Post-Award (Manage Grants)

Account Setup

Advance Account Procedures

If a PI has received notice from a sponsor that a pending proposal has been selected for funding, before activity on the project can begin or costs may be incurred, an account should be created.

If the need exists to start project activity and incur costs in advance of the final execution of the award document, a PI may initiate an advance account request. The establishment of an advance account is approved by the fiscal officer and the resulting department and dean. 

To establish the advance account, the PI must send the following to contracts@siu.edu:

• Verification from the sponsor that includes the award amount and a firm project start date.
• A completed and approved Request to Establish an Advance Account Form.
• A copy of the final approved proposal checklist (including a scope of work, budget and budget justification). 

 Additional considerations:

• The Request to Establish an Advance Account Form must include the budget purpose number that will be used if the proposal is not funded, has a different effective date or if disallowed costs are incurred during the advance period. The fiscal officer of this guaranteeing account must approve the advance account request.
• Unless there are unusual circumstances, the advance account should be limited to three months with an appropriate budget to cover this period.
• If the approvals as defined above, and the required information are not received, the advance account cannot be released.

The following guidelines and documentation requirements must be met for expenses charged to sponsored projects:

• All expenses charged to a sponsored project must be necessary, reasonable, allocable and allowable for the conduct of the project.
• All expenses charged to a sponsored project must be supported by dated original documentation identifying the budget purpose charged and required approvals.
• Documentation, electronic or other, must be made available and accessible at all times for audit purposes.
• Charges not meeting these requirements will be moved off the grant and onto departmental funds.

See below for transactions that require OSPA prior approval.
1. Account Corrections – OSPA approval is required for all account corrections involving a sponsored project.
• Complete the required account correction form and submit the form and attachment(s) to the appropriate OSPA grant assignee.
• If approved, OSPA will route to the appropriate area for further processing.

2. Computer Purchases – OSPA approval is required for all computer or computer equipment purchases involving a sponsored project.
• Complete the computer request form and submit to the appropriate OSPA grant assignee for approval.

3. Equipment Costing >$5,000 – OSPA approval is required for equipment purchases by invoice distribution form (IDF) only.
• Complete the invoice distribution form (IDF) and submit it to the appropriate OSPA grant assignee.
• If approved, OSPA will submit to Accounts Payable.

4. Purchases $10,000 and above – OSPA approval required
• Complete the purchase requisition form and submit to the appropriate OSPA grant assignee for approval.

Effective July 1, 2023, OSPA approval is no longer required on travel vouchers for domestic travel or purchases of <$9,999.99 processed via an invoice distribution form (excluding equipment and furniture). Please see below for the following updates:
5. Travel Voucher – OSPA approval is ONLY required when foreign travel is involved.
• Foreign Travel – Complete the travel voucher and submit it to the appropriate OSPA grant assignee. If appropriate, OSPA approves the travel voucher and forwards approval to Accounts Payable.
• Domestic Travel – Approval for domestic travel should be authorized by the PI and fiscal officer. If the PI and fiscal officer are the same, a secondary signature is required by a next-level supervisor or unit business manager signing under separate signatory authority.

6. Direct Voucher (IDF) Method of Payment (updated) – transactions $9,999.99 or less (excluding equipment and furniture)
• OSPA approval is not needed (excluding equipment paid with IDF and payments to sub awardees). Approvals at this level should be authorized by the PI and fiscal officer. If the PI and fiscal officer are the same, a secondary signature is required by the next-level supervisor or unit business manager.

If you have questions or concerns regarding these changes, please contact your OSPA Grant Assignee.

Federal agencies have differing rules regarding the definition and treatment of participant support costs on sponsored projects. This guidance provides an overview of participant support costs and issues of which principal investigators and fiscal officers should be aware. 

Participant Support Costs on Sponsored Projects - Guidance
Charging Participant Support Costs to Sponsored Projects

Sponsored projects involve formal agreements between the funding agency and the university, so modifications may require prior agency approval. In these situations, OSPA will work with the PI and the funding agency to secure any necessary approvals.

Use the following table to determine how to proceed with modifications:

Contacts for Modifications

Additional information regarding budgeting, no-cost extensions, and PI/key personnel changes: 

Rebudgeting of project funds

• Contact the assignee for your area in the OSPA post-award team.
• Grant assignee will review the request to determine if appropriate and if agency approval is required.
• PI prepares formal requests using a funding agency-approved format which may include:
  • Justification for the request including why the funds are available for transfer
  • Dollar amount to be transferred between budget line items
  • Final revised budget
• After the request has been reviewed and approved, it is forwarded to the OSPA research project specialist assigned to your area.
• OSPA will obtain the authorized institutional signature and will forward the request directly to the funding agency.

No-cost extensions

• A no-cost extension is a modification that involves no change in the scope of work and no additional funding. Simply put, additional time is needed to complete the project.
• The extension is handled through OSPA. Contact the OSPA research project specialist assigned to your college for assistance.
• A programmatic reason must be provided to OSPA for review. A programmatic reason explains why additional time is needed to complete the original project objectives, not to spend out remaining funds.
• A No-Cost Extension Justification form is available.

PI/Key Personnel Change

• A change in PI/key personnel often involves prior approval of the sponsoring agency and is handled through OSPA. Contact the OSPA research project specialist assigned to your college for assistance.
• Submit Request for Change in PI form along with appropriate documentation to OSPA for review.
• Submit a revised budget if the change will result in increased/decreased match commitments.

What is a Subaward?

Subawards are legally binding, formal agreements issued by the university for collaborative grant/contract activities involving personnel at other institutions.

The subcontract, at a minimum, must include a scope of work for the project, a description of the services or tasks to be performed by the subcontractor, and a schedule for deliverables, including any reports. The subcontract document must be executed by the university and the institution employing the subcontractor (or, if an independent subcontractor is used, by the subcontractor). Although monthly or quarterly progress payments or cost reimbursements are made at intervals over the time period of the contract, final payment for services normally occurs after it has been confirmed that the work performed by the subcontractor is satisfactory and in accordance with the terms of the subcontract agreement.

The use of sub-agreements ensures that all applicable grant or contract clauses are included to meet legal, financial, and reporting requirements. The OSPA director signs all subagreement documents on behalf of the university. OSPA will work with the subawardee's institution to implement the subagreement.

When a sub-agreement (subcontract, subgrant or memorandum of understanding) is required, it is the principal investigator’s responsibility to contact Contracts at OSPA as soon as possible to initiate the sub-award process.

Why Include a Subaward in Your Project?

Subcontractors can be used to:

• Accomplish work that may not be within the PI's area of expertise.
• Relieve the PI of some project tasks so he/she can work on other tasks.
• Provide technical assistance using equipment, instruments, assessments or analyses not available to the PI.

Subcontractors are usually identified through the PI's contacts, past research or scholarly collaborations and recommendations by others.

Make sure to discuss the project with the potential subcontractor before submitting a proposal or working toward developing a subcontract relationship to ensure that the potential subcontractor can perform the work needed within the time frame required. Be aware of the subcontractor's strengths and weaknesses, possibly from other researchers or scholars who have worked with the subcontractor, to determine reliability, work quality and cooperativeness.

Required Components for Subagreement Preparation (Provided by PI/PD)

• Detailed scope of work, with timelines for accomplishing tasks and producing reports of results, and with methods, procedures and analyses specified.
• Budget for the costs related to the sub awardee’s portion of the work.

Principal Investigator/Project Director Responsibilities related to Subawards

• Works with OSPA to ensure that the subcontract includes a scope of work that communicates what is expected of the subcontractor.
• Provides oversight of the project throughout its duration.
• Ensures that objectives are met within the specified time.
• Makes certain that the costs incurred fit the budget.
• Guarantees that the quality of the project reflects well on the PI and the university and is acceptable to the funding agency.
• Understand that the subcontractor can only be required to produce the work specified in the subaward agreement.
• Recognizes that if changes to the scope of work become necessary as the project evolves, this may necessitate changes to the sub-award agreement.
• Manage problems, if they arise.
• Familiar with subaward (subrecipient) monitoring guidelines.
• Contact Contracts immediately if problems arise that cannot be resolved by conversations with the subawardee’s PI.

Suggestions for Dealing with Problems in the Subaward Relationship

If problems come up during the course of the project:

• Talk with the subcontractor about what is needed and what is lacking in light of what was agreed to in the subcontract. Try to work out a suitable accommodation.
• If possible, keep on top of the work being performed so that any performance problems on the part of the subcontractor are identified early, not so late in the project that there is too little time for remediation.
• If the PI/project manager also has responsibilities that affect the subcontractor's work, such as providing materials needed by the subcontractor, it is important that those responsibilities be taken seriously and met in a timely fashion.

If the problems are not resolved by talking with the subcontractor:

• Discuss the problems with Contracts.
• PI/project manager, OSPA and others (e.g., university legal counsel) may need to work together with the subcontractor's institution, business or agency to attempt to resolve the situation.
• Typically, the subcontract must be relied upon as the basis for determining issues such as the quantity of work, adherence to the scope of work and costs. Issues of work quality are more difficult to determine and may be more contentious, thereby requiring more time to resolve. However, every attempt will be made to resolve the situation if possible.
• Sometimes situations cannot be resolved to everyone's satisfaction. In these cases, the university legal counsel must provide guidance about the costs/benefits of different possible courses of action, and the university must consider issues such as legal liability; relations with the funding agency that may affect other faculty; previous or ongoing relationships with the subcontracting institution, business or agency; and the fiscal magnitude of the issues involved.

Typically close out documents include:

• Final Financial Report
  • Grant accountants prepare and submit most financial reports that are required by the funding agency.
  • It is the fiscal officer/PI’s responsibility to ensure all project costs have been posted.
  • Fiscal officer is responsible for reviewing and approving final financial report.

• Final Technical Report
  • The principal investigator is responsible for preparing and submitting the final technical report required by the funding agency. This is an important obligation used to monitor and evaluate the project.
  • Failing to turn in reports on a timely basis can result in the agency delaying or suspending final payments on the grant or contract. It also can jeopardize possible future funding from the agency, not just for the PI involved but for other researchers at the university as well.
  • Check your award agreement to be sure you know when the final reports are due, what information is required and what format is specified by the agency.

• Report of Inventions
  • Notify OSPA that a report is required. 
  • PI certifies whether an invention resulted from the project. 
  • OSPA will complete and submit the required report to the funding agency.

• Final Property Reports
  • Contact your grant assignee.

• If you are an incoming faculty member bringing a grant to SIU:
  • Contact sponsored projects office at the institution you are leaving and they initiate the grant transfer.
  • Contact the Office of Sponsored Projects Administration as soon as you know you are transferring to SIU. 
  • Consider equipment purchased by the grant funding and make any appropriate arrangements to have equipment purchased with the project funding following the grant.
  • Each funding agency has grant transfer requirements. It is best to start early to make sure each requirement is handled and the grant is transferred in time for you to begin your research at the new institution.

• If you are an SIU principal investigator who has accepted a position at another institution, contact contracts@siu.edu. There are established procedures for transferring the grant or contract or subcontracting funding from SIU to another institution, which include:
  • Obtaining internal SIU approvals for transferring all or part of the grant to another institution.
  • Obtaining approvals and other required documents from the new institution that will receive the grant.
  • Obtaining internal SIU approvals for transferring any of the equipment purchased with the grant funds.
  • Obtaining approvals from the funding agency for the transfer or addition of a sub-award to the new institution.

Typically close out documents include:

• Final Financial Report
  • Grant accountants prepare and submit most financial reports that are required by the funding agency.
  • It is the fiscal officer/PI’s responsibility to ensure all project costs have been posted.
  • Fiscal officer is responsible for reviewing and approving final financial report.

• Final Technical Report
  • The principal investigator is responsible for preparing and submitting the final technical report required by the funding agency. This is an important obligation used to monitor and evaluate the project.
  • Failing to turn in reports on a timely basis can result in the agency delaying or suspending final payments on the grant or contract. It can jeopardize possible future funding from the agency, not just for the PI involved but for other researchers at the university.
  • Check your award agreement to be sure you know when the final reports are due, what information is required and what format is specified by the agency.

• Report of Inventions
  • Notify OSPA that a report is required. 
  • PI certifies whether an invention resulted from the project. 
  • OSPA will complete and submit the required report to the funding agency.

• Final Property Reports
  • Contact your grant assignee. 

What is effort?
Effort is defined as the amount of time spent on a particular project or activity. This includes the time spent working on the project and directly charged to the project as well as the time contributed to the project (cost shared effort).

What is effort reporting?
Effort reporting is the method used to certify the effort charged or contributed to a sponsored project.

What is contributed or cost shared effort?
Cost sharing represents the portion of the total costs of a sponsored project that are not borne by the sponsor of the project. These costs are borne by the university or third parties, rather than by the sponsor. The fulfillment of cost shared effort (salary) is demonstrated through the university’s effort reporting system. Any commitment of effort referenced in the project proposal or the award document must be honored, reported, and captured in an effort reporting system.

How does the university certify effort?
The university certifies effort after the pay period has ended and any salary dollars have posted. The method to certify effort depends on whether the salary costs are 1) directly charged to the sponsored project or 2) cost shared to the project.

1. Salary Costs Direct Charged to Sponsored Projects
   The actual salary paid for monthly and semi-monthly payrolls is based on the FTE percentage that is entered on the employee’s original appointment paperwork. The appointment is entered on the payroll paperwork as a percentage of total wages. The actual salary paid for bi-weekly and student workers is based on actual hours reported by the budget purpose fiscal officer during a payroll period. These hours are allocated to individual budget purposes based on work performed during that period.
   
   During each payroll period the fiscal officer of the grant budget purpose runs a fiscal officer certification report. The account fiscal officer is expected to review this certification report and then attest that the individuals paid are due the amounts indicated. If the amount paid is not correct (percentage of effort has changed or the budget purpose being charged is incorrect) the fiscal officer should immediately process a retroactive account adjustment (RAA) to change the costing of the individual’s salary.
   
   Please note that the individual signing the fiscal officer certification report should have firsthand knowledge of the actual work being performed on the grant or contract. If the fiscal officer lacks this knowledge, an individual working closely with the project should be consulted.

2. Salary Cost Share to the Project
   When salary cost share is determined to be a requirement on a grant or contract the Office of Sponsored Projects Administration (OSPA) will begin the monthly process of accumulating this information. On each budget purpose for which salary cost share is a requirement OSPA will send the fiscal officer (via e-mail) the certification of time record for grants and contracts form. This form will arrive prefilled with information including the reporting period, budget purpose number, budget purpose title, fiscal officer name and the unit name. A blank version of this form (along with instructions) can be found at https://eforms.siu.edu/siuforms/info/acs0309.php. Note that this form is to be used only for accumulating cost share information; salaries directly charged to the grant or contract should not be included on this form.

In reference to Uniform Guidance Code of Federal Regulations § 200.344 Closeout, the federal awarding agency or pass-through entity will close out the federal award when it determines that all applicable administrative actions and all required work of the federal award have been completed by the non-federal entity. If the non-federal entity fails to complete the requirements, the federal awarding agency or pass-through entity will close out the federal award with the information available. 

• Recipient must submit, no later than 120 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the federal award.
• A subrecipient must submit to the pass-through entity, no later than 90 calendar days (or an earlier date as agreed upon by the pass-through entity and subrecipient) after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the federal award.
• Unless an extension is authorized, a non-federal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award.
• The federal awarding agency or pass-through entity must make prompt payments to the non-federal entity for costs meeting the requirements in Subpart E of this part under the federal award being closed out. Including any upward or downward adjustments.
• Promptly refund any balances of unobligated cash that the federal awarding agency or pass-through entity paid in advance or paid and that are not authorized to be retained by the non-federal entity for use in other projects. (see 200.346).
• Account for any real and personal property acquired with federal funds or received from the federal government in accordance with § 200.310 through 200.316 and 200.330. 

Responsibilities

• Obtain all the required reports and confirm submission to sponsoring agency.
• Update account status to closed in pre-award system of records.
• Confirm that all financial reporting including but not limited to invoice submission for reimbursement and cash draws are completed and posted in the financial system (AIS).
• Complete all tasks outlined under the “procedure” section below.
• Confirm that all cash draws and revenue recognition are completed and posted in the financial system (AIS). 
• Reconcile and confirm completion of sponsoring agency’s information for the account.
• Update statuses to “closed” in both the grants management system and AIS.

Procedure

• Management of each team shall monitor all awards to be closed out by reviewing closeout reports.
• Simultaneously, team members shall coordinate with departments (PI) and monitor system record for all assigned closeouts.
• Review the terms and conditions of the notice of grants agreements (NOGA) for compliance.
• Confirm all reporting deliverables have been submitted. Such as:
  1. Federal: Review sponsor’s online system to confirm the deliverable have been submitted for completion.
  2. Non-Federal: Review the paper files, emails or electronic files to determine if there was any communication that indicated the deliverables were submitted for completion.
• Complete closeout checklist. (See Appendix-1 below). Verify the following tasks are completed.

1. Verify reported expenses in the final report/invoice has been completed, documented and submitted.
2. All adjustments have been processed and posted in AIS.
3. Budget equals expenses.
4. Account receivables is zero ($0.00).
5. No open account receivables items exist.
6. Unbilled account receivables equals zero ($0.00).
7. Project expenses equals budgetary control (commitment control) expenses, if applicable.
8. Project expenses equals general ledger expenses.
9. Revenue amount match in both AIS and grants database or system.
10. Revenue amount match expenses (cost reimbursement).
11. No deferred and billable transaction.
12. Pre-encumbrance (purchase requisition) is zero ($0.00).
13. Encumbrance (purchase order) is zero ($0.00).
14. All payments have been received and applied to invoices in AIS.
15. Refund and write-off adjustments have been processed to completion.