Manage Award

Many, but not all, of the University’s awards are direct or flow-through Federal Financial Assistance agreements (i.e., Federal Grants and Cooperative Agreements).  These awards are generally subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR Part 200 (Uniform Guidance) as described on National Science Foundation’s (NSF) Research Terms and Conditions and Prior Approval Matrix web pages.  The guidance in the subsections that follow is generally based on Uniform Guidance requirements, which are generally not applicable to the other types of awards described in this cautionary subsection.

The University receives many direct and flow-through awards subject to the Federal Acquisition Regulation in 48 CFR Parts 1 – 99 (FAR) and its agency-specific supplemental regulations (e.g., Defense Acquisition Regulations System (DFARS) or Department of Energy Acquisition Regulations (DEAR)).  While FAR-based awards generally follow the same cost allowability rules as Uniform Guidance awards (see 48 CFR 31.303), there are many differences ranging from how proposals are submitted/awarded to the remedies for the University’s non-compliance.

In addition to the above, the University receives many awards from Sponsors not using Federal funds, including states, counties, municipalities, universities, non-profits, for-profits and foreign entities.  For these agreements, the terms and conditions of the award documents (and possibly the associated Requests for Proposals) generally govern the relationship between the Sponsor and the University.

Regardless of the award type, the terms and conditions of the award generally supersede regulatory requirements, if any.  For this reason, it is crucial that you carefully review the Frevvo-based Award Review Checklist and PI Acceptance Form for details about specific requirements applicable to the award in question.

• After Award Acceptance, OSP Post-Award Services does the following:
  • The assigned OSP Financial Technician (FT) generates and sets up the new award and one or more projects in Oracle Financials Cloud (OFC).
  • The assigned Sponsored Projects Administrator (SPA) generates and sends a new award notification email (New Award Notification) to the PI, Business Manager (BM), Departmental Administrator (DA) and other personnel as appropriate.
    • Please keep a copy of the New Award Notification in your records.  This communication provides important award management information, such as the OSP proposal number, OFC award number, OFC project number(s), project and budget period start/end dates, F&A allocation percentages and other useful hyperlinks.
  • Depending on the FTs’ and SPAs’ (and other OSP personnel’s) workload, it may take several days to complete this process.  You can check setup status using the CA Pending Report: Awards, Mods and Advances.
  • Subsequently, the SPA schedules an in-person new award meeting (New Award Meeting), as needed, to discuss the award with the PI, BM, DA and other appropriate personnel (e.g., Accounts Payable should attend if foreign nationals are expected to receive payments from the award).  Discussion points typically include roles and responsibilities, special terms and conditions and basic award management principles.

The University regularly receives multiple-year awards that are funded one year at a time.  In some cases, the Sponsor (for various reasons, including delays in Federal appropriation acts and Federal government shutdowns) may not provide an amendment with funding for the next budget period until the previous budget period has ended.  This creates significant financial management issues because ongoing projects generally require ongoing spending (e.g, salary, fringe benefits), and unless the applicable project(s) is/are extended in OFC’s Project Portfolio Management (PPM) area, costs will not post in PPM.  Consequently, Advance Spending Requests for the next budget period can be submitted and approved when appropriate (see the Pre-Award Spending section below for more details).

During award performance, it may be necessary to adjust the baselined budget in OFC after submitting a Budget Adjustment Request Form.  The following guidance is applicable to such situations:

• Cost Sharing: Changes in the University’s approved cost sharing generally requires advance Sponsor approval (see 2 CFR 200.308(c)(1)(vii)).
• Direct Costs: Rebudgeting among direct cost categories (e.g., salary, fringe, other expenses), even if the cumulative total exceeds 10% of the approved budget, is generally permissible without prior Sponsor approval (see 2 CFR 200.308(e)).
• Direct v. Indirect (F&A) Costs: Rebudgeting amounts budgeted for indirect costs to absorb increases in direct costs, or vice versa, is generally permissible without prior Sponsor approval (see 2 CFR 200.308(d)(4)).
• Participant Support Costs: Rebudgeting participant support costs to other budget categories generally requires prior Sponsor approval (see 2 CFR 200.308(c)(1)(v)).
• Scope Changes: If any of the above budget revisions change the award’s scope of work, prior Sponsor approval is required (see 2 CFR 200.308(c)(1)(i))

Carry-forward of unexpended balances from one budget period to the next is generally permissible without the Sponsor’s prior approval (see 2 CFR 200.308(d)(3)).  However, some Sponsors (e.g., National Institutes of Health) may require prior approval if this is indicated in the award document.

The Basics of Charging Costs to a Sponsored Project answers many common cost allowability questions.  In addition to this guidance, selected items of costs for many different situations are itemized in 2 CFR 200.420 to 200.475.

Cost transfers must be used sparingly and as an exception to normal practices.  “Costs should be charged to the appropriate sponsored project when first incurred.” See Section 4.1.a of University Policy # 5090, Sponsored Programs Cost Transfer (emphasis added).  Further, “[a]ll cost transfers must be accomplished within 90 calendar days of the original charge.”  See Section 4.1.b.i of University Policy # 5090.

No-Cost Extension (NCE) frequently asked questions are available here.  NCEs can be requested from OSP using the Request for No-Cost Extension Form.

Changing a PI or another key person generally requires prior Sponsor approval (see 2 CFR 200.308(c)(1)(ii)), as does the PI disengaging from the project for more than three months or the PI reducing effort by 25% or more (see 2 CFR 200.308(c)(1)(iii)).

Pre-Award spending up to 90 calendar days before receiving the award is generally permissible without prior Sponsor approval (see 2 CFR 200.308(d)(1)).  Generally, the 90 day limitation does not apply to expenditures prior to receiving funding for a subsequent budget period.  See, e.g., NSF Proposal & Award Policies and Procedures Guide 19-1 (PAPPG) Chapter X, Section A.2.b(3), Pre-Award (Pre-Start Date) Costs (“Pre-award expenditures prior to funding of an increment within a continuing grant are not subject to this [90 calendar day] limitation or approval requirement . . . .”).

Detailed sponsored project procurement guidance is available on the Procurement Actions web page.

In most cases, all Equipment and Supplies purchased or acquired under awards from DOE National Laboratory Management & Operating (M&O) contractors are Government Property.  This is inconsistent with almost all other awards the University receives.  One example is subcontracts received from Battelle Energy Alliance, LLC (BEA), the M&O contractor of the Idaho National Laboratory.  Because these property requirements are so non-standard, OSP has developed the Implementation of DEAR 970.5241-1, Property, guidance for campus.

Information about Subaward negotiation, acceptance and monitoring is on the Subawards web page.