Management of grants, contracts, and other funding agreements is the responsibility of the Principal Investigator (PI) and the Administering Unit.
The PI is the individual with primary responsibility for:
- The scientific integrity and management of the project
- The financial management of project funds
- Adherence to all University policies, and
- Adherence to externally-imposed sponsor terms and conditions including reporting and record keeping requirements contained in the award document. The award document is the funding agency’s official obligation of funds for a project. Many awards cover a multi-year project period made up of several shorter (usually 12-month) budget periods. Funds often are awarded in budget period installments.
It is critical that the PI review and understand the contract or grant requirements and restrictions of each specific award. If any of the award terms are unclear, it is the PI’s responsibility to contact the OCG for clarification and guidance. If the terms of an individual award are more strict than federal guidelines and University policy, the terms of the award take precedence. For example, travel expenses are allowable under federal and University policy, but may be specifically excluded or limited by your specific award.
It is important upon receipt of the fully executed award for the PI and the Administering Unit to review the terms and conditions, make note of important conditions including, but not limited to, reporting deadlines, unallowable costs, areas that may require prior approval such as rebudgeting or no cost time extensions, publications may require sponsors review prior to dissemination, etc…
The Guide to Research Compliance for Principal Investigators and Department Administrators provides a single reference for all the accounting, safety and ethical guidelines that must be taken into consideration on sponsored projects.
Quality research requires adherence to the highest standards of integrity in proposing, conducting and reporting research. UC Davis is committed to achieving the premier ethical and legal standards of research conduct by fostering a culture of compliance, responsibility and conscience that reflects integrity and truth as core values in science and scholarship.
Explore the detailed information found in the links below in order to increase your awareness of, and compliance with, all applicable policies and procedures of the University as well as extramural funding agencies.
UC Davis Compliance Partners
The offices of record for expenditures is the Extramural Funds Accounting office. Upon receiving a fully signed and executed award from the office of contracts and grants, Extramural Accounting will establish a specific account and fund number for the project. The administering unit charges all costs to this number at the direction of the PI or PD. The budget for expending funds is allocated to sub-budget categories based on amounts in the proposal budget agreed to by the university and the funding agency.
Regularly Monitor Award
As the project progresses, the project should be monitored monthly to ensure adherence to award terms and conditions. Financial Ledger Reviews should be performed at least once a month.
Universities have a responsibility to be compliant with federal regulations, including the requirement that a commitment of effort is required on all externally funded projects. Effort reports are certified after the effort has been expended. It shows the actual effort, as a percentage of time, spent on the project. Effort reporting ensures that the effort charged or committed to each research award has actually been met. Effort reports are tracked in the Effort Reporting System (ERS). For more information about Effort Reporting, please visit Extramural Funds Accounting’s Effort Commitment and Cost Sharing page and UC Davis Directive 06-049.
The PI is responsible for submitting all required interim and final technical or project reports to the awarding agency or sponsor. The PI should review the award terms and conditions and make note of the following items in order to ensure timely completion of the reports as required by the Sponsor:
- What technical or program reports are required?
- What are the deadlines for reports?
- What format and submission methods are required?
Reporting Guidance for common sponsors, as well as generic guidance, is provided below.
NIH Progress Reports
The e-Snap feature in E-Commons has changed to Research Performance Progress Report (RPPR).
- Progress reports for Streamlined Noncompeting Award Process (SNAP) and Fellowship Awards with budget start dates on or after July 1, 2013, must be submitted using the era RPPR Commons Module.
- Progress reports for SNAP awards with budget start dates prior to July 1, 2013, may be submitted as either an RPPR or an eSNAP.
- Progress reports for fellowship awards with budget start dates prior to July 1, 2013 may be submitted as either an RPPR or a paper PHS 416-9, Ruth L. Kirschstein National Research Service Award Individual Fellowship Progress Report for Continuation Support.
Please review details in “NIH Research Performance Progress Report (RPPR) Instruction Guide” available at:Instruction Guide
Report content requirements as well as specific formats may be spelled out in the award terms and conditions. Typically the report content requirements may include:
- Project identification information
- Significant results of the project
- Project difficulties and solutions
- List of publications resulting from the project, including articles in progress (Please note some sponsor may require publications be submitted to the sponsor for their review prior to public dissemination.)
- A discussion of “milestones” and “deliverables”
Information on final technical reports can be found under SPO’s closeout tab.
No-Cost Time Extensions
Principal Investigators (PIs) are expected to complete a project within the original period of performance. However, unexpected circumstances can arise which justify a need for additional time. A No-Cost Time Extension should be requested only when the original scope of work cannot be completed within the project period and no additional funds will be required for completion. No-Cost Time Extensions should not be requested nor will they be approved simply because the PI expects funds will remain at the end of the project or to explore new avenues of research. This latter situation constitutes a change in the scope of work. Except as outlined below, sponsors must approve requests for No-Cost Time Extensions.
Federal agencies issuing awards under the terms and conditions of the Federal Demonstration Project (FDP) and the National Endowment for the Humanities (NEH) have delegated the authority to approve No-Cost Time Extensions to the campus. If the award specifically states that it was issued under the FDP or is sponsored by the NEH, and it does not contain any restrictions on time extensions, the Office of the Vice Chancellor for Research (OVCR) can approve a single extension for a period of up to twelve (12) months. Sponsors must approve all other time extension requests.
All requests must be forwarded to the OR. If the campus has authority to approve it, OR will notify the sponsor of the time extension. If the campus does not have this authority, OR must sign the request before it is forwarded to the sponsor for approval. The request should be in the form of a letter and addressed to either the Director of Sponsored Programs (when the OR can approve the request) or the sponsor’s Program Officer (when sponsor approval is required). The letter should contain the following information:
- The reason(s) why the work cannot be completed within the original project period, a brief summary of the progress made to date, and the work which still remains.
- The length of additional time required to complete the project. For most sponsors the maximum amount of time per request cannot exceed 12 months. For awards where the campus can approve the extension, the maximum is 12 months, and the OR can only approve one extension. Sponsor approval is always required for subsequent extensions.
- An estimate of the funds expected to remain unobligated on the original date of expiration, and a summary budget on how these funds will be used.
Once the request is forwarded to the OR it will be reviewed to ensure the above criteria are met. If the request is complete and the OR has the authority to approve it, it will be signed by the Director of Sponsored Programs and the sponsor will be notified that an extension has been approved. If the sponsor must approve the request, it will be signed by the Director of Sponsored
Programs and returned to the department/unit for mailing. If the OR is to forward the request, be sure to include the full name and address of the person who is to receive it.
To minimize the possibility of a break in funding, PIs should forward requests to the OR at least 45 days prior to the award’s expiration date. If the request can be locally approved, this will allow adequate time to notify the sponsor. If the request has to be approved by the sponsor, this amount of time should be enough for them to process it. Please note that all requests received after the project expiration date have to be approved by the sponsor, even if the campus could have originally approved it.
If you have questions about No-Cost Time Extensions and who can approve them, please call Sponsored Programs (754-7700) and ask for the assistant assigned to your department or unit. (This contact information updated 9/1/09.)
Note: The Office of the Vice Chancellor for Research (OVCR) mentioned in the memo is now called the Office of Research (OR)
National Institutes of Health (NIH):
Below are some handy tips and tools to help your new faculty member begin the process of transferring their NIH projects:
- First, if the new faculty member has not already done so, it’s most important to contact the Program Director at NIH regarding their NIH project(s) and explain to them that they’ve accepted a new position and identify that Institution, additionally, identifying when the appointment start date effective. In addition, explain that they would like to initiate a request to transfer their NIH project(s) to their new institution.
- Additionally, the attached PDF will walk the faculty member through what their previous University needs to do to initiate the transfer paperwork and what the new University is responsible for during this process.
- The website to the instructions are below and attached with highlighted notes for your convenience. http://www.niams.nih.gov/funding/Policies_and_Guidelines/transfer_institution.pdf
- The required Forms are found at the below website: http://grants.nih.gov/grants/forms.htm
- More important, the new faculty member will need to get specific instructions from the Program Director on how to transfer any not yet funded pending NIH proposal(s). Typically (but this may vary), the previous University signs a relinquishing statement for that proposal and a new proposal package is submitted directly to the Program Director under the new University, reflecting the current salaries, fringe benefits, and indirect costs for that new University.
- Once the faculty member has reviewed the information and discussed the information with your Program Director, please contact your Department Administrator in your Administrative Department and they will reach out to the Sponsored Programs, Proposal Analyst (insert link to the SPO Contact web page) to provide Sponsored Programs with the information needed to assist with the transfer application process.
National Science Foundation (NSF):
Disposition of a Grant When a PI/PD Transfers from One Organization to Another Organization (14-1 Award Administration Guide)
(i) Policy. When a PI/PD plans to leave an organization during the course of a grant, the organization has the prerogative to nominate a substitute PI/PD or request that the grant be terminated and closed out. In those cases where the PI/PD’s original and new organizations agree, NSF will facilitate a transfer of the grant and the assignment of remaining unobligated funds to the PI/PD’s new organization. This should normally be done with a tripartite agreement (involving NSF, the PI/PD’s original organization and new organization), or by a subaward arrangement (in certain circumstances) between the PI/PD’s original and new organizations, subject to NSF’s consent. (See AAG Chapter II.B.3.)
(ii) Procedures. When a PI/PD plans to leave an organization during the course of a grant, the PI/PD or the Sponsored Projects Office, or equivalent, shall notify the NSF Program Office. If the project is to continue with the original organization, the NSF Program Officer should advise the grantee to nominate a substitute PI/PD (see AAG Chapter II.B.2g). If the project is to be continued at the PI/PD’s new organization, and if NSF and both organizations agree, formal notification of the impending transfer can be electronically initiated by either the PI/PD or the PI/PD’s organization. The amount transferred has to be equal to or less than the unobligated balance.
The request shall include a:
- Brief summary of progress to date;
- Description of work yet to be accomplished;
- Completed on-line transfer request, including total estimated disbursements to date (transfer amount will be automatically calculated, based on the amount entered in total estimated disbursements). The original organization is responsible for including in the total estimated disbursements, any anticipated costs yet to be incurred against the original grant.
- Detailed line item budget for the transfer amount and any outstanding continuing grant increments.
The original organization concurs with the transfer of the award by electronically forwarding the request to the new organization.
The new organization completes the request by providing a detailed budget for the transfer amount agreed to by both organizations. The new organization must electronically sign the request when submitted to NSF. Submission of the request constitutes agreement by the new organization to assume responsibility for completion of the project effort and to administer the grant (as originally awarded) from the transfer date to completion in accordance with any special terms and conditions and the applicable general terms and conditions that normally govern NSF grants made to the new organization. Special terms and conditions, as appropriate, cited in the original award will convey to the new grantee organization.
FastLane will assign at submission a proposal number. This proposal number will become the new grant number when the transfer is approved by an NSF Grants and Agreements Officer.
(iii) Fund Transfer. Upon receipt of the above material, NSF will review the request and, if approved, deduct the specified transfer amount from the original grant and re-establish it under a new grant number at the new organization. Award notification by the NSF Grants and Agreements Officer will constitute NSF approval of the grant transfer. The award notification also will specify the applicable basic terms and conditions that govern the grant (i.e., RTC, NSF GC-1, or other Terms and Conditions).
(iv) Upon transfer of the grant to the new organization, any monetary discrepancies must be resolved between the original and the new grantee. NSF will not intervene in any disputes between the two organizations regarding the transferred amount.
(v) Equipment Transfers. Equipment purchased with NSF funds for use in a specific project should remain available for use for the duration of the project. PI/PDs who are in the midst of projects that included funding for equipment and who will continue the project at a new organization with NSF support should be able to arrange with their original organization to have the equipment transferred with them. Shipping costs for such equipment may be charged to the original or transferred grant as an allowable cost. Budgets should not include funds to “buy” equipment that had been previously obtained with Federal funds.
(vi) Possible Alternatives to the Transfer Process. When the amount of time and funds remaining in a project are modest, and if both the original and new organizations are in agreement, the original organization may issue a subaward to the new organization for completion of the project. This and other possible alternatives should be discussed with the NSF Grants and Agreements Officer.
Sponsored Programs’ specialty Negotiation Team consists of an experienced group of contract negotiators specifically tasked with expediting contracts including master agreements, awards from private corporations, confidentiality agreements, CRADAs, unfunded collaboration agreements, awards requiring complex negotiations or special interests, and related subawards. The Negotiation Team includes ancillary members representing key campus stakeholders such as InnovationAccess, Office of Corporate Relations, Office of Foundation & Corporate Giving, UCDHS Contracts, and Materiel Management-Business Contracts.
Contracts triaged to the Negotiation Team are not managed by the administering department’s regularly assigned SPO Award Analyst. However, award documents may still be sent to firstname.lastname@example.org.
This section provides a list of circumstances that require prior written approval of the federal entity (awarding agency or cognizant agency) before action can be taken by the campus. This list focuses on those requirements that are new or have changed as a result of the Uniform Guidance.
Cost Sharing or Matching – Voluntary cost sharing is not permitted on any federal proposal. Using the unrecovered indirect costs (when solicitation limits recovery of indirect costs to less than the full negotiated rate) to offset a cost-share component in proposals that require mandatory cost-sharing, calls for agency prior approval. If this is included in proposal budgets, it must be specifically requested via the budget justification section.
Program Income – If a project generates program income, and the PI wishes to retain it to carry out the purpose of the award, prior approval must be secured. Otherwise, program income must be used to offset sponsor expenses on the award.
Revision of Budget and Program Plans – PIs can now be absent from the project (location) and be still “engaged” in research activities without getting prior approval and/or a temporary replacement PI. A reduction in PI’s effort of 25% or more requires prior approval.
Rebudgeting of funds earmarked for participant support costs requires prior approval.
Prior approval is required for re-budgeting cost share. (Specifically, cost share must be delivered for the purpose for which it was promised.)
Fixed-amount Subawards — Agency prior approval is now required to enter into a fixed-amount subaward rather than a cost-reimbursement subaward, and the total value of each fixed-amount subaward may not exceed $150,000. To expedite agency approval and subsequent issuance of the subaward, PIs/departments should add a new justification statement to proposals contemplating a fixed-amount subaward. (For more information, see SPO’s Subaward Page.
Administrative or Clerical Costs — New as an allowable charge; however, prior approval is still required. In instances where these costs are contemplated, in order to expedite matters in the event of an award, it is recommended that prior approval be sought at the proposal phase (i.e., include in the budget and fully justify and request via the budget justification).
Compensation – Personal Services — Formal Effort Reporting is replaced with this new terminology, placing greater emphasis on Internal Controls.
(h)(1)(ii) Incidental activities. Incidental activities for which supplemental compensation is allowable under written institutional policy (at a rate not to exceed institutional base salary) need not be included in the records described in paragraph (h)(9) of this section to directly charge payments of incidental activities, such activities must either be specifically provided for in the federal award budget or receive prior written approval by the federal awarding agency.
Incidental activities for which supplemental compensation is allowable under written institutional policy.
Charges of a faculty member’s salary to a federal award must not exceed the proportionate share of the Institutional Base Salary (IBS) for the period during which the faculty member worked on the award and requires prior approval if not included in the award budget.[should any of this be added to earlier reference to effort reporting?]
Entertainment Costs — Costs of entertainment, including amusement, diversion, and social activities and any associated costs are unallowable, except where specific costs that might otherwise be considered entertainment have a programmatic purpose and are authorized either in the approved budget for the federal award or with prior written approval of the federal awarding agency.
Where possible and when necessary for the project, these costs will need to be included in the application to the funding agency or be the subject of a prior approval request after the award has been made.
Exchange Rates — PIs/departmental administrators, should notify Sponsored Projects offices ASAP if they feel their project qualifies for additional funding as a result of fluctuation in exchange rates (e.g., foreign subs, etc.).
Memberships, Subscriptions and Professional Activity Costs — Costs of membership in any civic or community organization are allowable with prior approval by the federal awarding agency or pass-through entity.
Participant Support Costs – Inclusion of this direct cost requires prior approval. For expediency, in the approval process, include and fully justify in proposal applications when necessary to carry out the project.
Pre-award Costs –Now requires “written” approval. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the federal award and only with the written approval of the federal awarding agency.
Travel Costs – Dependent care travel costs cannot be included in proposal budgets until UC establishes a policy. PIs need to understand that this new allowance of dependent care costs is NOT to pay for the travel expenses of their dependents accompanying them on their travel, but rather to pay for temporary expenses that are above and beyond normal care and that are a direct result of the employee’s travel.
For example, an employee with a small child must travel for two days, leaving at 8 a.m. Monday and returning at 5 p.m. Tuesday. Because the project necessitates the employee being in attendance on Tuesday, the employee must stay overnight. The grant cannot pay for child care expenses incurred during the normal work day on Monday or Tuesday but can pay for expenses incurred to provide care for Monday night.