guidelines should be carefully examined prior to any public release regarding a sponsored project.

3.2 Confidentiality – Proprietary Information

Some awards have restrictions on sharing of data or information related to the sponsored agreement specifically addressed in the award terms and conditions. This information should be shared with all project staff and documented for the project files retained with the PI(s). Additional requirements of the award may include written documentation of the receipt of proprietary information, prior review of publications, non-disclosure agreements, etc.

3.3 Intellectual Property (IP)

The University Research and Intellectual Property Policy guidelines should be reviewed. IP rights in association with sponsored projects are normally retained by The University of Tulsa and are negotiated with the award. Periodically, however, extenuating circumstances may exist resulting in shared rights. Any questions concerning potential Intellectual Property should be directed to the Chair of the Intellectual Property Committee or Vice Provost for Research.

3.4 Restricted Party Screening and Debarment

The U.S. government has established export regulations that restrict individuals and companies, or prohibit exporting or providing services to any party contained in the U.S. government export denial, debarment, and blocked parties lists.

In accordance with Executive Order 12549, all project personnel (including consultants, contractors and/or subcontractors) must be clear of any debarment restrictions, prior to being enlisted on a project. During the routing of a proposal, PI(s) must certify that to the best of their knowledge and belief neither they, the Co-PI(s) nor project personnel have been debarred, suspended, proposed for debarment, or declared ineligible to receive federal funds. The PI(s) also accepts responsibility of notifying ORSP immediately if there is any change to the debarment status of project personnel. Denied Parties may not be enlisted on federal projects as vendors, personnel, subcontractors or consultants. The following site may be used to check debarment status: http://www.epls.gov.

You may also contact ORSP for assistance in this review.

4. MONITORING CASH FLOW (SPONSOR INCOME AND REVENUE)

Once a new sponsored project has been established, a receivable is established by ORSP to process payments from the sponsoring agency. All requests for payment, invoices, and electronic payment requests pertaining to sponsored agreements are initiated in ORSP. All sponsor funds are payable to The University of Tulsa and any checks provided to PI(s) must be submitted to ORSP for proper processing in the University system.

Federal agencies require various financial reports including but not limited to: Financial Status Reports or Federal Cash Transaction Reports which are prepared and submitted from ORSP.

For additional Information on Sponsor Guidelines see the link below

 

SPONSOR GUIDELINES AND REGULATORY REQUIREMENTS

Disclaimer: The information above is provided is for general guidance and not meant to be considered all inclusive. Principal Investigators and project staff are strongly encouraged to consult with ORSP representatives for further clarification of each award’s guidelines and any other special terms and conditions that might apply.

See Policies, Procedures, & Guidelines for additional topics.