Award Start-up, Management, and Closeout
Establish New Award
It is critical to establish lines of communication with the PI and other relevant project team members at the inception of an award. Thoroughly reviewing the award and communicating any special terms or restrictions at establishment will help to ensure the award is appropriately established and administered.
Understanding Roles & Responsibilities
Since department structures and project needs vary widely, a meeting with the project team or (at minimum) the PI at the start of the award is best practice. This allows the project team to identify the members responsible for activities within the department and on the award, and facilitates efficient and effective communication. Clearly assigning project duties and responsibilities will help ensure the project runs smoothly.
Creating a Management Plan
Once the team identifies and assigns responsibilities to certain members, documentation is crucial. Email the project team and list all responsibilities. Include administrative department contacts for the technical team (i.e. the person the technical team should contact for effort changes, project purchasing or travel requests, etc.). The PI should confirm responsibilities and notify appropriate personnel if any changes are needed.
Need assistance? Email email@example.com
Manage the Award
- Allocation of expenses
- Monthly reconciliation of expenses
- Ongoing award analysis and planning
- Managing effort on sponsored projects
- NIH salary cap and cost share
- Subawards and consultant agreements
- Record management
All expenses on federally sponsored programs must be allocable, allowable, reasonable, necessary, and treated consistently per OMB Circular A-21. VCU faculty and staff must be aware of the appropriateness of any charges. See Grants and Contracts’ website on Direct and Indirect Costs for further information about the allowability of expenses on sponsored programs. Grants and Contracts also has a website on Unallowable Costs.
Monthly reconciliation of sponsored project accounts ensures accurate and efficient fiscal management of the award while minimizing headaches down the road. Monthly reconciliation also provides the PI with an accurate picture of spending and the remaining balance on the account. Review and retention of backup documentation for expenses is essential to responsible reconciliation.
The Research Dashboard greatly simplifies the process of monthly reconciliation of expenses. At the beginning of each month, the PI will receive a notification that their Monthly Expense Report (MER) is ready for viewing and certification. At this time, the PI and RA should work together to validate expenses for the previous month. The RA verifies that backup documentation exists for all charges on a project during the previous month (this could include approved changes to labor expenses, invoices, order forms, and receipts of purchases). Once any discrepancies have been addressed, the PI electronically certifies the MER in Dashboard. A regular and open monthly dialogue between PI and research administrator/the department is key to responsible spending on sponsored projects. Please see this training for more information on the Monthly Expense Report certification process.
Work with the PI to review the project plan and update it as necessary so that the financial outlays on a project align well with the technical progression. Ensure large commitments such as labor, animal resources, or large equipment, are current throughout the entire budget period to enable the most accurate picture of the unobligated balance available on an award.
The Uniform Guidance (2 CFR Part 200) Section 200.430: Compensation for Personal Services, states that the federal government requires that salary charges are consistent with actual effort in order to ensure that a sponsor is only charged for the amount of effort that directly benefited the project. Effort reporting and certification are a part of VCU’s system for verifying this information.
100% of an exempt employee or faculty member’s effort is considered to be 100% of their institutional activities. “Institutional activities” includes any sponsored research/activity and any non-sponsored instruction, departmental research, administration, public service, or other institutional activities (See Effort Activity Definitions on G&C’s webpage). 100% effort is based on total hours worked, not a set number of hours worked per week.
The PI on a proposal must obligate a minimum of 1% FTE effort for the sponsored project. This 1% requirement does not apply for equipment grants, training grants/mentorship on career awards, travel grants or conference support, or grants that underwrite course activities.
If an individual receives both VCU and MCVP salaries, use the VCU/MCVP salary calculator below to determine the correct percent labor distribution for their VCU PAF.
What is the current NIH/DHHS salary cap?
UPDATE: The Executive Level II rate has been increased to $185,100, effective January 10th, 2016.
What is VCU institutional base salary?
Combined total of contracted VCU salary and MCVP salary
Complying with the NIH and DHHS Salary Limitation
An investigator whose salary is greater than the current salary cap must cost share the portion of salary above the cap for each NIH grant, contract, or cooperative agreement to which the investigator is directly charged. Simply put, if an investigator’s total Institutional Base Salary (MCVP + VCU) is greater than the cap, then the remainder must be cost shared. Cost sharing amounts are proportionate to the amount of effort on the project.
Administrators should work with Grants & Contracts accounting staff to create cost share indexes for each grant, contract, or cooperative agreement to which the NIH salary cap applies. G&C and admins should collaborate to ensure the cost share index is properly linked to the sponsored project Banner Grant ID. Administrators can verify the cost share index is linked to the correct project by reviewing the investigator’s ECRT effort card or using the Cost Share portlet in the RA Dashboard. Both a grant index and cost share index should appear under the Grant ID and description.
The ratio between a sponsored project and a cost share index should always be 1:1 when the investigator’s salary is over the cap. When a cost share index is properly linked to a grant it will appear on the effort report and will provide definitive documentation that the NIH salary limitation was adhered to. At any time the NIH project is being charged salary for an investigator, the associated cost share index should be charged at the appropriate level. If more than one investigator in your area requires cost share on the same NIH project, the same cost share index can be used to cost share both salaries.
For a general discussion of cost sharing and its different forms, see G&C’s website on Cost Sharing.
Excerpts from: Salary Limitation on Grants, Cooperative Agreements, and Contracts (NOT-OD-15-049):
Every year since 1990, Congress has legislatively mandated a provision limiting the direct salary that an individual may receive under an NIH grant… For the purposes of the salary limitation, the terms "direct salary," "salary," and "institutional base salary" have the same meaning and are exclusive of fringe benefits and facilities and administrative (F&A) expenses, also referred to as indirect costs. An individual's institutional base salary is the annual compensation that the applicant organization pays for an individual's appointment, whether that individual's time is spent on research, teaching, patient care, or other activities.
Subaward – A financial and legal mechanism used to transfer a portion of the research or substantive effort of the prime award to another institution or organization. A subaward is a formalized agreement that spells out fiscal arrangements, defines the scope of work to be performed by the subawardee, and flows down the terms and conditions of the prime award to the subawardee.
Consultant Agreement – An agreement between an individual or organization (consultant) and the University whereby the consultant provides services of an advisory nature, usually for a fee. A consultant provides goods and services within normal business operations to many different purchasers, operates in a competitive environment, and may not be an employee of VCU.
Use a subaward if the PI can answer “yes” to any of the following:
- Will the collaborator perform work as part of their institutional appointment?
- Will the collaborator have programmatic decision-making responsibilities?
- Will the collaborator manage technical and administrative aspects of a portion of the overall project?
- Will the collaborator be using institutional facilities, students and/or staff?
Use a consultant agreement if the PI can answer “yes” to any of the following:
- Will the consultant be providing the service outside of their institutional time and commitments?
- Will the consultant be doing so without use of their institutional resources (including students and staff)?
- Will the consultant be paid directly as an individual, above and beyond their institutional salary with associated tax liability?
Need help deciding? Contact: firstname.lastname@example.org
A VCU employee may not be paid as a consultant on one of VCU’s sponsored projects. VCU employees may also not use University resources in conducting a consultant project for another organization or institution (see 2 CFR 200.430 (c)).
To comply with federal regulations, VCU must retain accounting and administrative records for all awards for at least five years or in accordance with the contract or grant stipulations, whichever is greater.
While Grants and Contracts Accounting and Office of Sponsored Programs retain most of the official award records, the department/PI must retain the following files:
- Personnel records
- Transactional level supporting documentation for project direct costs: Supply purchases, Travel, Consultants, Subawards
- Subawardee technical reporting
- Progress and Final Technical Reports
- Lab notebooks, logs, data collected
It is recommended that departments also keep the following records with the rest of the award documentation files in their offices:
- Awards and Amendments
- Progress Reports and Financial Reports
- Correspondence relevant to the management of the award
An approved “Records Retention and Disposition Schedule” must be obtained prior to destruction of any award files.
The Principal Investigator will receive a notice from Grants and Contracts 90 days prior to the end date on the award. The 90-day memo allows the PI to notify Grants and Contracts if there will be additional years with additional money, supplemental money, an extension of the award with no additional funding, if this is the final year of the project, or if this is a fixed price agreement. See Grants and Contracts’ website on Extending, Closing, or Releasing a Contract for more information.
Responsibilities during award closeout
- Ensure expenses are allowable per sponsor and institution regulations/guidelines.
- Confirm expenses are charged to the appropriate project.
- Assist PI with making project changes.
- Communicate progress towards project objectives within stated timeline.
- Assist PI in review of invoices or financial reports and notify of any incorrect charges.
- Assist PI in completion and submission of technical reports and ensure PI compliance with technical reporting requirements.
- Communicate with department to ensure expenses are posted to the correct project.
- Communicate changes in project scope or timelines (NCE requests, award continuations, rebudgeting).
- Review and approve costs included in Invoices and Financial Reports.
- Complete all project objectives stated in award document (progress reports, final deliverables, technical reports).
- Communicate to OSP a statement of inventions and that the final report has been submitted or was not required.