PART III POST AWARD PROCEDURES
Congratulations on winning a grant award! The OAGSR (the Grant Management and the Office of Finance and Business Services (OFBS), and the Office of Human Resources (HR) guide faculty and staff through the external and internal regulations and policies governing grant awards. We have the expertise and resources necessary to help the PI (Principal Investigator) use the award wisely and in compliance with the terms of the proposal, contractual agreements, and all appropriate regulations. Part III of the GPPM provides detailed procedures for implementing the grant award, including Planning, Award Management, and Closing the Grant.
PLANNING
Planning and managing a grant requires reliable information and careful coordination and cooperation between and among the PI, the OAGSR, and the funding source. Because any failure to adhere to pertinent rules and regulations can result in the termination of the award by the funding agency or disallowed expenses (requiring the College to replace the disallowed funds), good planning is essential. The PI is responsible for ensuring that the work of the project is carried out as proposed and that the funds are expended in accordance with sponsor requirements, College policies and procedures, and federal and state laws. OAGSR supports the PI in carrying out those responsibilities by providing information, guidance, and approval throughout the term of the grant.
This section discusses mechanisms that are in place to facilitate responsible, transparent grant implementation: the AIM meeting, guidance in accessing and monitoring the People Soft Account set up for your grant, and a listing of the most commonly used funding agency and regulatory guidelines. As part of the effort to plan for the implementation of a grant award, the PI is encouraged to review Part I of this manual for Principles Guiding Sponsored Programs at TCNJ, Roles and Responsibilities, and general internal and external policies guiding sponsored research.
AIM Meeting
Immediately upon acceptance of an award by TCNJ for most projects, someone from the OAGSR will contact the Principal Investigator (PI) to set up a date for an Award Implementation and Management (AIM) Meeting. The meeting is designed to review PI responsibilities in carrying out the grant and College resources available to support the PI. The PI will meet the people from OAGSR and OFBS who will guide him or her in the various aspects of award management, including planning and program implementation, establishing and managing the grant account, hiring, procuring products and services, and reporting.
The PI should plan to bring the final award budget, the PeopleSoft Chartfield numbers for any cost share committed to the project, and other pertinent documents. The PI may invite key personnel who will be instrumental in the administrative and financial aspects of the grant.
ACCOUNT SET UP/WEB ACCESS
The grant budget is usually finalized and confirmed at the AIM meeting. Once OFBS has all of the necessary award account information and the PI Award Acceptance Form has been signed, the Grant Administrator will set up the grant account on PeopleSoft.
The PI is responsible for providing OFBS with the specific PeopleSoft chartfield numbers from which cost share funds will be pulled. This information is needed before the grant account can be set up and before grant expenses can be charged.
Once the grant account is established, the PI can check the status of the account at any time by accessing the Web Report. Instructions are provided at the OFBS website. Before every expenditure or reallocation, the PI must check the web report for that account to see that there are sufficient funds to conduct the transaction desired. The web report should be checked periodically also, to reconcile the postings and ensure that they match your records.
Modification of Award
Occasionally, modification of an award in terms of project scope or budget is necessary. Such modifications or amendments require prior approval from the funding agency, and each agency has specific requirements for obtaining approval. Consult the award documentation for details. Proposed changes in project scope or budget must be processed through OFBS.
Reallocation of Funds
With a good project plan, the need to reallocate funds on a grant budget should be minimal. However, occasionally unexpected circumstances arise that require moving funds.
Reallocation Forms can be downloaded from the OFBS website. Before completing the Reallocation Form, the PI should
- check the Web Report to ensure that there are sufficient funds in the account, and
- review the proposal, award, and sponsor regulations to determine reallocation limits and/or requirements.
The completed reallocation form is submitted to OFBS for approval and submission to Budget and Finance.
Keeping Records
We recommend that the PI establishes a systematic record-keeping system for the project. These records should be reconciled periodically (we recommend monthly) with the web report.
Funding Agency and Regulatory Guidelines
In order to effectively manage a grant project, it is essential for the PI to carefully review the policy and procedural requirements of the funding agency. She or he should also continually review the award instrument for terms and conditions attached to the award.
Most funding agencies fall into one of three categories: federal, state and/or local government, private. Many agencies publish a procedural manual or guide to be used agency-wide. Federal agency-wide manuals most frequently used by TCNJ faculty and staff include:
US Department of Education Education Department General Administrative Regulations (EDGAR)
National Science Foundation - Award and Administration Guide Posted January 2008
National Institutes of Health, Office of Extramural Programs, Grants Policy and Guidance
The most commonly used state regulations include:
NJ Department of Education Grant Management website
NJ Department of Education Grant Recipient’s Manual for Discretionary Grants
For the government-funded projects, in addition to the specific award agreement and agency-wide manuals, general state and federal policies and procedures are in effect in grant awards. The federal regulations in the following documents guide grant activity at both state and federal levels.
Circular No. A-21 -- Cost Principles for Educational Institutions
OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations
Federal Acquisition Regulation's (FAR) Home Page
OMB Circular A-110, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations"
PROJECT MANAGEMENT
Sources of Funds
After a grant award is made, the funds are received at the College in several different ways. Some agencies send lump sum portions of the entire award at intervals during the period of performance. More frequently, monies come to the College on a cost reimbursement basis, usually after an invoice or electronic report is sent from the College to the funding agency delineating expenditures during the funding period (usually quarterly or monthly).
Most of the funds are electronically “drawn down” from the funding agency and deposited directly into the appropriate TCNJ account. Many of the award payments arrive in check form.
Procedures for Depositing Grant Income/Payments
The flow chart below delineates the procedures to be followed to deposit (transmit) payments received by the College in check form. Because many grants also have Enterprise programs associated with the grant, transmittal procedures for both grants and Enterprise programs are included.
This section provides guidance for expending grant funds. It explains procedures for hiring and/or payment to grant personnel; procedures for purchasing equipment, supplies and other items; travel regulations; procedures for setting up and monitoring subawards; and project reporting requirements.
Even though most procedures to expend grant funds are almost the same as those followed for the expenditure of College funds, there is one major difference: all grants expenditures must be approved by OFBS before payment can be made; all consultant payments and supplemental salary payments require additional signatures from OAGSR and HR.
THE SEVEN MAJOR CATEGORIES OF EXPENSE PROCESSING
Grant Personnel Hiring and Payment Procedures
FACULTY REASSIGNED TIME, SUMMER SALARY, AND TIME AND EFFORT REPORTING
Faculty Reassigned Time
When the award is received, faculty names and the amount of reassigned time are recorded in the Post Award database. Every semester, a listing of faculty with reassigned time for that semester is confirmed by OFBS with the Effort Certification Form (see Time and Effort Reporting).
Time and Effort Reporting
Time and Effort Forms are provided by OFBS and need to be completed by all personnel working on grants (both faculty and staff). Time and Effort forms need to be signed by the department chair or unit supervisor for faculty and by the principal investigator for other grant personnel.
Summer Salary for Faculty
Summer salary for faculty is calculated at a maximum of 10% per month of work, based on the salary base from the preceding year. The actual amount paid in a particular grant cannot exceed the amount indicated on the grant agreement budget and the total for all grant summer payments may not exceed the 10% base salary per month limit.. Payment is spread over the summer months. The Supplemental Payroll Authorization Form must be completed and sent to OAGSR for approval, after which it is then forward to HR, then the Grants Accountant in OFBS for payment authorization and forwarding to Payroll for payment.
NEW FULLTIME OR PART-TIME EMPLOYEES ON A GRANT
All grant hiring is expected to generally follow normal TCNJ Affirmative Action & Office of Human Resource procedures.
To hire an employee on a grant, begin by completing the Authorization for Employment form and submitting it to the OAGSR along with all supporting documentation. Once it is approved in OAGSR the form is forwarded to Human Resources (HR) for additional approval and processing. HR will generate the offer letter and contact the employee (if necessary) regarding the first day of employment. (HR orientation should be scheduled for this day.) The offer letter with all new-hire paperwork will then be mailed out to the employee. Once those forms are returned and the orientation is completed, the employee may begin work. Payment for part-time employees is generated from the Supplemental Payroll Authorization Form.
For all new fulltime held positions, the Grant Position Request Form must be completed first, and submitted to OAGSR. After initila approval, OAGSR will forward the form to the PI who will then contact Human Resources and follow normal college new employee selection procedures, including advertising, screening, and interviewing in order to identify the prospective new employee. Contact the Office of Human Resources (HR) at x2622 for specific instructions.
Once the candidate has been selected, the Authorization for Employment form can then be completed and the procedures described above are then followed.
HIRING CONSULTANTS VS. SUBAWARDS
It is often difficult to determine whether certain outside services needed by a grant project should be treated as a consultant or as a subaward. The following list of criteria was developed to assist in distinguishing between the use of a Consulting Agreement or a Subaward:
Consulting Agreement
- Given to independent contractors (individuals) or consulting organizations for professional services
- Tasks are specific, well-defined and of limited scope
- The consultant role is that of a hired service and not a collaborator.
- Given to colleges and universities, other institutions and organizations
- Usually has a partnership role, even when it is a small one
- Often has more autonomy in the completion of the work, within the parameters of the agreed-upon work plan, timeline, and budget
Once the determination has been made that a particular service provider is, in fact, a consultant, these steps should be followed to process payment for that person.
1. Complete the ICR and W9 form and submit it, along with the consultant’s vitae, to OAGSR for approval and forwarding to OFBS, the HR department for final approval.
2. After approval from OAGSR, the PI will complete the Professional Services Contract and submit it to OAGSR for signature and transmittal to OFBS, then HR for final approvals, encumbering the funds, and assigning a PO number.
3. After work has been completed, the consultant will need to submit an invoice to the PI. The PI completes and submits four items to OFBS: the Consultant Evaluation Form; the original invoice with the Project grant number, the PO number (from the Consultant Contract), stamped “Approved for Payment” and signed by the PI; and a copy of the completed work when feasible.
STUDENTS
All students hiring must follow On-Campus Student Employment policies and procedures set out in the career services Office.
For step-by-step instructions for hiring student employees, click here to go to the Career Services web site.
An advance request must be sent to Career Services for student employees/research assistants who will be paid more than the standard student pay rate. Please e-mail justification to Amy LoPrinzi, loprinzi@tcnj.edu.
Purchasing and Contracting
All goods and services are to be procured through the College’s Purchasing Department, regardless of funding source. The only exception is that every purchase must first be approved by the grant accountant in OFBS. Depending upon the nature and cost of the item, the PI will follow one of these processes: NJ State contract, credit card, quick payment form method, agency purchase order form method.
Proceed to the Basic Purchasing Guidelines page of the Budget and Finance Website for all TCNJ procurement regulations.
PURCHASING COMPUTER-RELATED EQUIPMENT
Some computer-related equipment can be purchased on state contract, but all computer-related equipment or equipment with computer components, must be discussed with Jeff Philburn. All PCs, Printers, PDAs, etc., and anything that will be on the network needs to be discussed with Jeff Philburn, x2660, philburn@tcnj.edu to determine support and compatibility.
Most office supplies can be ordered through the NJ State contract with Office Max. Simply go to the Office Max website, request a login, then order online.
REQUESTS FOR WAIVER OF ADVERTISING
In the event that a Waiver of Advertising must be prepared, the PI must contact OAGSR as soon as the purchase is identified so that the waiver is submitted properly and on time.
Before the budget item needing waiver of advertising can be purchased, the Board of Trustees, at a regular quarterly meeting, must waive advertising on that item based upon justification for waiver provided by the PI. The justification for waiver should arrive in OAGSR at least one month prior to the scheduled Board meeting (see Board of Trustees website for meeting dates). The justification should include the following:
PI Name and Grant Project Title
Description of service or item being purchased
Rationale for waiver of public advertisement
Number of vendors contacted (at least three if possible), including name and amount of quote (if sole source, please identify)
Since only the Board of Trustees is empowered to award these contracts, it is important that as much information as possible be submitted to assist them with their deliberations and decisions.
Travel Regulations
Follow travel regulations authorized at the OFBS website
Subawards
When TCNJ is the prime recipient of a grant that has sub-recipients, a Subaward Agreement is sent to the sub-recipients by the OAGSR. Subawards over the TCNJ dollar threshold may be subject to Board Approval for Waiver of Advertising before the Subaward Agreement can be completed. Contact OAGSR for determination.
The PI should complete the non-shaded sections of the Subaward Agreement, develop the Statement of Work and Timeline, the subaward budget, and any other special provisions for the entire grant period, and email all of these documents to the OAGSR for final processing and delivery to Subawardee.
OAGSR ensure that the subaward document is in accordance with the terms and conditions of the prime award and send two originals to the subawardee for signature. Subawardees are requested to return both signed originals to OAGSR to countersign, sending one countersigned original back to the subawardee. OAGSR is responsible for all negotiations of the subaward and for any changes to the subaward document.
Modifications to Subawards
A subaward may be modified at any time within the period of performance. Modifications can extend the period of performance, increase the amount, append additional tasks to the Scope of Work, or modify other terms and conditions as appropriate.
To initiate the modification process, the PI sends a written modification request to OAGSR (new year of funding, no-cost extension, additional tasks, etc.). Relevant attachments such as a new Scope of Work or new budget must be forwarded to OAGSR along with the request to modify the subaward. OAGSR will prepare the subaward modification document and obtain appropriate signatures.
Project Reporting Requirements
Because considerable attention is focused on getting funding for a project and then on implementing the project and meeting compliance requirements, it is easy to shortchange an equally significant aspect of grantsmanship, reporting the progress and outcomes of the work to the College and to the funding agency. Careful, thorough reporting of grant activity is an essential component of grant management. It documents the accomplishments of the project; it assures responsible stewardship of external funds; and it highlights the impact the project has had.
External sponsors usually require two types of reporting: technical (or programmatic) reports and financial reports.
FUNDING AGENCY REQUIREMENTS
Once TCNJ has entered into an agreement with a sponsor, it is TCNJ's responsibility to comply with all reporting requirements of that agreement. Funding agency reporting requirements are normally included in the award document and are confirmed at the AIM meeting. Financial reports are completed by OFBS and reviewed by the PI. Technical/programmatic reports are completed and submitted by the PI, with an electronic or a paper copy sent to OAGSR. OAGSR will copy and mail reports received at least three days before the due date.
Program/Progress/Technical Reports
Sponsored programs usually require final (and sometimes interim or annual) programmatic/technical reports from the PI. Annual reports document the progress to date on a given project. The final report usually includes a detailed description of the work performed, progress made, suggestions for future areas of study or involvement, and any related publications that resulted from the sponsored activity. Most sponsoring agencies have specific guidelines for the preparation and submission of reports. Reporting requirement specifics, found in the award terms and conditions, are provided to the PI at the AIM meeting. Failure to submit the final technical report in a timely manner may jeopardize subsequent funding and release of cash to the College. \
Financial Reports
A good financial report is simply an accurate, detailed itemization of every expenditure made for the project. Draft interim and/or final financial reports for grants and contracts are prepared by OFBS and sent to the PI for the necessary corrections and approvals. Once the draft report is approved and returned to OFBS, the final interim report is prepared, authorized on behalf of the College, and mailed to the sponsor. These reports are audited every year through the College’s regular auditing process, and can be audited by the external funding agency at their discretion.
No-Cost Extensions
On rare occasions, the work of a project will need to be extended beyond the project period. In such cases, it is possible to request a No-Cost Extension (NCE) from the sponsor. Requests for No-Cost Extensions should be made to OAGSR at least 30 days before the sponsors NCE decline or 90 days before the end of the period of performance of the grant. The request should include the name of the PI, project title, ChartField number, project dates, and a clear and concise rationale for the extension. If authorized by OAGSR, the extension date will be requested from the sponsor.
CLOSING THE GRANT
ENCUMBRANCES NEAR TO AND AFTER TERMINATION DATE
All supplies, services, and equipment must be received and used during the project period. Items received after the award period cannot be of benefit to the project, and auditors routinely disallow charges for such items even if they were legitimate charges at the time the order was placed. Place all orders for supplies and equipment well in advance (60-90 days) of the account expiration date to ensure delivery and use prior to that date. If you need additional time to complete reports or to acquire supplies, contact OFBS to inquire about a no-cost extension or to make other arrangements.
The closing of awards begins 30 days after the expiration date. OFBS will freeze the account, which prevents further expenses from being charged. The PI will be notified of the freeze and sent a Rough Draft Financial Report. The PI should review this report and indicate any necessary adjustments to expenses. Adjustments should be supported by accompanying documentation. The rough draft financial report should be signed by the PI.
The signed rough draft is returned to OFBS by the College due date (usually about one week after it was sent) so that the final financial report and/or invoice may be prepared and sent to the sponsor by the required date. Typically, the final invoices/financial reports are due 90 days after the award termination date. If a different time frame for the submission of the final invoice/financial report is indicated by the award notice, then the above process is adjusted accordingly.
The grant project file is officially closed when all reports ( performance/technical, and financial), have been submitted and the copies are on file in OAGSR & OFBS.
