Module 4: Post-Award Administration of Sponsored Projects (Part 1)

1. Module 4: Post-Award Administration of Sponsored Projects (Part 1) Office of Research and Sponsored Programs The University of Mississippi 100 Barr Hall ~ 662-915-7482 www.research.olemiss.edu/

2. This module will explain what happens after a proposal is funded. Part 1 covers: • Award receipt • Award review • Award negotiation • Award acceptance (or not) • Account set-up • Award management (just the basics) Updated February 2011

3. Award receipt • The university is the legal recipient of all awards • The Vice Chancellor for Research and Spon-sored Programs is the only person authorized to accept (sign) externally-sponsored awards on behalf of the University of Mississippi • All externally-sponsored awards should be sent to the ORSP (this does not include gifts, which are coordinated through University Development and/or The UM Foundation and/or The UM Research Foundation) Updated February 2011

4. Award review • Award review is a collaborative process: • The investigator reviews (with assistance from the department administrator, if appropriate) • The ORSP reviews • The ORSP retains the original award and forwards a copy and a Notice of Award memo to the investigator Updated February 2011

5. What should the investigator look for when reviewing an award? • Everything! Read the entire award, including terms and conditions. Pay close attention to: • Project/budget period • Budget, including cost sharing requirements • Scope of work • Restrictions (especially restrictions on publications and/or foreign nationals) • Reporting requirements Updated February 2011

6. What does the ORSP look for when reviewing an award? • Everything! • All of it • The whole thing • The whole kit and caboodle • The whole enchilada • Etc., etc., etc. Updated February 2011

7. What are some red flags in award review? • Restrictions on publications* • Restrictions on foreign nationals* • Indemnification (State of Mississippi law does not give UM the authority to indemnify) • Restrictions on the university’s intellectual property rights • Excessive reporting or invoicing *These restrictions conflict with UM’s mission. If UM accepts restrictions on publications and/or foreign nationals, our Fundamental Research Exemption may be invalidated. Updated February 2011

8. Why do we pay so much attention to those red flags? • As a public, comprehensive, research institution whose primary functions are the creation, dissemination, and application ofknowledge, the university must: • protect the right to disseminate research results in publications; • protect intellectual property and data rights; • protect itself and the investigator from liability; and • generate revenue without burdensome systems requirements Updated February 2011

9. Award negotiation • If there is language in the award that precludes any of the items mentioned on the “red flags” slides, or other items that may be unacceptable to the investigator or to the university, then the ORSP will try to negotiate with the sponsor to have the language removed from the award. This could take days, weeks, or even months (for industry-sponsored awards). Updated February 2011

10. Award acceptance • After the award has been reviewed by the investigator and the ORSPand • After any negotiations have been completed by the ORSP THEN • The award can be accepted by the university Updated February 2011

11. What are the roles of the investigator and the ORSP in award acceptance? • Investigator • The investigator indicates acceptance of an award by signing the Notice of Award memo and returning it to the ORSP • Office of Research and Sponsored Programs • The Vice Chancellor for Research and Sponsored Programs is the only person authorized to accept (sign) externally-sponsored awards on behalf of the University of Mississippi • By accepting an award, the university is legally bound to the budget, the scope of work, the project period, and all terms and conditions pertaining to the award Updated February 2011

12. What does the investigator’s signature on the Notice of Award indicate? • I have reviewed the terms and conditions and agree to comply with sponsor and university requirements • I accept responsibility for the technical aspects of the project, including timely submission of technical reports • I agree to submit activity reports and cost sharing details as required AND … Updated February 2011

13. What does the investigator’s signature on the Notice of Award indicate? More … • I will notify ORSP Sponsored Programs Administration to initiate any required subcontracts or subcontract modifications • I will notify Accounting to initiate invoicing (when invoicing is based upon completion of tasks) AND … Updated February 2011

14. What does the investigator’s signature on the Notice of Award indicate? More … • I accept responsibility for fiscal management of the award which includes: • Reviewing monthly budget statements* and/or appropriate SAP Budget Control System reports* to determine that all charges and credits are appropriate; and • Spending funds within the approved project period, in accordance with the approved budget, and in accordance with OMB Circulars A-21, A-110, and any relevant agency guidelines *Note: Someone in every department has access to SAP. Also, investiga-tors can obtain access to grant account data using the SAP to Excel Project (STEP), which accesses data in SAP and displays it in an Excel spreadsheet. Updated February 2011

15. Does the university ever refuse to accept an award? • It is not likely that the university would refuse to accept an award, but it is possible • The university reserves the right to refuse an award if the terms and conditions are unacceptable and cannot be negotiated to meet the needs of both the university and the sponsor Updated February 2011

16. Account set-up • Account set-up is handled by Accounting • The process goes like this: • The ORSP sends a Notice of Funding memo, a Transmittal Sheet, a budget, and a copy of the award to Accounting • The investigator receives a copy of the Notice of Funding memo • Accounting sets up the account and sends a memo to the investigator (and a copy to the ORSP) indicating the account number, funding agency and amount Updated February 2011

17. Award management: Investigator responsibilities • Investigator responsibilities: • Conducting the project as described in the award • Providing technical liaison with the sponsor • Assembling and providing guidance to program personnel AND … Updated February 2011

18. Award management: More investigator responsibilities • Investigator responsibilities: • Expending funds in accordance with university and sponsor regulations • Providing Accounting with Activity Reports documenting the personnel time devoted to the project • Working with Accounting to document any cost sharing committed in the award AND … Updated February 2011

19. Award management: More investigator responsibilities • Investigator responsibilities: • Keeping a current equipment inventory list and preparing and submitting annual equipment reports if required • Tagging equipment to which title vests with the federal government • Preparing and submitting technical reports and invention reports and cooperating in the completion of other reports as required • Maintaining records in accordance with university and sponsor regulations Updated February 2011

20. Award management: ORSP responsibilities • ORSP responsibilities: • Ensuring university concurrence with federal regulations regarding non-fiscal compliance issues • Coordinating overall non-fiscal sponsored projects management • Serving as liaison between the university community and the external sponsor regarding non-fiscal grants management issues AND … Updated February 2011

21. Award management: More ORSP responsibilities • ORSP responsibilities: • Preparing subawards related to sponsored programs • Securing audit certifications from intended subrecipients • Processing actions that require sponsor prior approval or those that are allowed by expandedauthorities • Monitoring report submission Updated February 2011

22. Award management:Accounting responsibilities • Accounting responsibilities: • Establishing accounts for programs after fiscal review of award documentation • Assisting the investigator in fiscal post-award administration • Serving as the contact point with agencies for fiscal matters • Ensuring consistent application of federal policies related to fiscal matters AND … Updated February 2011

23. Award management:More Accounting responsibilities • Accounting responsibilities: • Submitting fiscal reports • Ensuring that all documented cost sharing is reported to the sponsor • Calculating and recovering all legitimate F&A costs • Closing out accounts Updated February 2011