Roles and Responsibilities
Spending the Money
Your Grant Fund Number
How to Spend the Money Well
Be sure we don't pass on federal funding to "excluded parties"
How to Spend the Money – Literally
Personnel - Effort Certification Procedures
Equipment and Supplies - Read this before you spend more than $3K with one vendor
Travel - Be sure to stay in compliance with the Fly America Act
Changes After the Award
Rebudgeting and Prior Approval
No Cost Extensions
Grant Close-Out Procedures
All of the above guidance is rooted in an effort to ensure strong stewardship of federal funding. Additional Research Compliance Information is available.
I’ve Been Awarded a Grant! Now What?
Congratulations on being awarded a grant from an external funder! The grant that you have received is a testament to your hard work, fine scholarship and innovative ideas. We are proud of you and are pleased to have the opportunity to help you with the (sometimes messy) process of managing an external grant.
There are three main players in the administration of a grant:
- The Principal Investigator (PI) or Project Director (PD), that’s you
- The Tax and Compliance Manager (Sarah Hintz, x7844), your primary contact in the Finance Office
- The Director of Faculty Research Support (Tess Powers, x6318), your primary contact for general questions and concerns related to successfully managing your grant
Sometimes the faculty PI receives assistance in tracking the grant expenditures from his or her department’s staff person. In these cases, the staff person is a critical fourth player in the process of managing the grant well.
In the month or so after a grant has been awarded, it’s important that these individuals sit down together in a “post-award meeting” to discuss the grant award, review the applicable policies and procedures, and ensure that everyone has access to the various resources that are available to ensure proper management of the grant. It is important to remember that your grant is a legal, binding contract with the federal agency or foundation. Following grant guidelines is an important way to maintain your own – and CC’s – relationships with funding agencies. As competition for academic grants becomes increasingly intense, our compliance with funder requirements will come under ever-closer scrutiny. Your efforts to follow funder guidelines will help ensure that you – and CC – can continue to receive outside funding in the future.
Roles and Responsibilities
The Director of Faculty Research Support supports the post-award process by serving as a resource on budgeting matters, compliance requirements, and communications internally and with the funder.
Finance and Administration will assist with the overall financial administration of the grant, serving as a resource on processing payment requests, purchase orders, invoicing and drawdowns, following standard accounting practices and adhering to college procedures and federal regulations. The Tax and Compliance Manager will provide inception-to-date spreadsheets for the grant, generally twice a year and more often if requested, and also assist the PI and Director of Faculty Research Support with compliance and other grant-related procedures or questions. Finance and Administration will retain grant documents for seven years following the expiration of the grant.
The Principle Investigator or Project Director is responsible for all aspects of conducting the project, including:
- submitting all original award documentation to the Director of Faculty Research Support
- submitting any funds received to the Director of Faculty Research Support
- ensuring that the project stays within the scope and objectives of the original proposal, and working with the Director of Faculty Research Support in the event of any significant deviations from the awarded budget or other terms of the grant
- limiting expenditures to the total dollar amount awarded through regular monitoring in Self-Service Banner
- submitting all required reports on time and providing the Director of Faculty Research Support with copies of all narrative reports and grant-related correspondence
- complying with all terms and conditions of the funder and all applicable college policies and procedures
- certifying Effort Reports for all federal grants
- setting up summer student researchers as Student Fellowships (with stipends) and setting up academic year students as hourly employees to ensure that we have documented your authorization of payments for research assistants prior to the processing of payments;
- keeping records for at least seven years from the date of the final expenditure report, unless an audit, claim or litigation has begun.
Please review this detailed list of roles and responsibilities for more information.
Spending the Money
While the following guidance applies to all federal grants, it also applies to most other funders as well.
Your Grant Fund Number
Now that the grant has been formally awarded, the Director of Faculty Research Support will work with the Tax and Compliance Manager to establish a new fund number. Every new grant requires its own fund number, a six-digit number (beginning with #243XXX in the case of federal grants), followed by the PI’s department “org.”
All financial expenditures and other activity are tracked using this fund number. For tracking purposes, we recommend including the six-digit fund number in all email correspondence on your grant.
How to Spend the Money Well
Follow your approved budget. The budget that was submitted with your proposal has been approved by the funder, and therefore those costs have been approved. If you have any questions about whether a possible cost is allowable under the grant, please contact the Director of Faculty Research Support or the Tax and Compliance Manager prior to expending grant funds. In general, any costs need to meet the Basic Considerations outlined in the Office of Management and Budget’s Uniform Guidance; specifically they need to be reasonable, allocable, consistent and allowable. Guidance is also provided on specific kinds of items, such as alcohol, which is always unallowable. Under special circumstances, we may need to seek the funder’s prior approval before initiating certain expenditures. This matrix outlines when prior approval is required based on 11 different federal funders.
Ensure we work with reputable businesses. The government does not want to see federal funding going to businesses or people who have mismanaged federal funding in the past. In keeping with federal regulations (Section 200.213 of the Uniform Guidance), we need to do our “due diligence” with every major vendor to ensure that they are not an “excluded party” – that is, they are not suspended, debarred or otherwise excluded from conducting business with the federal government. Please review the College’s Statement on Debarment and Exclusions for guidance.
Closely monitor any subawardees. If any of the grant work is being conducted by a collaborator (through funding in Colorado College’s budget), we would have included your collaborator as a subrecipient on the grant. In keeping with federal regulations (Section 200.330 of the Uniform Guidance), subawards require a high level of monitoring, as summarized in the College’s Subaward Monitoring procedures.
Engage in no lobbying using federal funding. In keeping with federal regulations (Section 200.450 of the Uniform Guidance), for all proposals exceeding $100,000 the College’s Authorized Representative will sign a certification that no federal funds have been paid or will be paid to “any person for influencing or attempting to influence” any individual in connection with the federal grant. If any non-federal funds have been paid or will be paid to any person, the College’s Authorized Representative certifies he or she will complete and submit Standard Form LLL, the Disclosure of Lobbying Activities form.
How to Spend the Money - Literally
Grant purchasing follows the same Procurement and Purchasing policy used for all other college purchases. Purchasing Card (P-card) purchases follow the same policies and procedures as any other purchase made with a P-card. If you do not already have a college-issued P-card, you may wish to be issued a Declining Balance P-Card to be used only for grant purchases. However, if you use a P-card, you or your department must keep all the original receipts available in case the Finance and Administration Office needs them for an audit. Be sure to include the grant fund number on all paperwork. Personal credit cards should be used only as a last resort and never for purchases over $3,000.
In addition, the federal government imposes a set of standards for the acquisition of supplies, equipment and real property purchased with federal funds. New guidelines in the Uniform Guidance, which became effective Dec. 26, 2014, require that the College implement new procurement standards by July 1, 2018 (200.110a). The College’s draft guidelines reflect Uniform Guidance for purchases made with Federal funds, particularly regarding purchases over $3,000, and are in addition to the College’s standard procurement policy and should be followed for any purchase made with federal funds. The College has elected to utilize the grace period established in the Uniform Guidance and officially defer full implementation of these guidelines until July 1, 2018.
Below we elaborate on Colorado College’s procedures related to particular budget items often associated with federal research grants. They are divided into the following overarching categories: Personnel, Equipment, and Travel.
Faculty salary. Some funders support one to two months of faculty summer salary. Faculty are paid based on their previous academic year salary. Faculty will need to send a salary authorization (see template below) to Karen Ferguson, the Faculty Employment Specialist in the Dean’s Office, which will allow the Director of Faculty Research Support to prepare the Faculty Grant Salary Payment Form for signatures and submission to Payroll.
PI’s Authorization to Release Salary Information to the Director of Faculty Research Support during the grant period:
I, ______________, hereby give my permission to Tess to confirm updated salary information with Karen Obrzut in the Dean’s Office as part of the grant preparation and management process. If funded, this authorization extends during the length of the grant period, which ends on ___________________ . This authorization also extends through the end of the grant period in the event of a no-cost-extension to the grant.
Based on your plans to work on grant activity, the Director of Faculty Research Support will prepare Effort Certification documentation for your review and signature. More information on Effort Certification Procedures is available.
Academic year salary, if approved by the Dean prior to grant submission, follows similar procedures as outlined for summer salary, and involves replacing CC salary with grant-paid salary.
Summer student stipends. Faculty who will be mentoring undergraduate researchers should complete the Student Researcher (Non-Compensatory) Stipend Form. Summer Research Fellowships are awarded to our students to provide them the opportunity to learn research methods and procedures that will benefit them as they continue in their educational pursuits. Research Fellowships are awarded as a one-time payment at the beginning of the research term and are paid out through the student accounts as a student refund each Friday. Please encourage your students to complete direct deposit paperwork in the Finance Office to expedite the payment of their Research Fellowship. Research Fellowships are reported on IRS Form 1098-T and may or may not be taxable dependent on the student's individual situation. Please refer the students to IRS Publication 970 for more information.
Academic year students and other hourly employees. Faculty should set up academic year student workers as hourly employees by completing the online Student Employment Referral Form. The online Student Employment Referral Form must be completed by the faculty member and the student must turn in the completed employment paperwork to the Student Employment office within the Office of Financial Aid before a student will be paid. Hourly employees and academic year student workers do not need to complete T&E certification, as their time is certified via through the College’s electronic timesheet process.
Equipment and Supplies
For purchases between $3,000 and $24,999, two detailed cost estimates must be documented prior to purchase. For purchases of $25,000 to $150,000, three detailed cost estimates, with specifications clearly delineated, must be documented prior to purchase. See also the “Specific Requirements Based on Purchase Amount” and the “Capital Equipment” section of the draft Procurement Guidelines for Purchases Made with Federal Funds.
A Vendor Selection Form is required in the following circumstances:
- A sole source purchase
- A minimum number of cost estimates and quotations are not obtained
- Lowest cost bid is not selected
Foreign travel using federal funds must have prior approval from the funder, and airfare must be purchased on a “U.S. flag” airline in order to be in compliance with the Fly America Act. PIs on federal grants should confirm that their travel will be on a U.S. flag airline by referencing these guidelines. Colorado College’s meal guidelines also apply.
The PI or PD is responsible for monitoring all expenses charged to the grant. See instructions on how to access information in Self-Service Banner (SSB). For further information or assistance in accessing your grant information please contact the Tax and Compliance Manager.
In order to avoid cost overruns and to identify any misallocations, grant budgets should be reviewed regularly in SSB -- approximately once a month. Mistakes can happen, but expenses posted to a grant in error can be moved easily if the error is caught within a short period. During your review, be sure that all invoices and payroll charges that have been submitted are charged to the grant properly.
Errors found are often addressed through cost transfers or “journal entries.” Because all cost transfers are considered audit “red flags,” please review this guidance on cost transfers in federal grants.
In the event that a grant is overspent, the PI may be responsible for reimbursing those expenditures. If it is determined that the PI is responsible, overspending can be reimbursed to the College by charging your personal research account, through a payroll deduction or by making a payment by cash or check back to the College.
If the grant is eligible for Indirect Costs (formally known as Finance & Administration Costs), the Tax and Compliance Manager will bill the allowable indirect costs to the funding agency at the end of each calendar quarter. More on indirect costs is available.
Changes After the Award
While we do our best to anticipate the future in grant proposals, sometimes in the course of executing a grant, it becomes clear that changes are necessary. These can include changes in:
- the scope of work
- the role of the PI (or an addition of a Co-PI)
- the length of the grant period
- methods or procedures (significant in nature)
Other budget-related changes may also be necessary, such as:
- the addition of a subaward
- pre-award costs in excess of 90 days
- reallocation of money among budget line items (“rebudgeting”)
- rebudgeting of participant support costs
Depending on the funder and the nature of the change, these changes may require internal or external approval. It is important to note that, in either case, a written request must be reviewed and approved. Please discuss whether internal or external approval is needed with the Director of Faculty Research Support as soon as you determine that such changes would benefit the project.
Requesting a Reallocation of Grant Funds, aka “Rebudgeting”
The budget is the financial expression of the project or program as approved during the award process. Once a grant has been awarded, the PI is expected to follow the approved budget in overseeing the spending of the grant.
However, after a grant has been awarded, the PI may determine that the approved budget allocations are not consistent with actual project needs. She or he may request a reallocation of funds from one spending category, or account code, to another account code category that better reflects the project requirements. This process is called rebudgeting or budget revision.
A PI's ability to rebudget varies depending on the funder. PIs should discuss whether they are able to rebudget with the Director of Faculty Research Support and the Tax and Compliance Manager at the post-award meeting.
Many federal agencies have transferred the authority to approve such changes to awardee institutions. Colorado College’s implementation of these authorities is described below.
Colorado College’s Prior Approval Process
Funding agencies have delegated increasingly expanded authority to institutions to approve certain administrative actions. These agencies require grantees to assure that adequate institutional reviews and approvals are in place for decisions that affect the management of federally supported projects. All approvals must be documented. To provide these assurances, Colorado College has established the following Prior Approval Process.
The Tax and Compliance Manager administers all external funding that comes to Colorado College according to Uniform Guidance, applicable federal regulations, Colorado College policies, and the sponsor's particular grant provisions and conditions. The College’s Authorized Institutional Officials include the Dean and the Associate Dean of the Faculty, who are authorized to sign all research grant applications on behalf of the college.
Principal Investigators or Project Directors are authorized to make charges to their grant that agree with the approved budget. If the cumulative amount of such transfers exceeds or is expected to exceed 10 percent of the total budget as last approved by the federal agency, the PI will need to obtain approval from the College prior to incurring charges.
To obtain approval for administrative changes (such as a rebudget of more than 10 percent of the budget), the PI should work with the Director of Faculty Research Support to prepare a Prior Approval Form so that appropriate signatures can be obtained.
If the granting agency has authorized the College to approve such changes, the Director of Faculty Research Support will recommend approval of the request if the following four conditions are met. The changes are:
- are allowable under Uniform Guidance,
- are consistent with the terms and conditions of the award and with sponsor and Colorado College policies,
- do not constitute a change in project scope,
- are reasonable, necessary and allocable to the project. If the College does not have the authority to approve the request, the Director of Faculty Research Support will forward the request to the funding agency. The signed Prior Approval Form is retained in the grant file for three years following submission of the final financial report.
Requesting a No-Cost-Extension
Often PIs find that spending grant funding well and carefully takes more time than originally anticipated. As the project end date approaches, the PI should discuss with the Director of Faculty Research Support whether it would be prudent to extend the grant period in order to finish the project, in the event that funding remains. Most funders will allow a no-cost extension (NCE) provided that we justify how the additional time will allow us to complete the project. (NCEs are not allowed for the sole purpose of spending the remaining funds.)
NCE requests to the National Science Foundation: The first NCE to a grant from the National Science Foundation is automatic and must be submitted by the Director of Faculty Research Support at least 10 days prior to the expiration of the grant period. The second NCE (for a second additional year) must receive NSF approval and must be submitted by the Director of Faculty Research Support at least 45 days prior to the expiration of the grant period.
Grant Close-Out Procedures
We aim to close out a grant within the three months following the grant’s expiration date.
A grant is considered closed once all of the requirements for final reporting and all deliverables have been fulfilled and accepted by the sponsor. This includes, but is not necessarily limited to, the final technical report from the PI and the final financial report from the Business Office.
To close out the technical side of a sponsored project, the PI must send the sponsor the final technical report, with a digital copy to the Director of Faculty Research Support so that it can be added to the paper and digital files.
To close out the financial side of a sponsored project, the Tax and Compliance Manager will review the fund for any errors. If any unallowable expenses are discovered during this process, the charges must be transferred to an appropriate fund. Cost Sharing and Effort Reports will be verified and any deficits will need to be cleared. Additionally, any open encumbrances must be closed.
After all internal and external requirements have been met, the Tax and Compliance Manager:
- Closes the fund number.
- Receives any remaining documentation from the Director of Faculty Research Support.
- Marks the paper file as closed and stores it with closed files to be retained for at least seven years from the date of the final financial report.
- Reviews, with the Director of Faculty Research Support, the electronic file to ensure all electronic retention of all documents.
- Ensures that the grant closure date is marked on digital folders and internal tracking documents.
The Director of Faculty Research Support will send confirmation to the PI when a grant has been closed.
Research Compliance Information
There are a number of federal regulations that affect how the College manages research activity and funding. For any given project, only a few may apply. More information is available.
Many thanks to Carleton College, Middlebury College, Smith College and Wesleyan College for substantial use of their post-award procedures language.