Post-Award Guidelines

ACCEPTING THE AWARD

The first step in accepting an award is reviewing the terms and conditions. Grants should never be accepted without the full knowledge of the responsibilities attached to them. One of the basic principles that governs expending funds from sponsored projects is that costs charged to a grant must be allocable, allowable, reasonable and necessary, and treated consistently. The following list are just a few of the topics to consider when administering a grant.

Internal Review Process

At UTRGV all new awards and transfers are reviewed by the Office of Sponsored Programs. The following is non-exclusive list of documents that are reviewed:

Sponsored Research/Project Agreements
Non-Disclosure or Confidentiality Agreements (related to research or a potential sponsored project)
Materials Transfer Agreements
Consortium Agreements for research/sponsored project proposals
Memorandums of Understanding for sponsored research/projects proposals
Memorandums of Agreement for sponsored research/project proposals
Inter-Institutional Agreement for Management of Joint Intellectual Property
Interlocal and Interagency Agreements (sponsored projects)
Option to License Agreement
Patent License Agreement (university is patent holder)
Teaming Agreements (for proposals)
Technology License Agreement (university is owner of technology)
Award Agreements
Collaborative Research Agreement and Development Agreements
Subawards/Subcontracts

Once the award is negotiated and accepted, the PI/PD will need to make note of important dates related to the grant. For example a PI/PD must take note of the end and start date of the award, and the dates for all programmatic and fiscal reports. In addition, close attention to the information related to the payment of the grant award.

Step one in setting up your grant budget at UTRGV is to revise, if needed, the OSP budget Development worksheet, which was initially submitted to OSP at the time of proposal. If the budget development worksheet has not been completed, please contact us at research-som@utrgv.edu for assistance.

The budget information contained within the budget development worksheet will be utilized as a reference document for other departments within UTRGV. Information contained in this worksheet will be used to verify allowable expenditures and each individual’s percent (%) effort on a sponsored project.

Executing the Contract

As per the UT System Regents’ Rules and Regulations, Rule 10501 the Board of Regents delegates to the UTRGV President the authority to execute and deliver certain contracts and agreements on behalf of the Board. The President may further delegate his delegated authority to a secondary delegate. For proposals these delegates are also known as “Authorized Organizational Representatives”.

Delegation of Authority

Delegation of Authority
Contracts: Delegation of authority to execute and deliver contracts of any kind or nature, including contracts for purchase of equipment, supplies, goods and services.	Regents Rule 10501	Executive Vice President for Finance and Administration Associate VP for Financial Services Chief Procurement Officer Deputy President
Contracts between or among U.T. Institutions -Health Affairs Contracts: Any such contract or agreement shall provide for the recovery of the cost of services and resources furnished.	Regents Rule 10501	Executive Vice President for Health Affairs Dean, SOM Executive Vice Dean, SOM Deputy President
Agreements and Non-Research Grants Documents- UTRGV Division of Health Affairs: Fellowships and similar Medical and Health Affairs Personnel Support	Rule 10501; Rule 90101, Sections 15.1 and 15.3; UT System Policy UTS 125	Executive Vice President for Health Affairs and Dean, SOM Executive Vice Dean, SOM Deputy President
Agreements with Corporate Sponsors and Agreements that Grant an Interest in Intellectual Property: license agreements, research contracts with corporate sponsors, non-disclosure agreements and material transfer agreements.	Rule 10501	Executive Vice President for Research, Graduate Studies, and New Program Development Deputy President
State and Federal Contracts for Proposals for Sponsored Research:	Rule 10501	Executive Vice President for Research, Graduate Studies, and New Program Development Deputy President Associate Vice President/Director for Sponsored Programs

Setting up the Grant Account in Peoplesoft ERP system

The Office of Sponsored Programs and the Office of Grants and Contracts work jointly to ensure that a new Peoplesoft account is set-up in a timely manner. If the award notification has any cost share commitments, a cost share account will also be created at this time. An important step in setting up your internal Peoplesoft project account is to complete the budget worksheet. The dollar amount awarded in the notice of award and the dollar amount entered in the internal budget worksheet must match. Project personnel listed on the internal UTRGV spreadsheet are those individuals engaged in the project listed by name and by role. Important variables included in this worksheet include Institutional Base Salary, % effort anticipated on the project, calendar months of engagement, calendar salary and fringe benefits. The intent of this internal spreadsheet is to capture the entirety of the project as it relates to the personnel, supplies, and equipment costs.

The Grants and Contracts Office at UTRGV plays a major role during the course of the grant. This office will set-up the Peoplesoft project account, monitor expenditures above $3,000, as well as provide the corresponding agencies with financial reports.

The project director and finance director should plan for a possible audit and what audit documentation should be readily available. Both the project and financial director should review and track any matching funds for the project.

Coordinating Grant Tasks

It is recommended that a file be kept of each proposal that is funded. Grantees may want to keep an electronic file of scanned documents. The master file should contain the following:

A copy of the funded proposal.
Regulations for the grant program.
The award notice.
Documents showing approved revisions
Assurances
The project budget
Any correspondence with the funder related to the project
Memorandums of understanding with collaborative partners in the project
Records of Expenditures, receipts, and purchase orders
Programmatic, financial, evaluation, and audit purposes

Hiring Personnel

If the project budget includes staff and faculty that must be hired, or for which a percentage of their time will be charged to the grant, the PI/PD will need to complete the proper paperwork (CPAF/EPAF)to get things charged to the sponsored project. In particular, as soon as the notice of grant award is received, the PI/PD can start advertising for any vacant positions for which there is a budget line. In the case that a percent % effort will be committed from an existing UTRGV faculty or staff member, a Change of Personnel Action Form must be completed. A suggestion is to create a responsibility chart for all the staff to refer to during the project implementation. Information included in the chart can be dates for progress report submissions, evaluation activities, monitoring visit dates, financial reports, filing request for project extensions, if needed. Other records which are also necessary to keep are programmatic records and financial accounts, purchasing project equipment, inventory control, maintaining records of matching funds and close out of the grant.

University Volunteers
It is recommended that PI's follow HOP Policy ADM 04-208 when recruiting or accepting volunteers who are not students, staff, or faculty within UTRGV. UTRGV acknowledges and values the role of volunteers in enhancing the vision and mission or our university, but proper procedures must be followed at all times. Any foreign nationals must receive clearance from the Office of Human Resources, Immigration Services prior to accepting a volunteer assignment at UTRGV. Procedures include a volunteer application and criminal background checks.

Audits and Monitoring Visits

Managing federal grants can be a huge undertaking. Grantees should familiarize themselves with the corresponding sponsor operating guidelines and terms and conditions for their award. Most, if not all, grants and contracts follow university policies that are created in alignment with the Federal Office of Management and Budget (OMB) laws and regulations. These circulars are found on the OMB web site, www. Whitehouse.gov/omb/circulars. The following are the three circulars that provide guidance to Federal Award recipients on how to properly manage awards according to the laws and regulations.

OMB Circular a-21 titled Cost Principles for Educational Institutions
OMB Circular A-110 titled Grants and Cooperative Agreements for Grants and other Agreements with institutions of Higher Education, Hospitals and Other non-profit organizations.
OMB Circular A-133 titled Audits of states, Local Governments and Non-Profit Organizations

Audits are an important tool when determining compliance of university policies and Federal laws and regulations by award recipients. An audit always involves examining revenues and expenditures. The recipient institution is always responsible for ensuring that the expenditures charged to a sponsored project are allowable, allocable, and reasonable.

UTRGV Semi-Annual Project Certifications

Departments are required to reconcile their sponsored project accounts on a monthly basis. Please refer to instructions on the UTRGV web-site for instructions.

http://www.utrgv.edu/_files/documents/administration/bis-utrgv-semi-annual-project-certification-guide.pdf

Certification Deadlines are: March 31st for the period of September 1st - February 28th

September 30th for the period of March 1st - August 31st.

Types of Audits

If an institution expends more than $500,000 in federal funds in 1 year, a single audits is required to be conducted. The single audit entails an organization wide-audit that examines use of grant funds. Auditors will check to see that all guidelines are being followed and that grants funds are properly documented and recorded according to generally accepted accounting principles.

At all times, and especially when there is change of PI on a project, a request can be made for an internal UTRGV auditor to audit a grant.

Close out of an award

The close-out of an award is that last activity that is carried out after the award period has ended. This typically involves submitting a final program report and a final financial report. Grantees should read the terms and conditions to find out when these reports need to be submitted. Grantors typically allow at least 30 days to 90 days after the project is completed for the reports to be turned in.

If the grantor required matching funds as a condition for the award, grantees may be asked to submit verification that matching funds were incurred under the project or that in-kind contributions were received.

Equipment Inventory

Grantors will sometimes request a list of equipment that was purchase during the course of the award. This information can be easily compiled by accessing the capitalized equipment line in the university accounting records.

Compliance Certifications

Some federal grantors require that grantees comply with specific requirement by the end of the project. For example, the Department of Health and Human Services has a compliance requirement pertaining to new invention disclosures. A Final Invention Statement and Certification (Form HHS 568) must be submitted within 90 days following the expiration or termination of a grant or award. Grantees can suffer serious consequences if the award is not closed in an appropriate manner. This includes delays in reimbursement of expenditures and jeopardizing any possible future funding from grantors.

Time and Effort Reporting

The fundamental purpose of effort reporting is to ensure that the payroll distribution for individuals engaged in sponsored projects accurately reflects their actual effort on the project. The principle rule is that the salary, wages, and fringe benefits charged to a sponsored project must be allocable, allowable, consistently treated, and reasonable. Effort is based on total institutional activities and does not assume a 40 hour workweek or any other standard workweek for exempt employees. Effort Certification will be based on a reasonable estimate by recognizing that administration, patient care, research, public service, and teaching are often inextricably intermingled.

The Office of Research Compliance is responsible for ensuring that the University conforms to the confirmation requirement of the OMB A-21 circular, as well as verifying individual’s total professional effort.

How is effort calculated?

Dedicated effort on a sponsored project is often referred to as percent (%) effort. Determining percent (%) effort on a project is based on several other variables and responsibilities that tie into the role of the individual while an employee at UTRGV.

Each Primary individual listed in proposals with a specific committed effort must be aware and must approve his/her participation in the activity.

For health institutions, clinical practice compensation in IBS must be set by the institution and paid through or at the direction of the institution.

As per OMB A-21 grants for equipment and instrumentation or student augmentation and/or training, do not typically require committed Primary Individual Effort

For academic appointments of 9 months, Primary individual may be allowed 100% appointment outside the academic year. Care should be exercised to ensure that Primary Individual does not perform activities during this period that is unallowable, such as taking a leave during their 100% appointment, consulting during their 100% summer appointment, teaching a course (s) that will exceed committed effort, or engage in summer activity that will exceed the 100% committed effort.

U.T. System has implemented an electronic online Effort Certification System named ECRT – Electronic Certification Reporting Tool. Under this reporting system, each Faculty and other key staff certify their own effort cards. Program Directors and Principal Investigators are required to certify their own effort cards and the effort cards of all supporting individuals (graduate students, post-doctoral trainees, and classified staff) who work on their sponsored projects. Support staff are only required to view effort card, make notes, and notify PI/PD if revisions are needed. Costs should be appropriate to the award and that the labor charges documented need to be actually incurred on the project activities.

Reporting periods are as follows:

Fall semester- Sept. 1^st to December 31^st.

Spring semester- January 1^st to April 1^st

Summer- May 1^st to August 31^st

Records Retention (AC+5)

For all original state documents initiated by a sponsored project, the retention period is five (5) years after the closed/termination (AC+5) of the award or contract. After the five (5) years have been met the retention period is fulfilled and documents can be disposed of appropriately. A State record may not be destroyed if any litigation, claim, negotiation, audit, open records request, administrative review, or other action on the record is initiated before the expiration date of record retention.