Division of Title III Administration and Sponsored Programs
Managing the Grant
The Project Director is responsible for management of a grant or contract. A co-director may be designated and will be expected to complete the project in the event the Project Director becomes unavailable. The Director is expected to conduct the affairs of the
grant or contract in full compliance with provisions of the contractual agreement. Particular requirements governing a grant are usually provided with the grant award notification. Project Directors should become thoroughly familiar with any special terms
or conditions that should be adhered to in the conduct of the funded project. Sponsors will usually request a progress report on programs when they are finalized and/or at intervals during their operation. The Project Director is responsible for narrative involvement. All financial information should be provided by the University’s Business Office. Under no circumstances should a Project Director attempt to unilaterally provide the financial information to the sponsor. This action could cause serious auditing problems.
Fiscal Accounting Procedures
The Office of Sponsored Programs adheres to the Office of Financial Affairs’ policies and procedures in fiscal accounting for managing grants and contracts to include the establishment of an institutional indirect cost rate negotiated with the sponsoring agency.
Establishing an Account
An account is the financial record established by the Office of Financial Affairs to provide current information on the income and expenditures of projects. Each project is assigned its own account (identified by an account number). Expenditures can be made
for a project only after an account is established for the project. In order to establish an account the following must be done:
- Official notification of the grant award must have been received prior to establishing the account;
- The Project Director must meet with the Vice President for Financial Affairs and
complete a project budget;
- Hard matching funds must be transferred from departmental or unit accounts to the project account or a firm commitment must be on hand from a non-federal source.
Change to scope/objectives – the recipient shall obtain prior approval for any change to the scope or objectives of the approved project. (For construction projects, any material change in approved space utilization or functional layout shall be considered a change in scope).
Changes in Key Staff – The recipient of a grant or sub grant for research (or any kind of grant or sub grants if the terms of the award make this rule applicable) shall obtain prior approval: 1) to continue the project during any continuous period of more than 3 months without the active direction of an approved Project Director or PI; or 2) to replace the Project Direct or Principal Investigator (or any other persons named and expressly identified as key project people in the notice of grant or sub grant award) or to
permit any such people to devote substantially less effort to the project than was anticipated when the grant or sub grant was awarded.
Significant Changes may include: 1) a change in federal grant or contract effort is considered significant; 2) a change in function is significant; 3) a significant change must be instituted by the director of a federal grant program or the PI of a sponsored research program; 4) anything greater than a five percent (5%) change of a federal grant program or the PI of a sponsored research program; and 5) most changes required will be prospective changes that will process in the next monthly payroll cycle.
Other programmatic changes
The following shall require prior approval except to the extent explicitly included in the
project plan as approved by the awarding party at the time awarded: 1) providing financial assistance to a third party by sub granting or any other means; 2) transferring to a third party, by contracting or any other means, the actual performance of the substantive programmatic work. The term substantive programmatic work means activities which are central in carrying out the purpose of the project, and not merely incidental. Transfer of substantive programmatic work does not include purchase of supplies, materials, or equipment; acquisition of general or incidental support services; obtaining advice; or transfer of activities whose cost is treated as an indirect cost; and 3) providing medical care to individuals under research grants.
Supplant is defined as substituting grant funds to pay for personnel activities, services, or
other costs that were supported from other sources prior to receipt of a grant or such costs
that are contained in the current institutional budget. Examples include the following:
- An employee (administrator or faculty) continues to perform the same function as he did prior to the receipt of Federal funds but is now paid partially or completely with Federal funds.
- Funds regularly budgeted for travel, supplies, contracts, consultants or equipment is replaced with Federal funds.
Supplement is defined as using grant funds to correct a deficiency in an existing activity
or service, or to improve, enrich, or enhance an existing service or activity through the
addition of new services or activities.
Project Directors and PIs are encouraged to seek assistance from the OSP and
grant officials when there are questions concerning the issue of supplanting institutional
funds. It is very important that grantees maintain appropriate records and accounting
procedures to ensure that compliance is achieved with regard to this limitation.
Purchasing and Accounting
Once an award is made, there are some logistics that must either be in place or put in
place to increase the chances that the proposal objectives are met and that the policies and
procedures of the granting agency, as well as, those of the university are followed.
- Requisitions: Requisitions are made routinely with the appropriate account name and number (accounts are set up for funded projects in the Comptroller’s Office via a written request addressed to the Special Assistant to the President/Title III Administrator and Director of Sponsored Programs.
- Purchase Orders: The purchase order (PO) is the official document authorizing the purchase of requested items. POs are issued from the Purchasing Officer in the Purchasing Department.
- The Bid Process: Virginia Union University.
Time & Effort Reports
Effective October 1, 1986, the University implemented a revised time-and-effort reporting system to comply with the standards for documentation of labor costs charged to federally funded programs or sponsored research programs.
The standards for documentation for personnel costs charged to the grant are set forth in the Education Division General Administrative Regulations (EDGAR) Par 74 Administration of Grants Subpart Q Cost Principles Section 74.174 Part II B, which
“The costs of such remuneration are allowable to the extent that the total compensation to individual employees is reasonable for the services rendered and conform to the established policy of the institution consistently applies and provided that
the charges for work performed directly on Government Research Agreements are determined and supported as herein provided.” 45CFR 100, Appendix C. Section J.7d. Section J.7d provides that for proper documentation of professional salaries, the
contractor’s payroll system must be supported by one of two methods:
1. “An adequate appointment and workload distributions system accompanied by monthly reviews performed by responsible officials and a reporting of any significant changes in workload distribution.”
2. “A monthly after-the-fact certification system which will require the individual investigators, deans, departmental chairs or supervisors having first-hand knowledge of the services performed to report the distribution of effort.”
The system for time and effort reporting consists of the following:
1. Employees (professionals, faculty, administrators and support staff) remunerated, in whole or in part with federal grant funds.
2. Monthly employees who charge time directly to sponsored research agreements or who fulfill cost sharing requirements.
3. Monthly employees who distribute their monthly salary to more than one effort activity (either direct or indirect).
1. Faculty appointments are for 9 to 10 months in duration.
2. Nine to ten-month contractual faculty members may perform instruction in the summer session in addition to their normal contractual workload.
3. Professional, administrative, and support staff appointments are for 10, 11, or 12 months in duration.
Monthly, all staff covered (see System Coverage) will receive a complete Faculty and Staff Time & Effort Report.
The report will be signed by the employee and employee’s immediate supervisor. If the employee’s immediate supervisor is absent, the senior Administrative Officer of that division/department has the authority to certify the employee’s time.
All monthly reports must be returned on the 10th of the following month to the OSP to be forwarded to the Business Office. Payroll checks for those persons who do not submit completed time and effort reports will be withheld the following month.
Monthly, all staff covered will complete a Faculty and Staff Monthly Activity Report reflecting either “no change” or, where applicable, the “significant change” in time and effort.
All monthly reports should be returned normally within five working days after the end of the month to avoid retroactive payroll changes resulting from the significant changes in time and effort.
When it is anticipated that a portion of work to be performed under a grant or contract is to be subcontracted to an outside organization, the PI should first contact the Office of Sponsored Programs to make known the requirements of the subcontract. The PI must make no advance commitments, implied or otherwise, to potential subcontractors regarding the award of subcontract work. Some of the requirements that must be coordinated between the PI and the OSP are listed below:
- Prepare the “Statement of Work” and “Schedule of Payments” to be included in the subcontract;
- Develop a list of potential bidders (if necessary to consider only a single source, an explanation of the reason should be provided);
- Prepare and submit a “Request for Proposal”;
- Obtain sponsor approval prior to awarding of subcontract work.
- Determine that adequate funds are available to cover the subcontract work.
Keys: Collect university keys from all project staff and return them. Note: Appropriate deans and department chairpersons are to maintain key control for all labs and offices.
Project Files: A review of all project files. Budgetary and personnel information should be forwarded to the dean’s/director’s office for storage. All project files should be retained for three years because of the possibility of an audit.
Budget Close-Out: The most recent budget printout available from the Comptroller’s Office should be reviewed by the Project Director to ensure that all charges reflected in the printout and that funds are not over expended. During the last two weeks of the
budget period, the Project Director should meet with the Comptroller to review the budget.
Final Report: The final report required by the funding agency should be completed and submitted and copies forwarded to the dean’s/director’s office and the OSP.
Project Close-out Checklist
- Office of Human Resources notified of University supporting personnel position Terminations
- Complete Personnel Action Forms to terminate these employees
- Use remaining vacation leave
- Telecommunications notified to stop telephone service
- Dean’s/director’s office notified of furniture and equipment to be transferred
- Keys returned
- Files reviewed and stored
- Budget closed-out
- Final report submitted to funding agency with copies to dean/director and OSP
Subcontracting Practices and Procedures
I. With Private Funds
What is a Subcontract?
A subcontract may be defined as “an agreement written under the authority of and consistent with the terms of the Prime Award (grant or contract) that transfers a portion of the research or substantive effort to another organization.” This definition contains
four critical phrases, (as italicized):
Agreement: A subcontract is a formal, legal contractual instrument. The term subcontract is more correct than the often used terms sub grant and sub agreement. While it may seem logical to refer to a lower tier relationship from grant funds as a sub grant,
the bilateral agreement, which is actually a contract.
Authority of: Prior to transferring any substantive effort to another institution, approval of sponsor is usually required. Award from private sources may not be clear about the assignment of work to another party; sound practice, however, dictates that the sponsor be consulted beforehand. Otherwise, costs associated with a subcontract, which did not have prior approval may not be considered as allowable costs under the prime award.
Consistent with: An effective subcontract will establish the critical parameters of the relationship and will set out the rights and responsibilities of each party, but in particular will require that the subcontractor will conduct the project in accordance with the terms and conditions of the prime award by transferring or flowing down to the subcontractor the relevant terms of the prime award. Only in this way can the prime awardees exercise the prudent stewardship necessary to ensure fulfillment of its responsibilities under the prime award.
Transfers a portion of the research or substantive effort: In instances when another organization will be responsible for performing a portion of the substantive work for which the prime award was made, a subcontract does not refer to the purchase of goods, equipment or services, which can be handled properly by consulting agreements or purchase orders. The recipient of a subcontract is referred to as a subcontract. Terms, such as, “sub grantee” and “subrecipient institution” is also used.
The prime award is a grant. Contract or cooperative agreement which establishes the
relationship between the funding source or sponsor and the prime awardee. The recipient
of the prime award, or prime awardee, may alternatively be referred to as the “grantee” or
The term sponsor is synonymous with the funding organization or other agency, which is the ultimate source of funds.
What do Subcontracts Accomplish?
A subcontract serves to identify clearly the obligations and responsibilities of the collaborating organizations and to ensure that the sponsors expectations and requirements can be met. Moreover, a formal subcontract agreement demonstrates to the sponsor the
appropriate level of stewardship and accountability.
When Should Subcontracts be Issued?
In deciding whether to issue a subcontract or to use a different vehicle, the awardee should consider the following question: what type of activity will be performed and is it an integral part of work for which the award was made; does the action constitute a
purchase of services or the establishment of a collaborative effort between colleagues; what is the appropriate tone of the relationship which will exist; how much creativity and flexibility will the subcontractor have in developing and accomplishing the anticipated work? These types of factors are more cogent indicators of the vehicle to be used than factors, such as, length of agreement or size of award.
A formal and unique subcontract should be drafted, negotiated, and implemented
whenever a portion of the substantive work for which the award was made will be
transferred to another organization. In such cases, a subcontract is preferable to the use of
general purchase orders, consultant agreements can effectively transfer funds from one
organization to another, and the type of agreement used substantially sets the tone of the
relationship. Purchase orders, for example, are appropriate for vendor relationships and
the purchase of supplies and services, such as, fabrication, some statistical analysis, etc.;
subcontracts are the correct vehicle for the transferring programmatic work, whether
research, training, curricular reform, or conferences, etc.
Handling Rejected Proposals
There are many reasons for proposals being rejected. Proposal developers are
encouraged not to take a rejection of a proposal personally; a number of meritorious
proposals get turned down for lack of funds. On a rejected proposal, one should get the critique from the agency, address reviewers’ comments, and resubmit. You may not agree with the comments and you do not have to accept, but they should be addressed. Success rates of first submissions run anywhere from 25% to 35%, depending upon the agencies. When a proposal is re-evaluated; modified as necessary and resubmitted, chances of funding increase dramatically in a number of cases. The suggestion on rejected proposals is to try, try, try and try again.