Step 7: Award Management

The below information is a brief overview of the Post-Award Process that Grant and Contract Accounting follows in its post-award administration of awarded sponsored projects.

Please note that this overview also includes a breakdown of principal investigator, budget manager, and department administrator responsibilities, as they relate to the post award management and compliance of sponsored projects.

I. Post-Award Administration Oversight and Guidance

1. Provide oversight and guidance of post-award administration to principal investigators (PI) and departmental staff to ensure compliance with sponsor terms and conditions, as well as university policies and procedures
2. Assists PIs, department grant administrators, and staff by providing guidance on policies and procedures and the Grant Financial System
3. Provide training to update administrative staff and PIs regarding changes to agency guidelines as well as institutional policy, procedures, and financial systems

II. New Award Setup

1. Establishes and monitors sponsored research projects within the Grant Financial System
2. The Account Set Up/Change Checklist is to be used to establish the main grant ID and fund numbers, including cost share funds where applicable, within the Grant Financial System Maintenance screens. This process is used to establish new awards, process continuations, no cost extensions (NCE), and advanced expenditure authorizations in the Grant Finance System
3. Load budget based on award documentation provided by the Office of Research and  Sponsored Programs (ORSP)
4. The responsible grant accountant will notify the PIs via the New Grant and Fund Communication email when a new FOAP has been established

III. Review and Processing of Sponsored Research Project Expenditures

1. Grant and Contract Accounting (GCA) will review and approve transactions received by a department that are associated with sponsored research projects (i.e. requisitions, payroll authorization forms, ITVs, travel reimbursement requests, check request approval—only used for purchases less than $500, etc.), as appropriate. Please note that subcontract agreements should be in place prior to payment of subcontract invoices
2. Review, approve, and process requests for cost transfers, including salary reallocations related to sponsored projects, as appropriate
3. Monitor expenditure activities on sponsored research funds to ensure compliance with federal regulations, agency specific requirements, and university policies and procedures
4. Review and approve procurement card applications and expenditures, as appropriate

IV. Time and Effort Reporting (Required on Federal Awards)

1. GCA maintenance of the Time and Effort Reporting system
2. A notification will be sent to the PI on a semester basis to complete time and effort reporting
3. Monitor certification of time and effort reporting, ensuring Illinois Tech’s compliance with federal effort reporting regulations

V. Invoicing and Financial Reporting

1. Process account reconciliation of grant expenditures; processing department submitted cost transfers as required
2. Prepare and submit interim and final financial reports and issues invoices in a timely manner, as required by sponsors
3. Execute cash drawdowns through letter of credit draws, monitors accounts receivable, and advance payments; monitor overall cash collection for sponsored projects
4. Prepares and provides special reporting to sponsoring agencies (i.e., ARRA, NSF survey, etc.)

VI. Award Closeout

1. GCA will send PI Award Expiration Notifications via email, as appropriate
2. Coordinate financial closeout and termination of an award with PIs and departmental staff
3. Reconciliation of any deficit or other corrections would then be processed by the responsible grant accountant based on applicable cost transfer/salary reallocation paperwork received by the PI and or departmental staff
4. Complete final reporting, if required
5. Complete final Invention Report, if required
6. Complete Property Report, if required
7. Close out grant/fund(s) in Banner Financial System

VII. Financial Audits

1. Coordinates all audits conducted by external audit agencies and provides information required during audit reviews

Please note that sound fiscal management of sponsored research funds requires knowledge of and adherence to prescribed sponsor and institutional financial guidelines. The principal investigator (PI), on behalf of the university, has primary responsibilities for technical and fiscal management of the project in accordance with the sponsor’s guidelines (i.e., rules, regulations, and/or terms and conditions of the award), as well as the university’s applicable policies and procedures, located on the Controller’s Office website. These documents and forms have been made available to assist PIs in effectively managing their sponsored research awards.

PI fiscal responsibilities during the post-award phase of a sponsored research project include the following:

I. Review Sponsor Award Document(s)

Ensure compliance with terms and conditions of the sponsored project, including compliance with federal and agency regulations and requirements (i.e., prior approval stipulations, budget limitations, and overall sponsor deadlines)

II. Initiate the Process of Personnel Hiring for the Project

The PI will work with their assigned budget manager or departmental administrator to complete the necessary Payroll/Personnel Authorization Form(s)

III. Subcontract Agreements and Subcontract Amendments

Encumber fully executed subcontract agreement and subsequent amendments via a requisition/purchase order processed through the grant financial system

IV. Expenditure Processing

1. Ensure that expenditures are processed in a timely manner and that purchases on sponsored projects are allowable, allocable, and reasonable
2. Review subcontractor and consultant invoices to determine whether services have been adequately performed

V. Project Period Expenditures

Ensure that goods and services are received or performed within the project period

VI. Sponsor Pre-Approvals

Obtain and document sponsor pre-approvals for pre-award spending, budget modifications, and no-cost extensions, as applicable

VII. Sponsor Notifications via the Office of Sponsored Research and Programs (OSRP)

Notify the sponsor when significant conditions related to project status change (i.e., change in key personnel, PI leaving institution) through the Office of Sponsored Research and Programs

VIII. Equipment

Ensure that permanent equipment purchased with grant funds is properly tagged, including notifying General Accounting on property disposition

IX. Time and Effort Certification Reporting

Review and certify time and effort reports related to the project, certifying that labor distributions are in direct proportion to effort expended on the project

X. Cost Share

Ensure that all mandatory and voluntary committed cost-sharing is properly documented, processed, and recorded

XI. Review Account Activity

Account activity must be reviewed on a regular basis to ensure the accuracy of expenses incurred, that expenditures conform to the project budget, and costs are consistent with the project schedule and incurred within the project start and expiration dates. Identify erroneous expenses and works with Grant and Contract Accounting (GCA) and other university offices (i.e. payroll, Bursar’s Office, etc.) to ensure that any issues and errors are addressed and corrected timely

XII. Project Close-Out

Assist in project close-outs in accordance with GCA requirements and sponsor guidelines; please contact the Office of Sponsored Research and Programs for technical reports, patent disclosure, and other non-financial reports

The responsibilities of the budget manager and department administrator, as they pertain to sponsored projects, include:

I. Expenditure Monitoring

Monitor expenditure activities on sponsored project funds within the Grant Financial System on a monthly basis to ensure timely and accurate processing

II. Daily Transaction Processing

Process daily transaction paperwork associated with sponsored research projects (i.e. requisitions, payroll authorization forms, ITVs, travel reimbursement requests, check request approval, etc.)

III. Cost Transfer and Salary Reallocation Processing

Process required cost transfers documentation, including salary reallocations related to sponsored projects, as appropriate

IV. Time and Effort Certification Reporting

Assist PIs in the review of time and effort reporting documents to ensure accurate and timely certification

V. Project Closeout

Assist PIs working with GCA staff to review project expenditures to ensure timely closeout and submission of financial reporting

Any sponsored research travel will be subject to Illinois Tech’s travel policy, unless other guidelines are specified within the award documentation.  It is important that principal investigators (PI) maintain documents relative to grant travel if that travel was purchased with a procurement card and not reimbursed by the university through submission of a travel expense reimbursement.

To view the Travel and Business Expense Reimbursement form, click here.

Fly America ACT

Principal Investigators who have received federal funding are required to comply with the Fly America Act.  What this means to most faculty is that you are required to use United States carriers whenever flying to foreign countries. There are exceptions to this act, so please review the Fly America Act prior to planning for any foreign travel.

I. Definitions

1. The Fly America Act. The "Fly America Act" refers to the provisions enacted by section 5 of the International Air Transportation Fair Competitive Practices Act of 1974 (pub. L. 93-624, Jan. 3, 1975), 49 U.S.C. App. 1517, as amended by section 21 of the International Air Transportation Competition Act of 1979 (Pub. L. 96-192, Feb. 15, 1980). 94 Stat. 43.
2. U.S. Flag Air Carrier. The term "U.S. flag air carrier" means an air carrier holding a certificate under section 401 of the Federal Aviation Act of 1958 (49 U.S.C. App. 1371). Foreign air carriers operating under permits are excluded.
3. United States. For purposes of the Fly America Act, "United States" means the 50 states, the District of Columbia, and the territories and possessions of the United States (49 U.S.C. App. 1301(38)).
4. Gateway Airport in the United States. A "gateway airport in the United States" means the last airport in the United States from which the traveler's flight departs, or the first airport in the United States at which the traveler's flight arrives.
5. Gateway Airport Abroad. "A gateway airport abroad" means the airport abroad from which the traveler last embarks enroute to the United States or at which the traveler first debarks incident to travel from the United States.

II. General Requirements of the Fly America Act

The Fly America Act, 49 U.S.C. App. 1517, as implemented in the Comptroller General's guidelines, Decision B-138942, March 31, 1981, requires Federal employees and their dependents, consultants, contractors, grantees, and others performing United States Government financed foreign air travel to travel by U.S. flag air carriers:

1. Unless travel by foreign air carrier is a matter of necessity as defined in paragraph (b)(3) of this section, or
2. When U.S. flag air carrier service is available within the guidelines in paragraphs (b)(4)(5) of this section.

III. Necessity for Use of Foreign Air Carrier Service

Use of foreign air carrier service may be deemed necessary if a U.S. flag air carrier otherwise available cannot provide the air transportation needed, or use of U.S. flag air carrier service will not accomplish the agency's mission.

IV. Availability of U.S. Flag Carrier Services

1. General. U.S. flag air carrier service is available even though:
   1. Comparable or a different kind of service can be provided at less cost by a foreign air carrier;
   2. Foreign air carrier service is preferred by or is more convenient for the agency or traveler; or,
   3. Service by a foreign air carrier can be paid for in excess foreign currency, unless U.S. flag air carriers decline to accept excess foreign currencies for transportation payable only out of these monies. (See also paragraph (b)(5)(iv) of this section.)
2. Scheduling Principals. In determining availability of U.S. flag air carrier service, the following scheduling principals should be followed unless their application results in the last or first leg of travel to and from the United States being performed by foreign air carrier:
   1. U.S. flag air carrier service available at point of origin should be used to destination or, in the absence of direct or through service, to the furthest interchange point on a usually traveled route;
   2. Where an origin or interchange point is not served by U.S. flag air carrier, foreign air carrier service should be used only to the nearest interchange point on a usually traveled route to connect with U.S. flag carrier service; or,
   3. Where a U.S. flag air carrier involuntarily re-routes the traveler via a foreign air carrier, the foreign air carrier may be used notwithstanding the availability of alternative U.S. flag air carrier service.

V. Guidelines for Determining Unavailability of U.S. Flag Air Carrier Service

1. Travel to and from the United States: Passenger service by a U.S. flag air carrier will not be considered available when the travel is between a gateway airport in the United States and a gateway airport abroad and the gateway airport abroad is:
   1. The traveler's origin or destination airport, and the use of U.S. flag air carrier service would extend the time in a travel status, including delay at origin and accelerated arrival at destination, by at least 24 hours more than travel by foreign air carrier.
2. Travel Between Two Points Outside the United States: For travel between two points outside the United States, U.S. flag air carrier service will not be considered to be reasonably available:
   1. If travel by foreign air carrier would eliminate two or more aircraft changes enroute;
   2. Where one of the two points abroad is the gateway airport en route to or from the United States, if the use of the U.S. flag air carrier would extend the time in travel status by at least 6 hours more than travel by a foreign air carrier, including accelerated arrival at the overseas destination or delayed departure from the overseas origin, as well as the gateway airport or other interchange point abroad; or,
   3. Where the travel is not part of a trip to or from the United States, if the use of a U.S. flag air carrier would extend the time in travel status by at least 6 hours more than traveled by foreign air carrier including delay at origin, delay en route and accelerated arrival at destination.
3. Short Distance Travel: For all short distance travel, regardless of origin and destination, U.S. flag air carrier service will not be considered available when the elapsed travel time on a scheduled flight from origin to destination airport by foreign air carrier is 3 hours or less and service by U.S. flag air carrier would involve twice the travel time.
4. Travel Finances Solely with Excess Foreign Currencies: U.S. flag air carriers render themselves unavailable by declining to accept payment in foreign currencies for transportation services required by certain programs or activities of the Government which, under legislative authority, are financed solely with excess foreign currencies which may not be converted to U.S. dollars. In these instances, and notwithstanding the provisions of paragraph (b)(4)(I)(C) of this section, foreign flag air carriers that will accept the required foreign currency may be used to the extent necessary to accomplish the mission of the particular program or activity. The statement of justification required under paragraph (c)(3) of this section must indicate that the transportation service needed can be paid for only in excess foreign currencies and that otherwise available U.S. flag air carriers declined to accept payment in the foreign currencies.

1. Authorization or Approval: Expenditures for commercial foreign air transportation on foreign air carrier(s) will be disallowed unless there is attached to the appropriate voucher a certificate or memorandum adequately explaining why service by U.S. flag air carrier(s) is not available, or why it was necessary to use a foreign air carrier. Use of foreign flag air carriers may be authorized or approved only when U.S. flag air carrier service is not available as determined under the guidelines in paragraph (b) of this section, or when foreign air carriers are used under the reciprocal terms of an appropriate bilateral or multilateral agreement as described in paragraph (c)(2) of this section.
2. Air Transport Agreements: Nothing in the guidelines in paragraph(b) of this section shall preclude and no penalty shall attend the use of a foreign air carrier which provides transportation under an air transport agreement between the United States and a foreign government, the terms of which are consistent with the international aviation goals set forth at 49 U.S.C. App. 1502(b) and provide reciprocal rights and benefits.
3. Justification Statement: A statement executed by the traveler or agency justifying the use of a foreign flag air carrier for any part of foreign travel must be entered on or attached to the travel voucher, transportation request, or any other payment document. Each request for a change in route or schedule which involves the use of a foreign flag air carrier must be accompanied by a statement justifying such use. The following is a guide for preparing the justification statement:
4. Employee Liability for Disallowed Expenditures: Where the travel is by indirect route or the traveler otherwise fails to use available U.S. flag air carrier service, the amount to be disallowed against the traveler is based on the loss of revenues suffered by U.S. flag air carriers as determined under the following formula set forth and more fully explained in 56 Comp. Gen. 209 (1977):
   Sum of certificated carrier segment mileage authorized (¸) Sum of all segment mileage authorized (x) Fare payable by Gov’t Minus (-) Sum or certificated carrier segment mileage, traveled (¸) Sum of all segment mileage, traveled (x) Through fare paid

Code Sharing

On September 25, 1991 the Comptroller General released a decision regarding the Code Sharing of flights by U.S. and foreign flag carriers utilizing the equipment of the foreign flag carrier. This is announced in Comp. Gen. File B-240956. The decision is as follows:

The question in this case, presented by the Department of State, is whether a U.S. flag air carrier's arrangement to provide passenger service in international air transportation on the aircraft of a foreign air carrier under a "code-share" arrangement with the foreign air carrier would meet the requirements of the Fly America Act, 49 U.S.C. App. 1517 (1988). Since it appears that such service generally would be considered to be service by a U.S. air carrier in international air transportation rather than by a foreign air carrier, that service should also be considered transportation provided by a U.S. air carrier for purposes of the Fly America Act.

The concepts of allowability, allocability, and reasonableness of costs address the legitimacy of a cost charged against a specific sponsored research award and are defined and determined by the Office of Management and Budget (OMB), the sponsor's requirements, and/or college policy.

Alongside the principal investigator (PI), Research Administration Services and Grant and Contract Accounting are to ensure that all costs charged to the sponsored research award are reasonable, allowable, and allocable. A determination of these three criteria for a given cost is based on the specific guidelines of the sponsoring agency and according to federal cost principles. 

Allowability

Definition: Legitimate and permissible allowance of grant activity and related costs.

Expenses charged to a sponsored research award must meet the following allowability criteria:

• The costs must be in line with the programmatic or research requirements of the grant being charged
• The costs must be given consistent treatment through the application of those generally accepted accounting principles appropriate to the circumstances.
• The costs must conform to any limitations or exclusions set forth in the sponsored agreement or in the Federal Cost Principles (OMB Uniform Guidance §200.403)

Example: A principal investigator did not budget for an equipment failure, but their existing laser broke and the grant project is stalled until it is fixed. The active grant has a materials and supplies budget that seemingly could support the cost of the laser’s replacement parts. Allowability would be determined by the sponsor’s defined budget terms and conditions (or agency regulations), and whether or not the replacement parts fall into the defined materials and supplies category.

Allocability

Definition: Grant costs are distributed in an equitable manner as to align with the direct involvement of a project.

Allocability ensures a cost has been incurred solely to support or advance the work of a specific sponsored research award. It also means that the process of assigning a cost, or a group of costs, to one or more cost objectives in a reasonable and realistic proportion to the benefit provided or other equitable relationship.

Example: A research grant requires particular chemicals for testing. The chemicals will only be used for this particular project, so the cost is allocated 100 percent to the grant. Conversely, if the chemicals were to be used for multiple grant projects, the expense would need to be allocated to all the awards benefiting in a proportionate manner so as to properly reflect true use and allocation. 

Reasonableness

Definition: Using sound judgment with a fair and sensible approach for reviewing and approving grant financial activity.

The cost must be able to withstand public scrutiny and withstand internal and external review against Federal Cost Principles.   Additionally, preferred vendors and reasonable pricing for goods and services should be engaged as to prevent needless spending on the grant.

Example: A principal investigator (PI) needs to travel overseas in order to present their research at an international conference. Upon choosing a flight, the PI sees two flights with similar departure and arrival times. One flight is one hour shorter than the other, but costs an additional $750 and would slightly exceed the existing travel budget. Would it be reasonable to spend an extra $750 on the grant to save one hour of flight time? The reasonable expectation is to engage cost savings and conduct prudent spending wherever possible.

2 CFR Part 200, Subpart E - Cost Principles of Uniform Guidance

On October 1, 1994, the National Institutes of Health (NIH) implemented the Streamlined Non-competing Award Process (SNAP). The grant mechanisms included in SNAP are administered under the Expanded Authorities' provisions of OMB Circular A-110, which waives cost related prior approvals. The prior approval authorities retained by PHS will remain in effect under SNAP.

The phases of SNAP are as follows:

• Phase I—simplified the requirements of the non-competing application process (1995)'
• Phase II—the Notice of Grant Award was changed to reflect only direct and indirect costs, and indirect costs are now included in the future year recommended funding levels (1996)
• Phase III—Financial Status Reports (FSR) are required at the end of the competitive segment, rather than annually; FSRs will be required by NIH 90 days after expiration of the competitive segment

SNAP Eligibility

NIH grant recipients (including those participating in the Federal Demonstration Project) are expected to follow the streamlined non-competing process for mechanisms routinely covered under expanded authorities, except Program Project Grants (P01s) and Outstanding Investigator Grants (R35s). As published in the NIH Guide for Grants and Contracts, Vol. 23, No. 45, December 23, 1994, NIH routinely applies expanded authorities to Program Project grants (P01s), Minority High School Student Research Apprentice Program awards (S03s), Research Career Awards (K-Series), and all Research Project grants (R-Series), except Phase I Small Business Innovation Research (R43) and Small Business Technology Transfer (R41) awards.

Any award excluded from expanded authorities is routinely excluded from SNAP, unless specifically included in SNAP as a term and condition of the award.

Costs considered “unallowable” must be identified and may not be budgeted, charged, or reported on any sponsored research awards (See OMB A-21, Part J). There are exceptions to these unallowable costs based upon the funding mechanism (i.e., program grants or center awards P41, etc), and the terms and conditions of the award. Please review the circular to review all costs that are allowable with their exceptions.

• Advertising and public relations costs
• Advisory councils
• Clerical/administrative salaries (including secretarial)
• Telecommunications
• Alcoholic beverages
• Alumni activities
• Bad debts
• Commencement and convocation costs
• Contingency provisions
• Defense and prosecution of criminal and civil proceedings, claims, appeals and patent infringement
• Donations and contributions
• Entertainment costs
• Fines and penalties
• Fundraising and investment costs
• Goods or services for personal use
• Housing and personal living expenses
• Lobbying
• Losses on other sponsored agreements or contracts
• Pre-agreement costs
• Selling and marketing
• Student activity costs

Re-Budgeting

The principal investigator or project director is charged with the responsibility of establishing a project’s operating budget and maintaining it within the limits set by the sponsor for the period(s) of the project. Limitations on the re-budgeting of project funds, and requirements to be met in re-budgeting such funds, vary across sponsors. General reasons that may require re-budgeting would include:

• Change in effort/months of key personnel (including principal investigator)
• Need or increase in equipment
• Change in overall scope of work
• Change in subcontract
• Need for additional funds
• Consultants (if not specified in the budget)

No-Cost Extensions

No-cost extensions are necessary when a project is reaching the end date of the award and it is determined that the project requires more time to complete all the specific aims noted in the proposal. This needs to be determined at least two to three months prior to the end of the award.

If re-budgeting or a no-cost extension request is necessary, please contact the Office of Sponsored Research and Programs to initiate the process.

Congress has historically passed a statutory restriction in the Health and Human Services (HHS) Appropriations Act that limits the maximum rate of compensation that can be paid to an individual to the Executive Level I of the Federal Executive Pay Scale. This “salary rate cap” limits the rate of pay directly chargeable to grants, cooperative agreements, and contracts issued by the National Institutes of Health (NIH), the Substance Abuse and Mental Health Services Administration (SAMHSA), and the Agency for Healthcare Research and Quality (AHRQ). For the current NIH Salary Cap Summary (FY1990 - Present), please refer to this link: https://grants.nih.gov/grants/policy/salcap_summary.htm.

The portion of salary in excess of the rate cap is not allowable on NIH, National Science Foundation, and other federal awards. When an employee’s rate of pay exceeds the salary rate cap, the difference between what the employee would have earned at full pay and the maximum amount allowed under the cap for that percent of effort must not be charged to another federal award. The difference may be charged to a privately sponsored award only when specifically allowed by the private sponsor.

Salary in Excess of the Salary Cap

Salary amounts in excess of the NIH salary cap are considered voluntary committed cost sharing. The associated fringe benefits and indirect costs are also considered cost sharing.

Cost-sharing represents that portion of the total project costs (direct or indirect) of a sponsored agreement borne by the university, rather than by the sponsor. There are three types of cost sharing that are described below.

Types of Cost-Sharing

Mandatory Cost-Sharing

Mandatory cost-sharing is that portion of the university contribution to a sponsored project, which is required by the terms of the project. It must be included or a proposal will receive no consideration by the sponsor.

Voluntary Cost-Sharing

Voluntary cost-sharing represents resources offered by Illinois Tech in sponsored project proposals when not a specific sponsor requirement.

Voluntarily committed cost-sharing is defined as those resources that are committed and budgeted for in a sponsored agreement.

Voluntary uncommitted cost-sharing is defined as university faculty effort that is over and above that which is committed and budgeted for but not charged to the sponsored agreement. Voluntary uncommitted cost-sharing should not be recorded as organized research.

In both mandatory and voluntary cost-sharing when an award is received in which cost sharing was proposed, the cost-sharing becomes a binding commitment that the university must provide as part of the performance of the sponsored project. Failure to properly record cost-sharing may result in audit findings that could result in audit disallowances that have to be refunded to the appropriate sponsor.