Technical/Programmatic Reporting Guidance
Principal Investigators (“PIs”) on sponsored projects are responsible for the management and conduct of sponsored activities. As part of that responsibility, PIs are required to understand and comply with the technical/programmatic reporting requirements of their awards, which involves becoming familiar with reporting formats, templates and any online submission portals. To assist PIs, the Office of Sponsored Programs (“OSP”) includes technical reporting information in Section 17F of “Award Checklist and PI Acceptance” forms (i.e., Frevvo) when PIs accept their awards.
2 . Technical Report Due Date Reminders
2.1 Automated Reminders
OSP supports PIs with their federal and flow-through award technical reporting obligations by sending them automated email reminders from Jennifer Lutke via Smartsheet (firstname.lastname@example.org) 45 days before technical reports are due. The email subject line contains the words Technical Report Reminder.
Please read the message body to find the type of report due and your project title. Here’s an example notification:
2.2 Notifications to Deans and Department Chairs
In addition to the automated email notifications described above, OSP also provides monthly reports to Department Chairs and Deans (or their non-academic equivalents) identifying PIs with federal or flow-through award reports due within the upcoming 30 days. Deans, Department Chairs or their designees coordinate with PIs to ensure technical reports are submitted in a timely manner.
3. Corrective Actions for Late Technical Reports
Late technical reporting is a significant issue, as the University is responsible for overseeing sponsored project operations. Technical reports must be submitted at the intervals required by sponsors. Failure to submit timely technical reports can negatively impact a PI’s reputation, and all late technical reports create unnecessary and costly work for University faculty and staff. Additionally, Federal regulations allow corrective actions that have a negative impact on PIs and the University. For example, sponsors may:
- Withhold payments to the University;
- Disallow all or part of the costs of a project;
- Suspend or terminate an award;
- Initiate suspension or debarment proceedings against the University (which could make us ineligible for Federal funding); and/or
- Withhold any additional awards and incremental funding for existing awards.1
If a PI has not submitted a technical/performance report and provided OSP proof of submission prior to the due date for federal and flow-through awards, OSP will notify Department Chairs and Deans two (2) business days after a report becomes delinquent in OSP’s records. The Department Chair or Dean will contact the PI immediately to resolve the issue and take any necessary corrective action.
Additionally, OSP will take the following corrective actions:
- When a federal or flow-through technical report is two (2) days overdue, a PI will become ineligible to submit new proposals as a PI or Co-PI until the technical report has been submitted.
- When a federal or flow-through technical report is seven (7) days overdue, all of the PI’s awards will be deactivated in the financial system. Costs that cannot post to the deactivated awards will be charged to the PI’s surplus/deficit accounts on file. Once the PI submits the delinquent technical report, OSP will work with the PI to reactive awards. However, costs that were incurred during this time are ineligible for transfer back to the sponsored project.
- OSP will also notify the Vice President for Research and Economic Development (“VPRED”) of all federal or flow-through technical reports that become seven (7) days overdue. The VPRED will use his/her discretion to reallocate previous and future Facilities and Administrative (“F&A”) cost allocations to cover costs associated with completing reports in the most expeditious way possible.
- PIs who demonstrate a pattern of late reports may become ineligible to be a PI because they have demonstrated a lack of “appropriate . . . administrative capabilities.” See Policy # 5020 (Principal Investigator Eligibility.
4. Frequently Asked Questions
4.1 What should I do if due dates change?
OSP recognizes that technical reporting due dates may change during the course of a sponsored project. If you receive a due date change notification from a sponsor, you are responsible to promptly inform OSP at email@example.com so our records can be updated. This will avoid unnecessary escalations.
4.2 What should I do if due dates are not listed in the award?
Certain sponsors (e.g., U.S. Department of Education) do not list technical report due dates in the award document. They may instead provide the due dates to you at a later date. If you do not have the technical report due dates, you should contact your Program Manager / Technical Contact for more information. Once you have the dates, promptly inform OSP at firstname.lastname@example.org so our records can be updated.
4.3 What should I do if I cannot meet technical report deadlines?
If you cannot meet technical report deadlines, you should first contact your Program Manager / Technical Contact to see if it’s possible to obtain a deadline extension. Your Program Manager / Technical Contact is not required, or may not have authority, to grant an extension.
If the extension request is unsuccessful, promptly contact your Department Chair and/or Dean. They may be aware of other resources available (e.g., graduate students) to assist you. Be advised that your Department Chair and/or Dean may, among other things, reallocate previous and future F&A cost allocations to pay for these additional resources.
4.4 Do I need to submit technical reports if I have requested a no-cost extension?
Yes. Unless you have written confirmation from your Program Manager / Technical Contact that your report is not due, you must submit your report by the existing deadline.
For example, National Science Foundation has advised: “A ‘no cost extension’ adds time to an award, but does not relieve the awardee of reporting requirements. Annual reports are still due every 12 months. When the award finally does expire, the final report and project outcomes report are both due within 120 days.” See, e.g., Dear Colleague Letter No. NSF 16-040 (PDF).
4.5 What constitutes “proof” I have submitted my technical report?
The automated email reminders described above ask that you submit a copy of your technical report to email@example.com. Other acceptable methods include: (i) copying firstname.lastname@example.org when you submit your report via email; and (ii) forwarding a copy of a confirmation you receive from an online portal after your submission. Please note that merely stating you have submitted your report is not sufficient. OSP needs written information from an independently verifiable source, as OSP may be required to provide this information to our external auditors.
4.6 Does OSP have any additional technical report guidance for specific sponsors?
Yes. OSP has developed NSF Technical Reporting Guidelines to assist you.
4.7 Can OSP help me submit my technical reports or obtain due date extensions?
OSP is happy to help you understand the terms and conditions of your award, including technical report due dates, but it is your responsibility as a PI to: (i) prepare and submit technical reports (including researching how to submit your reports via online portals); and (ii) obtain written due date extensions from your Program Manager / Technical Contact. If you still have questions or concerns after researching how to prepare and submit your reports, please email OSP at email@example.com; OSP will seek additional resources to assist you.
4.8 Do I submit financial reports to sponsors?
Typically, sponsors should receive technical reports from PIs and financial reports from OSP Sponsored Project Administrators (“SPAs”). Some sponsors require periodic reports to contain both technical and financial information. In these limited situations, you should coordinate with your assigned SPA (assigned by Department number) to obtain updated financial information before submitting the combined report.
1 For example, if a PI has a late technical report on her/his award, a sponsor like NSF can withhold the issuance of continuation funds for: (i) the award with the late report; (ii) the PI’s other NSF awards; and (iii) NSF awards on which the individual with the late report is a Co-PI (impacting relationships with other colleagues).