| 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 Administration. 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
Awards can be classified in the following categories:
- Cooperative Agreements
- Memorandums of Agreements/Memorandums of Understanding
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 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.
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
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.
Use of Awarded Funds
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.
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.
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.
Colleague Financials Forms
In order for the PI/PD to purchase items and manage budgets, a Colleague Access Request Form and a Resource Authorization 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 the PI/PD in Colleague, for the first time.
- Colleague Access Request Form - When properly completed, this form is used to set up and give designated individuals access to an account. It also 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 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 Administration. 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.
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.
Purchases for equipment must be purchased through the University’s Colleague Financials system and must conform to Materiel Management Policy and Procedures No. 18. Please refer to Policy No. 18 for further information.
Purchases for travel must be purchased through the University’s Colleague Financials system 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.
Use of Leave Time for Classified Employees in Grant Funded PositionsTime and Effort Reports (TER)
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.
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.
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.
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.
The University has adopted an Intellectual Property Procedures policy. The Intellectual Property Procedures can be downloaded for review. IP Procedures
Guidelines and Regulations Governing Federal Grants and Contracts
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)