Manage Award Process
Research Services is responsible for non-financial grant and contract administration, functioning as the liaison between the funding organization, the faculty member, and other University offices. Moreover, Research Services supports Research Accounting in the institutional oversight of grant and contract awards to ensure compliance with OMB circulars, FARS and other federal and state laws, regulations and policies that govern the expenditure of sponsored funds.
Manage Award Responsibilities
Research Services provides non-financial grants management support to include maintenance of the official grant file; monitoring subrecipient performance in collaboration with the PI and RAs; preparing/submitting prior approval requests in collaboration with RAs to include no cost extensions, changes in scope of work, disengagement of key personnel from the project for more than 3 months or 25% reduction of effort, transfer or contracting out of work that was not described in the original application; reviewing and executing continuation funding amendments; and budget revisions in collaboration with RAs i.e., transfer of participant support costs, changes in matching and cost sharing. Research Services ensures documentation of deliverables i.e., reports.
Manage Award Procedures
|Award Handoff||Research Services reviews award instrument, identifies any extraordinary terms, institutional concerns in preparation for the project PI Award meeting. In collaboration with Research Accounting, will discuss when to involve Research Services; this usually involves any revisions to the performance of a project that require institutional approval such as changes in the budget, addition, modification, or deletion of objectives (scope of work), change in performance period. Research Services provides contact information for research compliance questions. Confirms subawardees to ensure that there haven’t been any changes that might require sponsor approval. Research Services researches and responds to any concerns from the meeting.|
|Administrative||Research Services answers questions related to the management and terms and conditions of active projects during the project period.|
|Contractual –Subrecipient, consultant/contractor/professional services and vendors||Research Services confirms the final determination on the type of relationship involved (subrecipient vs. contractor vs. vendor) after (a) the award has been setup, and at the request of the Principal Investigator: Subrecipient determination: Research Services verifies the eligibility of the subrecipient by confirming that the subrecipient information contained in the proposal has been approved by the subrecipient’s Authorized Organizational Representative (AOR) using the information provided in the executed Subrecipient Commitment Form and is still valid: information is still valid if the form has been signed by the subrecipient’s AOR within 12 months of the date of the AOR’s signature. Uses the information on the subrecipient Commitment Form, assessment tool, SAMS and Visual Compliance to conduct a risk assessment prior to entering into an agreement; subawards will not be issued to subrecipients that pose an unacceptable risk to the University. Consultant/Contractor/Professional Services determination: Research Services verifies the eligibility of the consultant by confirming that the information contained in the proposal has been approved by the pertinent part using the information provided in the executed Consultant Commitment Form and is still valid: information is still valid if the form has been signed by the pertinent party within 12 months of the date of said signature. Research Services uses the information on the Consultant Commitment Form to conduct a risk assessment prior to entering into an agreement; contracts will not be issued to consultants that pose an unacceptable risk to the University. Vendor determination: Research Services refers investigator to Research Accounting for financial post award administration.|
|Subrecipient monitoring||Research Services manages macro-level monitoring i.e., periodic spot checks of reports to ensure the award is being carried out according to the terms and conditions of the agreement, etc. and inappropriate subrecipient expenses and/or problems with performance reported to our office by the PI who is responsible for micro-level monitoring of the work effort of subrecipients and consultants.|
|Prior Approval for Programmatic and Financial Changes||Research Services reviews any proposed project changes against each sponsor’s specific requirements regarding changes to the scope of the project or modifications to the approved budget to ensure that requested changes in project duration or the budget aren’t covered under expanded authority without referring back to the sponsor. Research Services ensures for those grants/contracts that require sponsor’s prior approval, correspondence per the funder’s guidelines is completed and authorization for proposed change is approved and executed on behalf of the University and PI. Research Services notifies RA who in turn sends out an updated Factsheet to notify the investigator and other academic and administrative units.|
|Deliverables||Research Services ensures the PI has provided a copy of the project performance reports or a transmittal letter (or email) to that effect when reports are not submitted through a sponsor’s electronic portal so the university has a record of those types of submissions.|
Manage Award Policy Resources
|Application & Retention of Salary Savings Resulting from Sponsored Programs Policy – RSSP-405-5||To support externally-funded research and scholarship efforts at Georgia Southern University and to provide consistency in the application and retention of salary support for externally-funded efforts across all Georgia Southern University units.|
Direct charge of faculty and staff time to sponsored programs is performed through the completion of a Personnel Action Form, to be submitted to the Office of Research Accounting following approval by the academic or administrative unit. The budget section of the Personnel Action Form should be utilized to identify the location to transfer the salary savings generated from the buyout.
A payroll reallocation form is used to process a buyout for previously processed payrolls. The budget section of the form should be utilized to identify the location to transfer the salary savings generated from the buyout.
|Charging & Distributing Facilities and Administrative Costs Policy – RSSP-409||Facilities and Administrative Costs (F&A) or indirect costs are charged to all sponsored programs (grants and contracts) under the requirements of the U.S. Office of Management and Budget 2 CFR 200 Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, and consistent with the University’s federally-negotiated F&A Cost Rate with the Department of Health and Human Services, the University’s cognizant agency. Recovered F&A costs reimburse the University for those Actual Costs associated with performing research, which are not specifically allocable to any single sponsored project. Such costs include utilities, buildings and facilities costs, laboratories, information technology infrastructure, general administration, sponsored programs administration, compliance services, department and central administrative costs associated with managing externally funded projects and libraries.|
Historically, the distribution of recovered F&A costs has followed the classification of the sponsor, providing separate distributions based upon the status of a federal or non-federal sponsored program. While unconventional, the impetus for this distribution can be traced back to the Memorandum of Understanding between Georgia Southern University and the Georgia Southern University Research and Service Foundation, which uses similar language as that originally utilized in establishing the Georgia Tech Research Corporation within the University System of Georgia. As such, the following methods should be used in distributing recovered F&A costs under federal and non-federal programs:
-Recovered F&A costs are distributed between the Georgia Southern University Research and Service Foundation (GSURSF) and Georgia Southern University (GSU).
-For federal programs, and as described by the Memorandum of Understanding between the entities, the distribution of the total recovered F&A cost under a sponsored program is “36/46th” or 78.26% to GSU and “10/46th” or 21.74% to the GSURSF.
-For non-federal programs the distribution remains as historically provided for, and is distributed as 39.13% to GSU and 60.87% to the GSURSF.
-Based upon these historical processes, the distributions resulting from federal and non-federal programs are distributed by GSU to the academic and administrative units according to the Standard F&A Distribution (see policy).
The recovered F&A costs are calculated by multiplying the applicable F&A rate (federal, non- federal, or other stipulated rate) by the applicable rate-bearing direct costs incurred or charged to the sponsored program.
Recovered F&A costs are calculated by the Office of Research Accounting on a monthly basis and dispersed to the academic and administrative units as applicable using a fund code 15 account.
Fund code 15 and Fund code 20 are non-lapsing program codes and not subject to fiscal year end closing.
F&A costs recovered by the GSURSF are retained as part of the Foundation’s financial portfolio and used for the sole purpose of supporting the research, funding and technology transfer activities of the University’s research enterprise.
COLLEGE-SPECIFIC DISTRIBUTION OF RECOVERED F&A COSTS
Academic units may, with the prior approval of the Provost, devise their own alternate distribution of F&A costs for the academic portion (Project Director/Principal Investigator, Department Chair/Unit Director, and Deans) of recovered F&A costs to incentivize external funding within their units.
DISTRIBUTION OF RECOVERED F&A COSTS TO COLLABORATIVE ACADEMIC UNITS
By default, recovered F&A costs for sponsored programs involving only one college and department will be distributed as described previously. In cases where one or more colleges and/or departments are collaborating under a sponsored program, recovered F&A costs attributable to any of the academic distribution categories (project director/principal investigator, department chair/unit director and deans) may be split, either equally or unequally, to align with the effort and/or resources of the collaborating units. For example, under a sponsored program involving a single college with multiple departments, the departments may wish to split the project director/principal investigator portion (20%) amongst multiple investigators and the department chair/unit director portion (15%) amongst the participating departments. In collaborations involving more than one college, the applicable college portion (15%) may also be split equally or unequally.
There are two acceptable methods for aligning F&A costs under collaborative projects:
New and pending proposal submissions
The distribution of F&A costs amongst collaborating units should be memorialized at proposal routing/approval stage of the proposal development process, with vested parties certifying to the distribution of F&A costs prior to proposal submission. Although it is best to acquire all approvals at the proposal stage, the F&A cost distribution may be altered by mutual agreement of the vested parties any time before an award is established.
Currently active projects
The database utilized by the Office of Research Accounting retroactively calculates F&A revenue distributions back to the beginning of the fiscal year. Thus, any changes made to the distribution of active sponsored programs will be retroactive to July 1 of the current fiscal year. To minimize disruption to accounting functions, any realignment of F&A costs under active collaborative projects must be performed between July 1 and September 30. In such cases, all parties (investigators, chairs and deans) must approve of the revised distribution, which will only apply to recovered F&A costs collected during the current fiscal year and beyond, and not retroactively to prior fiscal years.
Recovered F&A costs are distributed not more often than monthly by the Department of Research Accounting based upon the F&A cost distribution on file for each individual sponsored program.
UTILIZATION OF F&A COSTS
Recovered F&A costs may be used to acquire goods and services at the discretion of the recipient. Recovered F&A costs are considered restricted state funds and all costs must adhere to the policies of Georgia Southern University and the University System of Georgia. The department chair/unit director may independently impose further restrictions on the utilization of recovered F&A costs, restricting allowable costs to, for example, only research-related costs, as the chair deems appropriate.
RETENTION OF F&A COSTS
All F&A costs recovered under sponsored programs are retained by the University, as are any and all goods, supplies and equipment purchased with recovered F&A funds. If an investigator departs or retires from the University, funds remaining in his/her individual F&A account will be moved to the University’s General F&A account.
|Reports and Deliverables for Sponsored Projects Policy – RSSP-404-02||This policy defines the responsibilities of the principal investigator (PI), Research Services (RS), and the Georgia Southern University Research & Service Foundation (GSURSF) with respect to reports and deliverables required by the funding agency.|
For technical reports and deliverables, the PI will provide Research Services with one copy of the following (as applicable) for the official project file:
all progress reports;
final technical report; and
the submittal letter or email to the funding agency.
The GSURSF will place a copy of each financial or other nontechnical report in the official project file.
|Sponsored Expense/Cost Transfers Policy – FS-RA-2101-01||To define expense/cost transfer policy for federal grants and contracts to assure compliance with all applicable federal and state laws.|
Expense transfers must be timely, conform to university and sponsor guidelines and have appropriate documentation to be considered allowable. Frequent, late, or inadequately documented transfers raise questions about the propriety of the transfers and may result in expenditure disallowances and/or subsequent reduction in funding.
Sponsored project funds should be reviewed by the Principle Investigator (PI) on a monthly basis to ensure that all expenditures charged are correct and appropriate. It is the responsibility of the principal investigator to authorize transactions and review the expenditures for accuracy. If an error is discovered, an expense transfer should be made no later than 60 days after the original transaction or 30 days after the end of a project, whichever comes first. To request an expense transfer, the PI or department should complete the Expenditure Transfer Form located on the Financial and Business Services website for General Accounting forms. Acceptable documentation of the expense transfer include, at a minimum:
1) The completed expense transfer form. The form must include an explanation to fully document how the error occurred and a certification of the correctness of the new charge by the PI or responsible party if PI is absent. An explanation merely stating that the transfer was made “to correct error” or “to transfer to correct project” is not sufficient.
2) Business Objects Financial History report showing the original charge
3) Approval by PI and Budget Manager of the budget of the original charge.
The completed form should be sent to Research Accounting for review and posting.
Under no circumstances is it appropriate to initiate an expense transfer for the sole purpose of utilizing unexpended funds or to cover losses or overages from other projects. Federal regulations specifically prohibit transfers of this nature.
Federal regulations governing expense transfers:
2CFR220.C.4.b (OMB Circular A-21 C.4.Allocable Costs) – “Any costs allocable to a particular sponsored agreement under the standards provided in this Appendix may not be shifted to other sponsored agreements in order to meet deficiencies caused by overruns or other fund considerations, to avoid restrictions imposed by law or by terms of the sponsored agreement, or for other reasons of convenience.”
NIH Grants Policy Statement, Part II: Terms and Conditions of NIH Grant Awards, Section 7.5 Cost Transfers, Overruns and Accelerated and Delayed Expenditures
“Cost transfers to NIH grants by grantees, consortium participants, or contractors under grants that represent corrections of clerical or bookkeeping errors should be accomplished within 90 days of when the error was discovered. The transfers must be supported by documentation that fully explains how the error occurred and a certification of the correctness of the new charge by a responsible organizational official of the grantee, consortium participant, or contractor. An explanation merely stating that the transfer was made “to correct error” or “to transfer to correct project” is not sufficient. Transfers of costs from one project to another or from one competitive segment to the next solely to cover cost overruns are not allowable.
Grantees must maintain documentation of cost transfers, pursuant to 45 CFR part 74.53 or 92.42, and must make it available for audit or other review (see Administrative Requirements— Monitoring—Record Retention and Access). The grantee should have systems in place to detect such errors within a reasonable time frame; untimely discovery of errors could be an indication of poor internal controls. Frequent errors in recording costs may indicate the need for accounting system improvements, enhanced internal controls, or both. If such errors occur, grantees are encouraged to evaluate the need for improvements and to make whatever improvements are deemed necessary to prevent reoccurrence. NIH also may require a grantee to take corrective action by imposing additional terms and conditions on an award(s).
The GMO monitors grantee expenditure rates under individual grants within each budget period and within the overall project period. The funding that NIH provides for each budget period is based on an assessment of the effort to be performed during that period and the grantee’s associated budget, including the availability of unobligated balances. Although NIH allows grantees certain flexibilities with respect to rebudgeting (see Administrative Requirements— Changes in Project and Budget), NIH expects the rate and types of expenditures to be consistent with the approved project and budget and may question or restrict expenditures that appear inconsistent with these expectations.
The GMO may review grantee cash drawdowns to determine whether they indicate any pattern of accelerated or delayed expenditures. Expenditure patterns are of particular concern because they may indicate a deficiency in the grantee’ s financial management system or internal controls. Accelerated or delayed expenditures may result in a grantee’s inability to complete the approved project within the approved budget and period of performance. In these situations, the GMO may seek additional information from the grantee and may make any necessary and appropriate adjustments.”
Examples of Expense Transfers
Expense transfers that may be appropriate:
-Correction of technical errors, such as data entry or transposition error
-Recurring and routine transfers to allocate direct expenses (if allowable), such as
telephone charges, fuel charges and printing charges.
The methodology for allocating charges must be consistent, well-documented and based on the benefit derived.
Transfer of pre-award costs from another departmental account, given that the expenses
were allowable and allocable, and were incurred within the sponsor permitted time period before the beginning date of the award. Temporary accounts should be established for these types of pre-award costs if possible to avoid these types of expense transfers. Transfers to move unallowable charges, or to eliminate a deficit, to a non-sponsored account
Expense transfers that are not appropriate:
-Transfers processed solely to move deficit spending from one sponsored project to another sponsored project
-Transfers that are processed solely to use up an unexpended balance, but do not appear to be of direct benefit to the project, i.e. transfers of costs during the last months of a project
-Transfer of unidentified expense or lump-sum expenses to a sponsored project
-Transfers of expenses that were not incurred during the project period of performance, unless specifically allowed by the sponsor
-Transfer of Revenue, Cash, or Facilities & Administrative expense to or from a sponsored project.
Last updated: 9/9/2020