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Roles and Responsibilities in the Administration of Grants at UMSL
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Transcript of Roles and Responsibilities in the Administration of Grants at UMSL
Roles and Responsibilities in the Administration of Grants
at UMSL
University of Missouri Policies & Procedures
Responsible Parties
• Principal Investigator (PI/Co-PI)
Named by sponsor on award document with overall responsibility to manage the award.
• Department Administrator (Dept Admin)
Individual in the department assisting PI with the fiscal management of an award.
• Office of Research Administration (ORA)
Campus office monitoring compliance with applicable regulations, policies, and terms and conditions of the award.
See Business Policy Manual, BPM 210 Sponsored Programs
High Level Roles & Responsibilities
Principal Investigator
The University of Missouri assigns primary responsibility for fiscal management to the Principal Investigator (PI), which is in the spirit of both federal regulations, individual sponsor guidelines, and university policies and procedures.
Per current UM System policies, PIs are responsible for:
All expenditures made against a sponsored project
Knowing and adhering to the specific limitations and restrictions of the sponsor and of the award documents
Knowing and adhering to all administrative and financial compliance requirements of sponsors, regulators and the University
Department Administrators are responsible for:
Providing support to PIs in the administration of awards
Knowing and adhering to all administrative and financial compliance requirements of sponsors, regulators and the university
High Level Roles & Responsibilities
Department Administrator
The Office of Research Administration (ORA) is responsible for:
Reviewing proposals to ensure they meet agency requirements before submission
• Overall budget within the guidelines
• Risk-assessment if budget exceeds $3 million
• Evaluation of sources of cost share, if any
Overseeing regulatory compliance of proposals
• IRB, IACUC, conflict of interest, and export control compliance
Ensuring fiscal compliance with sponsor and University policies and procedures (e.g., financial reporting, milestone tracking, invoicing)
High Level Roles & Responsibilities
ORA
Roles & Responsibilitiesin Proposal Development and Submission
(Pre-award)
Development of proposal• Proposal narrative, scope of work
• Financial budget and justifications
• Approvals – Proposal Signature Routing Sheet, PSRS (aka, signature page)
• Refer to ORA website for institutional information
Proposal Submission to the ORA• Minimum of two weeks prior to deadline• Extra week if budget is above $3 million
ORA reviews and submits – PI does not submit
directly
Roles & Responsibilities
Principal Investigator< General Pre-Award Responsibilities >
The PI’s general responsibilities in proposal development include the following:
Ensure sponsor requirements and guidelines are met
• Forms• Unique allowability restrictions• Submission deadline
Compliance with University policies• Accounting Policy Manual (APM) – Section 60• Business Policy Manual (BPM) – Section 210
Roles & Responsibilities
Principal Investigator< Pre-Award Responsibilities: Proposal Development >
Allowable direct costs per A-21 and sponsor• Reasonable• Allocable• Consistent treatment• Conform to limitations or exclusions of sponsor
Justify any unlike circumstances
Reasonableness of effort commitment• Evaluate with existing commitments
Roles & Responsibilities
Principal Investigator< Pre-Award Responsibilities: Budget >
Use of subawards• Include in budget and scope of work• Properly identified• Subject to same compliance requirements• Obtain letter of commitment and budget from
sub-awardee grants office
Use appropriate F&A rate• Approval required for any waivers from VPR
(rarely approved)
Roles & Responsibilities
Principal Investigator< Pre-Award Responsibilities: Budget >
Cost sharing requirements
• Cost share should be included only when required or suggested
• Must be an allowable direct cost
• Committed cost share must be approved
• Evaluate for reasonableness
• Ensure all cost sharing is clearly identified – direct or implied
• If award is received, all committed cost share must be allocated and documented appropriately
Roles & Responsibilities
Principal Investigator< Pre-Award Responsibilities: Budget >
Conflict of Interest disclosures
Human Subjects – Institutional Review Board (IRB)
Institutional Animal Care and Use Committee (IACUC)
Export Control regulations
Intellectual property potential
Responsible conduct of research training
Roles & Responsibilities
Principal Investigator< Pre-Award Responsibilities: Compliance >
The Department Administrator:
Assists with review of proposal for compliance
Reviews budget for allowable costs• Identifies need to justify unlike circumstances
Ensures PSRS is signed by appropriate individuals
Roles & Responsibilities
Department Administrator< Pre-Award Responsibilities: Proposal Development >
Before submission, the ORA reviews for: Compliance with submission requirements
Proposal budget calculations
Allowable costs and budget justification
Risk assessment if budget is over $3 million
Appropriate approvals on the PSRS• The ORA obtains institutional endorsement
The ORA is responsible for formally submitting the proposal.
Roles & Responsibilities
ORA< Pre-Award Responsibilities: Review & Submission >
The PI evaluates need for a Pre-Award Project Account and submits a request to the ORA
Criteria to establish an account prior to award:
• Proposal must be under review
• PI, Department Head and/or Dean guarantee costs
• Justification to begin work before award receipt
• Other approvals required (e.g., human subject)
Roles & Responsibilities
Project Establishment
The ORA monitors Pre-Award Projects that are:
• Older than 90 days (discusses status with PI)
• Older than 6 months (determines appropriate action)
Upon award execution, the ORA:
• Changes status from Pre-Award to Awarded
• Reviews pre-award projects to ensure spending is properly reflected
Roles & Responsibilities
Project Monitoring
Roles & ResponsibilitiesAccepting & Establishing an Award
for Sponsored Programs
(Post-Award)
Upon receipt of the Notice of Grant Award (NGA), the PI:
Notifies all appropriate individuals (e.g., ORA, sub-awardees, CoPIs, Dept Administrator)
Determines whether to accept award
Reviews and approves the NGA
Creates a revised budget if necessary
Conducts technical and programmatic negotiations
Roles & Responsibilities
Principal Investigator< Post-Award Responsibilities: General >
Once award is fully executed, the PI: Delegates authorization to:
• Dept administrator or other applicable persons who are university employees with direct knowledge of the award and related compliance requirements
Determines payroll distribution
Identifies non-owned assets/equipment in the award
Reviews expenditures posted to the grant on monthly basis
The PI has overall responsibility to manage the award.
Roles & Responsibilities
Principal Investigator< Post-Award Responsibilities: General >
The PI ensures regulatory requirements are in place: Conflict of Interest disclosures
Human Subjects – Institutional Review Board (IRB)
Institutional Animal Care and Use Committee (IACUC)
Export Control regulations
Intellectual Property
Responsible Conduct of Research training
Roles & Responsibilities
Principal Investigator< Post-Award Responsibilities: Regulatory >
Upon receipt of the NGA, the Department Administrator assists with:
Notifying all appropriate individuals
Creating a revised budget if needed
When the fully executed award is established, the Dept Admin:
Verifies the budget information in the financial system
Sets up payroll distributions
Ensures award funded non-owned assets/equipment are identified
Reviews expenditures on monthly basis and issues reports to the PI as deemed necessary
Roles & Responsibilities
Department Administrator< Post-Award Responsibilities: General >
Upon receipt of the NGA, the ORA reviews for: Award consistency with proposal
Compliance with University policies
PI approval and acceptance of NGA
Completion of regulatory approvals
Roles & Responsibilities
ORA< Post-Award Responsibilities: General >
Before award acceptance, the ORA:
Conducts fiscal, business, and legal negotiations
Notifies sponsor of changes in:• Project scope• Budget• Cost sharing• Facilities and Administrative (F&A) rate• Other legal clauses• Other changes at PI‘s direction
Roles & Responsibilities
ORA< Post-Award Responsibilities: General >
After award is fully executed, the ORA: Notifies appropriate individuals
Establishes award in the financial system including• Project ChartField string
• Budget information
• Subawards
• Cost sharing commitments
• Catalog of Federal Domestic Assistance (CFDA) and Schedule of Expenditures of Federal Awards (SEFA) cluster
• Billing information
• Milestones for report due dates
Ensures award funded non-owned assets/equipment are identified and tracked
Roles & Responsibilities
ORA< Post-Award Responsibilities: General >
Roles & ResponsibilitiesAllowable Costs: A-21
Effort Verification Reporting (EVR)
Cost Sharing
General
Cost Transfers and PCEs
Roles & Responsibilities
A-21: Allowable Costs
Roles & Responsibilities
EVR
Roles & Responsibilities
Cost Sharing
Activity PI Dept Admin
Overall Compliance Responsibility XAttend Compliance Training X XAdministrative Financial Management X XMonthly Mangerial Review X XAllowable Costs X XDocumentation to Support Costs X
Roles & Responsibilities
General
Roles & Responsibilities
Cost Transfers & PCEs
Roles & ResponsibilitiesClosing Sponsored Awards
Ensures all costs charged to award are: • Allowable• Within period of availability• Documented
Identifies outstanding charges• P-card• Feeder systems (e.g. telecommunication)
Clears deficits
Ensures cost transfers are made timely
Roles & Responsibilities
Principal Investigator< Closing Sponsored Awards: Final Review >
Ensures compliance requirements are met for: Committed Effort - PI and key individuals
• Example: PI - 25% reduction in effort or 3 month absence
• Significant changes of key individuals
Subawards – final invoices and deliverables received
Cost sharing commitments• Mandatory and voluntary• Changes in category of cost share from award
Other requirements per award agreement• Program income
Roles & Responsibilities
Principal Investigator< Closing Sponsored Awards: Final Review >
Evaluates need for no-cost time extension
Completes PI Certification• Signifies all costs are allowable per A-21 and/or
sponsor
Submits technical and programmatic reports• Reporting period will vary by sponsor
Provides intellectual property notices
Roles & Responsibilities
Principal Investigator< Closing Sponsored Awards: Final Review >
Updates payroll distribution (PAFs)
Cancels P-cards and feeder systems
Retains documents for required period• PI retains scientific data• Department retains transactional data
Returns non-University owned assets to sponsor
Roles & Responsibilities
Principal Investigator< Closing Sponsored Awards: Administrative >
Assists PI in closing of award: Ensuring costs are allowable and documented
Timely addressing items such as:• Cost transfers, Payroll Correcting Entries (PCEs)• Updating payroll distribution (PAFs)• Cancelling P-cards and feeder systems• Closing purchase orders, open encumbrances• Returning non-University owned assets to sponsor
Roles & Responsibilities
Department Administrator< Closing Sponsored Awards >
Works with unit to close out award
Conducts high-level compliance review to ensure:
• Terms and conditions met• Subaward invoices received and paid• Deficits cleared• Technical report completed• Reasonableness of cost transfers • Costs are allowable and inline with budget
Roles & Responsibilities
ORA< Closing Sponsored Awards: Final Review >
Submits final invoice to sponsor• Excess funds de-obligated• Reconciliation of program income
Documentation for permanent file• Proposal, Award, EVRs, invoices, programmatic, technical
and financial reports, sub-award documentation, etc.
Confirms non-owned assets/equipment returned to sponsor
Completes transfers on fixed-price contracts
Inactivates project in financial system
Submits final financial report to sponsor
Roles & Responsibilities
ORA< Closing Sponsored Awards: Administrative >
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MORE INFOOffice of Research Administration
www.umsl.edu/services/ora
314-516-5899