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Award Process and Other Post-Award Administrative Processes

I. SETTING UP AN ACCOUNT

The Office of Sponsored Programs (OSP) working with the Principal Investigator (PI) will negotiate the terms and conditions of the sponsored agreement. The time required to negotiate the agreement depends on a number of factors. As a general rule, negotiating contract with private industry takes more time than grants from the Federal Government. The OSP is the only office authorized to conduct negotiations and always involves the principal investigator in this process. Under no circumstances should the PI sign a sponsored agreement or give the impression that she/he is negotiating on behalf of the University.

When all negotiations are complete and the OSP receives the signed award notice/contract, the OSP is responsible for the initial entry of an award in the university financial system. We wish to complete this process as speedily as possible but need information as outlined in the Establishing an Award link. Failure to provide OSP with any of this information means a delay in your receiving project funds.

If the Principal Investigator wishes to have an account established in the financial system prior to the receipt of a complete award document, a preliminary project account can be established. It is called a Verbal Approval Request.

I.A Policy for Requesting a Sponsored Project Financial Account (aka “Verbal Approval Request”)

After a proposal has been approved for funding by an agency, instances sometimes arise whereby administrative issues at the agency delay the issuance of an award document, resulting in a delay of the establishment of financial accounts. This delay could have a detrimental impact in terms of salary to personnel, purchasing of equipment and a significant delay in the beginning of a project. This policy establishes an internal administrative process to initiate the project while awaiting official agency award documents.

A written request for the establishment of a financial account must be submitted to the Office of Sponsored Programs (OSP) by the Principal Investigator and countersigned by either the Dean or Department Chairperson. This request must contain at a minimum the following three components:

• Identification of the project for which an account is to be established;

• Requested dollar amount and period of performance for the account;

• An acknowledgement that the College and/or Department will be responsible and will reimburse the institution for all costs incurred if for any reason the award is not forthcoming.

Once the OSP receives this request, they will seek verbal and/or written assurance from the sponsor that acknowledges the dollar amount of the award and period of performance, focusing on the start date. Once this assurance has been given to OSP, a Notice of Award Summary (“Green Sheet”) will be issued.

The release of any matching funds and/or the issuance of any subcontracts associated with the project will be withheld pending receipt of the official agency award document.

OSP reserves the right to decline the request for financial accounts if the agency’s assurance is not obtained. Further, if your project involves human subjects, animal or biohazards and institutional approval has not been granted by the appropriate committee, a financial account will not be established until written evidence of such approval has been provided to the OSP. See “Verbal Approval Request” draft.

I.B PRE AWARD COSTS

Many federal sponsors will permit an applicant/grantee, at his/her own risk, to incur obligation and expenditures to cover costs prior to the effective date of any award provided the following criteria are met: The costs concerned are considered necessary to the conduct of the project, the costs are allowable under the potential award, and when required for specific expenditures or activities prior agency approval has been obtained. For new and competing continuation awards, the costs must be incurred within 90 days prior to the effective date of the award. In allowing the applicant/grantee this flexibility, the government expects the grantee to be fully aware that such borrowing against future support must not impair his/her ability to accomplish the project objectives in the approved timeframe or in any way adversely affect the conduct of the project. Additionally, the incurrence of costs prior to the award of a grant imposes no obligation on the Federal Government to either make the award or increase the amount of the approved budget.

It is the policy of WVU to secure approval for pre-award costs when at all possible. A formal letter with supporting budget should be submitted to the federal sponsor by the PI through the OSP detailing the need for the pre-award costs.

II. REVISED BUDGET

Many federal sponsors will permit a certain degree of latitude to re-budget within and between direct cost budget categories to meet unanticipated needs and to make other types of post-award changes. The degree of discretion permitted varies by type of award (grant, cooperative agreement, contract), grantee, and type of programs. Approval may be required from the government, while other approval processes can take place at the institutional level. It is important to review the terms and conditions of your award to determine the re-budgeting latitude you as PI may have. If you have questions regarding re-budgeting, please contact the post-award staff at OSP.

III. CHANGE IN PRINCIPAL INVESTIGATOR

Most federal sponsors will require the grantee to notify them prior to the PI or other key personnel named in the Notice of Grant Award withdrawing from the project entirely, being absent from the project during any continuous period of 3 months or more, or reducing her/his time devoted to the project by 25 or more percent from the level that was approved at the time of award (for example, a proposed change from 40 percent effort to 30 percent or less effort). The federal sponsor must approve any alternate arrangement, including any replacement PI or other key personnel proposed by the grantee.

IV. CHANGE IN THE SCOPE OF WORK

While the type of award (i.e. grant, cooperative agreement or contract) has some bearing on this category, in general, the PI may make changes in the methodology, approach or other aspects of the project objectives. However, the grantee must obtain prior approval from the sponsor for changes in scope, direction, type of training, or other areas that constitute a significant change from the aims, objectives, or purposes of the approved project.

V. NO COST EXTENSIONS (NCE) or EXTENSION OF A PROJECT PERIOD WITHOUT ADDITIONAL FUNDS

Many federal sponsors will permit the grantee to extend the final budget period of the project one time for a duration of up to 12 months beyond the original expiration date shown in the Notice of Grant Award (NGA) if no additional funds are required to be obligated by the awarding office, there will be no change in the project’s originally approved scope or objectives, and any one of the following applies:

• Additional time beyond the established expiration date is required to ensure adequate completion of the originally approved project.
• Continuity of grant support is required while a competing continuation application is under review.
• The extension is necessary to permit an orderly phaseout of a project that will not receive continued support.

The fact that funds remain at the expiration of the grant is not, in itself, sufficient justification for an extension without additional funds.

A formal memorandum from the PI to the OSP requesting the extension, identifying the length of the extension and a justification is needed at least 30 days prior to the original expiration date. This will provide the OSP sufficient time to review the request and notify the sponsor prior to the expiration date of the award.

VI. PROJECT CLOSEOUT

A project must be completed at the end of the award period if the University is to receive completed reimbursement. Projects may require some or all of the following reports: final technical, final financial, patent and invention, and property inventory for both purchases and sponsor supplied equipment. A closeout may also require the submission of a final invoice and a “Contractor’s Release.” Information regarding final reports can be found on the OSP Notice of Award Summary, in the award document or contract, and/or in the sponsoring agency’s guidelines. The Principal Investigator should consult the OSP Closeout staff prior to the end of a project for reporting requirements, report distribution and required delivery dates.

The OSP provides as a reminder to each Principal Investigator (PI)a Notice of Expiration letter for each active project. This letter is issued 90 prior to the expiration date of their project and will hopefully remind PIs if they need an extension to initiate the necessary paperwork, cancel any outstanding encumbrances, or begin preparation on any final technical reports or related documents in accordance with agency requirements.

The office of Financial Administration and Research Accounting is responsible for submitting any financial reports required in order to closeout the award.