SPO provides post-award management and serves as a liaison between the university and the sponsoring agency once an award has been made. SPO assists with compliance, subcontract negotiation, project set-up and monitoring, modification of awards, effort reporting and project close-out activities.
All award documents are to be submitted to SPO for award set up. When SPO receives a new award, the document is sent to the principal investigator or program director with a congratulatory letter.
The PI/PD should examine:
- The statement of work
- budget (indirect costs matching, release time)
- reporting requirements
- re-budgeting restrictions
- required sponsor prior approvals
- patent and copyright terms, if applicable,
- submissions dates for continuation or renewal proposals and other provisions.
The PI should communicate any objections or questions to SPO for discussion and possible negotiation with the sponsor.
The PI/PD should review the following institutional policies to better understand the research compliance requirements for managing grant funds:
A Post-Award Account Create conference between the University Grants Accountant, the PI/PD and SPO will be conducted to make certain PIs/PDs are aware of and agree to carry out their responsibilities to Claflin University and to the sponsor while participating in sponsored activities.
The PI/PD will be required to complete the Budget Request form for the account number to be created. This process opens chargeable accounts for the PD/PI and the responsible unit to use during the course of the project. The PI/PD will use the assigned account number for charging all expenditures directly related to the project.
The following are the forms for the Account Create meeting. The PI should complete the Approved SPO Budget Request Form using the Chart of Expense Accounts.
The project and cost sharing account budgets, provided by SPO to the Fiscal Affairs Office, will be valued at the funded amount of the sponsored award and at the associated amount of committed cost sharing respectively. It is the responsibility of the PD/PI to work with appropriate personnel to make available committed cost sharing funds from that authority's sources.
SPO will work with the PI/PD through the lifecycle of the award to provide oversight for allowable costs to a project. However, the PIs/PDs are responsible for understanding and fulfilling their fiscal obligations accordingly and are expected to exercise proper fiscal oversight for each sponsored project they are awarded. This includes, but is not limited to performing:
- monthly reviews of project budgets
- addressing budget discrepancies and errors promptly
- completing time and effort reports in a timely manner
In addition, PIs/PDs are responsible for ensuring that only costs which are allowable (i.e., allocable, collectible, consistent and reasonable) are charged to projects. All other charges, whether made willfully, or through ignorance or negligence, are violations of federal law which could result in penalties to the University and the individual PI/PD.
Technical reports and deliverables should be completed in compliance with sponsor guidelines. All reports must be submitted to SPO for approval and submission to the agency. When the PI/PD is required to submit reports online, reports are to be forwarded to SPO for review and approval before submission to the sponsor agency.
Financial reports must be prepared and submitted by the Division of Fiscal Affairs. In addition, financial data required for technical or program reports must be prepared and authorized by the Office of Fiscal Affairs.
The PD/PI and his/her department are responsible for identifying appropriate charges to be applied against cost sharing accounts throughout the life of a sponsored project but certainly before the end of the project period. All required cost sharing obligations must be met and properly documented in the accounting system before the project accounts can be financially closed out.
Changes in Scope of Work
A change in the award or contract’s scope of work is any change that significantly alters the subject matter or objectives even if there is no associated budget revision. The PI/PD must contact SPO if there is a change in the scope of work. SPO will review the award terms to determine if prior approval from the sponsor is needed. For all prior approvals, SPO will reach out to the sponsor to obtain authorization.
Budget revision requests must be submitted to SPO for processing. SPO will consult with the PI/PD to determine the allowability of the request based on the award terms and conditions. Reallocation of budget categories should not be performed without confirmation from SPO that the action is permissible by the sponsor.
Change of Principal Investigator
When a change of PD/PI on a sponsored project becomes necessary, sponsor approval/notification may be required. Requests should be routed to SPO from the Department/School for processing. The request should include the following:
- Name of PD/PI issued the award
- Sponsor Name
- Account number
- Name of the nominated replacement, along with a current biographical sketch
- a full justification for the requested change with approval from the Department/School.
SPO will submit the request to the sponsor and update grant records accordingly. In the event of a sponsor objection to the request, SPO will contact the requesting department to determine next steps.
Transfer of Grant to Another Institution
A sponsor awards funds to the institution and not the PI, therefore, if a PI leaves the institution, he/she must obtain permission from Claflin University to take the award to the new institution. The PI/PD must obtain approval from the Department/School/Administrators before SPO can submit a grant transfer request to the sponsor. Upon approval from the Department/School, the following information should be submitted to SPO:
- Name of PD/PI
- Sponsor Name
- Account number
- Name of new institution and an administrative contact at the new institution
- Letter signed by appropriate Dean and Chair giving approval to transfer the grant.
SPO will submit the request to the sponsor and work with the new institution to transfer any remaining funds after all allocable expenses are charged to the project.
No Cost Extensions
SPO encourages the PI/PD to complete the project in a timely manner. However, there are times when additional time is needed to finalize the project. A no cost extension extends the period of performance on a project. No cost extensions are usually requested to provide additional time to complete work on the project to meet the deliverables or to ensure the proper close-out of an award. A sponsor may require prior approval of a no cost extension or may grant the institution the authority to proceed without prior approval. If a no cost extension is need, the PI/PD must contact SPO to initiate the request.
Approximately 60-90 days prior to the expiration of the project account, the SPO will contact the PI/PD regarding the status of the account via email. The PI/PD should ensure that all project costs are appropriately charged to the account. As the project nears termination it is important to review all costs and clear those which are unallowable or inappropriate to this account.
The notice of project closeout indicates the required closeout actions. The requirements for project closeout are established by contractual provision and/or agency regulations. When all closing actions are completed, the project file is closed and housed in SPO for a period of five years (longer, if required by the agency).