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Post-Award Policies and Procedures
The Office of Sponsored Programs (OSP) will be your chief contact in the
post-award phase of your project for questions related to programmatic concerns.
After an award has been made, changes affecting items such as the budget or
the award period are sometimes necessary. While there is some consistency in
governmental agency regulations regarding post-award changes, each agency does
have its own rules. Awards from non-government sponsors are also governed by
rules specific to each sponsor. Therefore, should a post-award change be
required, the Project Director (PD) or Principal Investigator (PI) may refer to
the sponsor regulations or may contact the OSP with specific questions about
effecting the change.
When the OSP receives an award document from a sponsor, a copy of the document is sent
to the principal investigator or program director with a procedural letter. The
PI/PD should examine: statement of work, budget (F & A costs matching,
release time), reporting requirements, rebudgeting restrictions, required
sponsor prior approvals, patent and copyright terms, if applicable, submissions
dates for continuation or renewal proposals and other provisions. He or she
should communicate any objections or questions to the OSP for discussion and
possible negotiation with the sponsor.
Effective July 1, 2002, all Post Award fiscal responsibilities were transferred from Sponsored Programs, located in the
Office of Research and Economic Development; to the Grants and Contracts Accounting (GCA)
Unit,
located in the Division of Finance and Business. For post award fiscal support
services please contact (757) 823-2816.
A conference between the PI/PD and the GCA will be conducted to make certain
PIs/PDs are aware of and agree to carry our their responsibilities to Norfolk
State University and to the sponsor while participating in sponsored activities.
Awards from the funding agency to the University must receive prior review of
all terms and conditions by OSP, regardless of the type of sponsor. OSP is
responsible for negotiating appropriate remedies if an award fits into any of
the following categories: 1) it contains provisions that are incompatible with
the University's policies on sponsored activities; 2) it is inconsistent with
government-wide regulations for universities; 3) it fails to include all the
elements agreed upon prior to an award; 4) it requires modification to conform
to a PI's/PD's needs. OSP must also have on file the signed Internal Approval
Form. The original Notice of Grant Award should be on file in OSP with a copy
provided to the PI/PD and GCA.
Norfolk State University must comply with applicable statutes, regulations,
and approved applications of all agencies in implementing sponsored programs;
and it must use funds in accordance with those statutes, regulations and
applications. The fiscal and reporting policies of funding agencies under the
guidelines referenced in the award require a more detailed management and record
keeping system than may be practiced by other units of the University. Audit
exceptions could arise, not because of failure to complete activities, but
because of inability to provide documentation for achievement of objectives. All
sponsored program personnel must follow sponsor policies and procedures even
though these may result in additional effort on the part of the personnel.
Compliance with the regulations included in the award will ensure that the
program is administered according to sponsor guidelines and will ensure that the
University has the documentation that will be needed to successfully demonstrate
compliance. The information will also help activity directors administer their
activities and accomplish their objectives expeditiously.
Classification of Awards
Negotiations
Use of Awarded Funds
Program Management
Fiscal Control
Other Controls
Expenditures
Personnel Issues
Classification of Awards
Awards can be classified in the following categories:
- Grants
- Contracts
- Subcontracts
- Cooperative Agreements
- Memorandums of Agreements/Memorandums of Understanding
Grant
The term "grant" is commonly used to describe nearly all awards of extramural
support for various projects initiated by faculty and staff members. It is a
transaction with an agency in which the agency provides funds, property, service
or anything of value in order to accomplish a specific goal.
The requirements for submitting proposals vary from agency to agency as do
grant awards. Generally, grant awards have the following characteristics:
- They are made for a particular purpose.
- The purposes are specified in writing.
- They have a definite program start and end date.
- They have a definite budget start and end date.
- They typically include restrictions on the use of grant
funds and on the reallocation of funds from one budget category to another.
- Most agencies require progress reports, program reports,
financial reports and, in most instances, technical reports.
Contracts
Contracts are agreements signed by both parties which bind the sponsor to
provide funding to a recipient in support of a specific set of activities which
include one or more deliverable items. In addition to the above-referenced grant
characteristics, contracts typically include the following:
- The terms of the contract often are spelled out in greater
detail.
- The recipient is obligated to perform the work set forth
in the contract and to deliver any and all products for which the contract
has been awarded.
- The contract must be fulfilled regardless of the cost to
the University.
- The applicant is generally given less latitude to modify
the scope of the agreed upon activities and/or the expenditure of funds
provided by the contractor.
Cooperative
Agreements A Cooperative Agreement is a transaction with an
agency in which the agency provides funds, property, service or anything of
value in order to accomplish a specific goal with substantial involvement from
the sponsoring government or agency. The Cooperative Agreement consists of the
following:
- The Award/Signature Page which is signed by the Agency and
the Cooperator before it is valid.
- The General Terms and Conditions for Grants and
Cooperative Agreement.
- Assurance of Compliance which includes the Scope of Work,
Delivery of Schedule, Budget and Method of Payment.
Memorandum of
Agreements (MOA)/Memorandum of Understanding (MOU)
A Memorandum of Agreement or Memorandum of Understanding is an agreement
between the University and agency where the University enters into a binding
agreement where the roles and contributions of both parties are clearly defined.
The memorandum of agreement/Memorandum of Understanding consists of the
following:
- The date agreement is made,
- The identification of the agreeing parties,
- The Scope of Services/work,
- The budget,
- The terms of agreement,
- Payment methods, and
- Reporting requirements
Subcontracts
A subcontract is a transaction entered into by a supplier, distributor,
vendor, or firm that will furnish supplies or services for performance for a
prime contractor, another subcontractor or a partner. The subcontract consists
of the following:
- Identification of the parties involved,
- The awarding agency,
- The period of performance,
- The statement of work,
- The budget,
- The personnel,
- The terms of agreement and
- The reporting of requirements.
All awards received by faculty and/or staff as members of NSU are actually made
to the University. NSU assumes all financial responsibility and guarantees that
the project will be completed. To accept an award, a number of steps are
required. First, OSP receives notification that the sponsor wishes to support
the project.
For an award, the Principal Investigator/Project Director and
Department Head/Director should review the award’s terms and conditions
and recommend that the University either accepts it as offered or with
changes as outlined in their recommendations.
For a contract, the process begins before an award is made. During
pre-negotiations, the sponsor and faculty or staff discuss technical details.
The OSP verifies budget details and confirms all rates quoted in the proposal.
After this phase, OSP enters into formal negotiations with the sponsor by
reviewing the contract’s terms and conditions. After all parties agree upon the
contract’s content, the University accepts the award.
The assurance that funds will not be used to supplant institutional funds is
inherent in the fiscal policies and procedures of the Commonwealth of Virginia
and in most sponsors. Under these policies budgeting is executed under a set of
strict procedures, and accounting and auditing are likewise executed to assure
that all funds are properly assigned and spent. The University is assured by
these procedures that it will receive its full budget of State funds and any
sponsored programs assigned to it. The University is also compliant with federal
and state guidelines.
Account Create Process
Funds are not released to the University until the project’s official start
date. This date is predicated upon acceptance of all terms of the award by both
parties. Grant start and end dates are set by the sponsor in the award.
Contracts are not as predictable since in some cases the start and end dates are
specified and in others they are determined by the final signature date. The
final signatory may be the University or the sponsor, depending on the contract.
Once the start and end dates are determined, the Post Award Account Create
Conference is scheduled between the PI/PD and GCA to begin the process of
setting up the account number. The account create package contains all forms
needed to create your account. Project expenditures are processed using
this assigned unique code which identifies the correct fund. The PI/PD should
verify required forms with GCA.
Award
Notice
An account number cannot be assigned without an official award notification
or signed contract. The award notice will include such information as the start
and end date, the amount funded, award number, issuing agency’s name, address,
technical/fiscal officer and telephone number, period of performance, title of
project, reporting terms and incremental funding dates on multiple-year
projects, and the official signature of the contract officer.
Grant Budget
Request Form (BU1.5)
The Budget Office and GCA uses the Grant Budget Request Form (BU1.5) to
appropriate the award funding in accordance with the approved budget. This form
contains objects of expense that are compatible with approved budget and cost
accounting standards. Some of the most frequently used object codes are listed
below.
1000—General Operating Expenses. This object code includes contractual
services, supplies and materials and continuous charges.
1110—Fringe Benefits. This object code includes expenses for employer
retirement contributions, salaried state employee insurance, wage earning state
employee insurance and medical hospitalization insurance.
1123—Staff Salaries. Includes classified salary costs.
1125—Salaries, Overtime. Includes expenses for hours worked in excess of the
normal workweek.
1121—Faculty Administration. Includes expenses for compensation to persons
for professional services rendered on a full-time (temporary, restricted, or
permanent) basis or a permanent, part-time basis in administrative positions
carrying faculty appointment in institutions of higher education.
1126—Teaching Salaries. Salaries, Teaching and Research. Includes expenses
for compensation to persons for professional services rendered on a full-time
(temporary, restricted, or permanent) basis or a permanent, part-time basis in
research and teaching positions carrying faculty appointment in institutions of
higher education.
1140—Wages. Includes expenses for general wages, graduate assistant,
overtime, student teaching and research part-time, and work study student wages.
1216—Internal Charges. Includes expenses for services provided for cables,
facsimile-transmissions, local and long distance telephones and similar
telecommunications.
1220—Travel. Includes expenditures for moving and relocation services,
personal vehicle travel, public carrier travel, state vehicle travel,
subsistence and lodging, and travel supplements and aid.
1400—Transfer Payments. Includes expenditures for awards, contributions, and
claims; educational and training assistance; grants and aid; and dedicated and
general shared revenue.
2200—Equipment. Includes expenditures for computer, educational, cultural,
electronic, photographic, medical, laboratory, motorized, office, specific use,
and stationary equipment. 8700—Facilities and Administrative Costs. are those
costs that benefit common or joint objectives and cannot be identified readily
and specifically with a particular sponsored program, instructional activity or
other institutional activity. These costs are normal business activities of the
University such as utilities, public safety, libraries, building and equipment
use and maintenance, accounting, payroll, and academic and sponsored
administration.
Budget Narrative
The Budget Narrative is the approved detailed budget from the sponsoring
agency. In some instances the funded amount may be increased or decreased from
the proposed budget. At this time a revised budget is required.
Salary
Allocation / Extension Report (SAREX)
All faculty, classified and hourly positions included in the sponsored
program budget must have a salary allocation report form. This form is used to
allocate an employee’s pay to various departments. Detailed instructions for
completing the Salary Allocation/Extension Report is included with the form.
Request for extensions will be completed 45 days prior to the expiration of
the sponsored program. This form must be completed if the position to be funded
is beyond the original appointment period.
Temporary
Employment Agreement (TEA)
Positions that fall in the category of part-time lecturer (teaching),
academic model, coach, regular faculty (overload), research or teaching graduate
assistant, and SP15 recipients must have a TEA form completed and submitted with
the SAREX form.
Student Hourly
Form
Student paid positions must have the Student Hourly Form completed and
attached to the SAREX form.
Employee Grant
Contract (Employment Agreement)
Faculty positions paid from a program must be completed and signed by the
appropriate Vice President. This contract outlines the position rank/title, the
project number, salary, the appointment period and any conditions of employment.
Interactive
Fund Accounting System (IFAS) Forms
In order for the PI/PD to purchase items and manage budgets, an IFAS
Signature Authorization Form, a Resource Authorization Form, and an IFAS Access
Request Form must be executed for them to gain access to the University’s
financial system. All forms must be approved by PI/PD supervisory hierarchy and
processed through Enterprise Information System (EIS).
Resource Authorization Form - This form is used to set up in IFAS for
the first time any new employee.
IFAS Signature Authorization Form - When properly completed, this form
is used to set up and give designated individuals access to an account.
IFAS Access Request Form - This forms establishes the job-running
capabilities for the employee. All capability requests are coordinated with the
Enterprise Information Systems (EIS) support staff to maintain security.
These IFAS Forms may be found on the O: drive in the NSU Forms folder. Direct
all inquiries regarding these forms to Mrs. Denee Harris of the EIS office on ext. 32353.
Credit
Card Application
To make purchasing more efficient, the University has a small purchasing
credit card policy. The PI/PD, or his designee, is responsible for making
purchases on the account in accordance with established university guidelines.
Please contact Materiel Management to secure procedural instructions.
Programmatic Reporting Dates
Reporting requirement specifics can be found in the award terms and
conditions which are forwarded to the University with the award notice. Although
each sponsor's reporting requirements may vary, it is usually required that a
PI/PD prepare and submit interim programmatic reports to document progress on a
given project.
All sponsor requirements must be met in a timely manner and the PI/PD is
responsible for submitting all reports via the OSP to the agency.
Norfolk State University operates and manages all fiscal affairs in accordance
with policies and procedures for institutions of higher education as mandated by
the Commonwealth of Virginia. The mandated systems include the Higher Education
Uniform Accounting System, Commonwealth Accounts Reporting System, the Student
Loan System, and the Student Accounts System. The fiscal control of all funds
at Norfolk State University is the responsibility of the Vice President for
Finance and Business. Checks and balances are utilized throughout the University
system to assure early detection of potential problems.
The University utilizes the services of the Internal Auditor and will
continue the Commonwealth of Virginia's annual audit to assure cohesive
programming. A set of accounts will be established in the Budget Office
to maintain individual control numbers to each award. Within the system
each PI and PD will be responsible for the control of his budget and the
maintenance of a set of unofficial financial records in his own office
to guide daily management. Official records will be maintained and
financial reports will be generated by GCA.
Official reports will be computer-generated and distributed to each Director
or Investigator for review and approval, prior to submission. The Director is
then able to reconcile his office records and the monthly statement to assure
the accuracy of each. Directors and Investigators are responsible for conveying
errors to the appropriate office in Business and Finance or the Office of Budget
and Planning as appropriate.
Other Controls
It is the responsibility of this office to maintain adequate standards of
biological containment for activities involving potential biohazardous
materials; to maintain procedures with regards to safeguarding human subjects;
and to assure that personnel follow rules and guidelines for the care and use of
animals as set forth in the Animal Welfare Act of 1968 and the PHS-NIH Health
Extension Act.
All proposals involving the use of biohazardous materials, human
subjects and/or animals must be accompanied by a completed application
prior to submission to sponsors.
All expenditures must be executed in compliance with University Purchasing
Procedures as detailed in Materiel Management Policy and Procedures No. 1-27.
Equipment
Purchases
Purchases for equipment must be purchased through the University’s IFAS and
must conform to Materiel Management Policy and Procedures No. 18. Please refer
to Policy No. 18 for further information.
Travel
Purchases for travel must be purchased through the University’s IFAS and must
adhere to the most current Commonwealth of Virginia, Department of Accounts,
State Travel Regulations which includes daily per diems for meals and incidental
expenses and lodging including taxes and tips. Please refer to Travel Policy
and Procedures No. 1 for further information.
Policy
35 Use of Leave Time for Classified Employees in Grant
Funded Positions
This policy states that during the final stages of the sponsored program, the
employee must take all annual leave down to the very minimum prior to the ending
date of the sponsored program. (Please see Policy 35 for the complete policy)
Time and Effort
Reports (TER)
The Federal Office of Management and Budget (OMB) Circular A-21 requires
universities to document 100% effort of employees paid from federal funds. GCA
manages this process through the use of Time and Effort Reports.
Program Income
Some sponsored projects may generate gross income as a result of the award.
Program income includes, but is not limited to: income from fees for services
performed, the sale of commodities or items fabricated under an award, license
fees, royalties on patents and copyrights, and interest on loans made with award
funds. Interest earned on advances of federal funds is not considered program
income.
Except as otherwise provided in federal awarding agency regulations or the
terms and conditions of an award, program income does not include the receipt of
principal on loans, rebates, credits, discounts, or interest earned on any part
thereof. Program income should be treated in accordance with NSU’s Program
Income Policy.
Unexpended Funds
For continuation or renewal proposals most sponsors require an estimate of
unexpended funds and reserve the right to approve the use of those funds for
future budget periods. This should be discussed with OSP staff well in advance
of a resubmission to determine whether a carry forward request or a no-cost
extension is more appropriate.
No
Cost Extensions
The OSP encourages all PI/PDs to complete work under their agreement in a
timely manner. Therefore we expect all work to be completed within the time
specified in the award agreement, however, if the PI/PD needs additional time to
complete the work outlined in the proposal a request to extend the project
period should be completed. The request should come from the PI/PD in writing
or by e-mail to the OSP.
Under the Federal Demonstration Partnership (FDP), a request for a no-cost
extension under all participating Federal agencies (except the Office of Naval
Research), may be approved by the OSP.
OSP must notify the sponsor at least ten (10) days prior to the expiration of
the award, and in some cases at least thirty (30) days prior, therefore
requires the departmental request at least fifteen (45) days prior. The OSP
will notify the sponsor of the extension if approved.
Intellectual Property
The University has adopted an Intellectual Property Procedures policy. The
Intellectual Property Procedures can be downloaded for review.
The agreement can be pulled in word format.
The agreement can be pulled in PDF format.
In addition to those items listed above, federal regulations contain provisions
for carryover funds, procurement of general support services, insurance on
federally owned equipment, public information service costs, publication costs,
renovation expenses, and patent costs, among others. The following list contains
agency links for specific guidelines that govern University grants and contract.
NIH Guide to
Grants and Contracts
A-21,
Cost Principles for Educational Institutions (10/1/97)
A-87,
Cost Principles for State and Local Governments (5/4/95, amended 8/29/97)
A-122,
Cost Principles for Non-Profit Organizations (5/19/98)
A-102,
Grants and Cooperative Agreements with State and Local Governments (10/7/94,
amended 8/29/97
A-110,
Uniform Administrative Requirements for Grants and Agreements with Institutions
of Higher Education, Hospitals, and Other Non-Profit Organizations (11/19/93,
amended 9/30/99)
A-133,
Audits of States, Local Governments, and Non-Profit Organizations (6/24/97)
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