Award Receipt

Award Receipt

Determining Award Terms and Conditions | Documents Needed to Process Internal Notice of Award (INOA) | Prior Approval

Determining Award Terms and Conditions

PIs are responsible to review and understand critical information in the award document, applicable agency guidelines, and federal guidelines (OMB A-110, OMB A-21, section J).

The following list of terms will enable identification of essential information in the award documents:

• Project period: What is the earliest beginning date and the last termination date for all periods of the project? This may include several budget periods.

 

• Award amount for the project period: What is the cumulative amount legally committed and encumbered by the agency for all budget periods? This may include obligated funding for a current budget period plus pending funding for future periods.

• Budget period: Does the award specify annual periods for performance, spending, or payment for a project continuing for more than one year? When does each of these annual periods start and end? What are the terms for each budget period?

 

• Award amount per budget period: Has the agency specified an amount obligated or restricted for a specific budget period? Has the agency committed only a portion of the total project funding at the time the award is executed?

• If the agent has committed only a portion of funding, what are the conditions for future pending funding to be activated or become obligated? For example, when the future budget period is reached, is funding automatically obligated or will the agency send formal notice?
• If the award specifies a limit on what can be spent for each budget period, what are the terms regarding overspending or under spending?
• Many agencies fund projects in increments. Look for terminology that requires an accounting for each budget period and a refund of the unexpended balance for each period. In these cases, you might need approval to spend an unobligated/unexpended balance past the termination date or to spend more than the budgeted amount.

 

• Award budget: Determine the amount awarded for each budget period, if applicable, and for each expense category (i.e., salary, supply and expense, travel, equipment, indirect costs).

• Unallowable expenses: Determine expenses the agency doesn't allow as a direct cost. (For example, foreign travel is not allowed by many agencies.) After reviewing the agency terms, check to see if any normally unallowable expenses are approved in the award budget. 

 

• For federal funds, OMB A-21 cost principles may override approvals in the award budget. For guidance on expense allowability, contact the Office of Sponsored Programs (OSP) or the Office of Finance for that granting agency.

• Expense limitations: Are any expense categories limited to a specific amount within a budget or project period? For example, many agencies limit the amount that can be spent on travel for each budget year.

 

• Rebudgeting requirements: If expenses exceed the budget for a particular category or if the PI wants to spend in categories not previously budgeted, what are the terms for changing the approved budget? Some agencies allow a deviation within approved categories and some require approval for any change.

• Billing and payment terms: Is the award payment basis fixed price or cost reimbursable? Are there specific billing and payment terms and instructions?

 

• In general, most federal and private contracts and federal grants are billed in some manner. Grants from private sponsors are usually not billed.
• If the award requires billing, look for the billing schedule and additional requirements such as detail to be included on the invoice itself (e.g., breakdown of salary by position, etc.) or reports to be submitted with the bill (e.g., cost-share report, equipment report, etc.).
• If billed, Office of Finance submits invoices to the agency. The department is responsible for providing the Office of Finance with the other required reports or attachments.
• If the award does not require submission of an invoice, look for terms regarding the amount and frequency of payment. Look for the manner of payment (check, wire transfer, etc.).
• If you receive checks for any of your sponsored project awards, contact the Office of Finance for deposit instructions.

• Cost-sharing requirements: Contributions to the project for personnel or other expenses to be paid from other fund sources are considered mandatory cost sharing, if included in the award documents.
• Check the approved budget for salary or other itemized expenses budgeted at zero cost to the project.
• Review the budget narrative for language committing personnel time or other expenses at no cost to the project.
• If cost-sharing commitments are included, the University is required to track and report these, and the PI must certify this contribution to the project.
• Any questions for cost sharing should be directed to the Office of Sponsored Programs or the Office of Finance.

 

Documents Needed to Process Internal Notice of Award
 
BACKGROUND

When an award document is received in the Office of Sponsored Programs (OSP) and negotiation of the award is complete, OSP must ensure all administrative requirements are in place prior to acceptance of the award and notification to the University and the Principal Investigator. The Internal Notice of Award (INOA) will not be issued until all regulatory documents are received. The most common delays in release of funding include lack of regulatory committee approvals, conflict of interest disclosure, and the award to protocol verification match.

BUDGET

A detailed budget for the award must accompany the INOA. The INOA will not be processed if the PI has not provided the detailed itemized budget with justification.  As a major cost to most projects involves personnel salaries the detailed budget will allow OSP to review and approve PAFs for personnel on the sponsored projects. Failure to provide the budget can also potentially delay the processing of other expenditures such as check requests, purchase requisitions and consultant agreements. Although some sponsors do not require detailed budgets (i.e. modular budgets to NIH) for the reasons stated above it is a requirement to submit a detailed budget to the OSP

REGULATORY COMMITTEE APPROVALS

Most sponsors do not require proof of regulatory committee approval until the award stage. Any scope of work which requires approval from one or more of the regulatory committees must have approval prior to the release of the award synopsis in most cases. Since most of the CDU regulatory committees only meet once per month, Principal Investigators should submit their protocol applications to the appropriate committee as soon as an award appears to be forthcoming.

If a scope of work includes human subjects research, approval from the Institutional Review Board (IRB) may be required. For more information, please contact the Office for the Protection of Human Subjects at 323-563-5902.

If a scope of work includes animal research, approval from the Institutional Animal Care and Use Committee (IACUC) may be required. For more information, please contact the administrative office for IACUC.

If a scope of work includes the use of pathogens or recombinant DNA, approval from the Institutional Biosafety Committee (IBC) may be required. For more information, please contact the administrative office for Biosafety.

CONFLICT OF INTEREST DISCLOSURE

Depending on the sponsor of a project, Principal Investigators are required to disclose potential conflicts of interest, both financial and in obligation.

For the Public Health Service (PHS) and the National Science Foundation (NSF), as well as those sponsors who adopt the federal requirements, OSP and the University Auditor must receive the appropriate disclosure form prior to the acceptance of the award.

For non-governmental sponsors, OSP and the University Auditor must receive the appropriate disclosure form prior to acceptance of the award. For non-governmental sponsors, this is forwarded to OSP along with the proposal for review.

In cases where a positive interest is identified, the disclosure must be reviewed by the Conflict of Interest Committee (COIC).  For more information, please contact the University Auditor.
OSP & IRB Communication to ensure consistency between the research that was proposed and the research that was approved by IRB.

 

Prior Approval

The term “prior approval” refers to the sponsor requirement for principal investigator/project director to obtain written institutional or agency approval for specified post-award changes in the approved project or budget.  If the award in question is from a federal agency, general guidance is received in both OMB Circulars A-110 and A-21.  However, individual agency guidelines must be reviewed to determine whether correspondence must be sent to the agency or whether an institutional prior approval is permitted.  If the sponsor is not a federal agency, unique terms may apply and require careful review.  Whether internal or external approval is needed, accurate and complete documentation is required.

Based on an administrative requirement from the National Institutes of Health (NIH), Charles Drew University of Medicine and Science (CDU) must have written procedures in place for reviewing and approving in advance certain administrative changes to projects funded by NIH. 
The Office of Sponsored Programs (OSP) refers to these procedures as an “organizational prior approval system.”  This approval system enables Principal Investigators to make revisions to their originally funded projects. The request must be routed to and reviewed by OSP, and OSP is responsible for forwarding the request to the appropriate official at NIH.The Office of Sponsored Programs is the designated institutional office authorized to issue an internal approval for changes prior to going to the sponsor.  OSP is authorized to grant institutional approval or to send formal requests for approval to sponsor through completion of the Prior Approval Form.  Proposed changes must be approved by OSP or the sponsor, depending on the nature of the proposed revision, before they can be implemented by the principal investigator/project director.  Administrative changes which do not fall within the boundaries of the OSP Prior Approval system must be approved by the funding agency.  Administrative changes approved through the use of the Prior Approval Form will be kept on record in both OSP and the Office of Finance.

The NIH permits a certain degree of flexibility in making post-award programmatic changes and budget revisions.  The re-budgeting of certain cost items must have the prior approval of the University and/or appropriate NIH awarding unit.  Below is a chart to identify those transactions that require University prior approval and/or those that must be presented to NIH for authorization.

(Note: The above table has been revised in accordance with the 03/20/2001 NIH Guide Notice) 

DEFINITIONS

Change in Scope

Change in scope is a change in the methodology, approach or other aspects of the project objectives.  Significant re-budgeting is one action likely to be considered a change in scope.

Carryover of Unobligated Balances

Carryover of unobligated balances is the carryover of funds unspent as of the expiration of a budget period.  These may be automatically carried over into the next budget year unless greater than 25% of the total amount awarded.  The PI/PD must report carryover greater than 25% as part of the Non-Competing application process.  Grant mechanisms excluded from automatic carryover of unobligated balances are center (P50, P60, P30 etc.); cooperative agreements (U’s); National Research Service Awards (T’s and F’s); and Phase I SBIR and STTR (R43, R41).

Please note that unobligated funds at the end of a project period or expiration of the grant can only be carried forward and expended under an authorized no-cost extension period.

Change in Key Personnel

Change in key personnel must be reported to PHS when the PI/PD or other key personnel named in the Notice of Grant Award will withdraw from the project entirely, be absent from the project during any continuous period of 3 months or more, or reduce his/her time devoted to the project by 25 or more percent from the level that was approved at the time of the award.  NIH must approve any alternate arrangement, including any replacement PI or other key personnel proposed by the grantee. The request for approval of alternate PI/PD/key personnel should include:

• A justification  for the change
• Biographical sketch of the individual proposed
• Other sources of support
• Any budget changes resulting from the proposed change.