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Office of Sponsored Projects For PIs: Managing your Sponsored Project September, 2013 PI HANDBOOK. SHARED RESPONSIBILITIES. Stewardship and compliance

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Pi handbook

Office of Sponsored ProjectsFor PIs:Managing your Sponsored ProjectSeptember, 2013

Pi handbook


Shared responsibilities

  • Stewardship and compliance

  • Effective management of public funds/taxpayer dollars to maximize research outcomes

  • Avoidance of serious cases of fraud, institutional mismanagement, or poor management of sponsor funds

    The ultimate responsibility for the management of the agency funds rests with the PI


The ultimate responsibility for the management of the agency funds rests with the PI

  • PI must be very familiar with the NOA and its terms and conditions

  • PI’s responsibility to meet/communicate with the Department/Research Grant Manager on a regular basis to inform Department Grant Manager of:

    • Personnel changes, change in scope

    • Supplies and equipment purchases

    • Subawards

    • No-cost extensions

  • Department/Research Grant Manager’s responsibility to:

    • Keep the PI informed of

      • Award Terms and Conditions

      • Expenses and remaining balances

      • Reporting requirements (including closeout)

      • Non-competing and competing renewal budgets and deadlines

    • Work with Sponsored Research Manager

  • OSP’s responsibility to serve as direct liaison with sponsor

Pi handbook

5 Principles of Financial Transactions Management

  • Consistency: Transactions must be handled in a consistent manner. Policies and procedures have been established to address similar types of transactions in a routine manner.

  • Timeliness: Transactions must be handled within a reasonable period of time consistent with time frames outlined for federal agencies, a private sponsor, and Dartmouth College.

  • Justification: There must be a reason for the transaction that supports the project’s goals, and adheres to guidelines outlined by federal agencies, a private sponsor, and Dartmouth College.

  • Documentation: Sufficient documentation to support the transaction must exist. The documentation must be retained, organized and complete enough to stand up to an audit.

  • Certification: Transactions must be approved and carry all the correct authorizing signatures.

Pi handbook

Allowable, Allocable & Reasonable Costs

  • Allowability: Expenses charged to a sponsored research award must meet the following criteria:

    • The costs must be reasonable

    • The costs must be given consistent treatment through application of generally accepted accounting principals appropriate to the circumstances

  • Allocability: The cost has been incurred solely to support or advance the work of a specific sponsored research award

  • Reasonableness: Must be able to withstand public scrutiny

  • Dartmouth policy takes precedence over sponsor requirements

  • Reference Office of Management & Budget (OMB) Circular A-21

Pi handbook

Advance Account/Pre-award Spending Requirements

  • PI has a good sense that the proposal/renewal will be funded

  • Department is responsible for covering the expenses if not funded by the sponsor

  • Allowable costs prior to funding

    • Payroll

    • Purchasing of equipment

  • PI/Department to complete routing form, budget, scope of work

    • True pre-award costs

    • PTAEO String in advance

  • Internal Advance Account Request form

    • Current Conflict of Interest Disclosure (COID)

    • Invention Agreement must be on file – one time submission

    • Current/updated CPHS and/or IACUC Approval Number(s)

    • Department Chair signature required

    • Department submits the signed form to OSP for their review and approval

      Not all sponsors allow Pre-award; OSP to check with sponsor

Pi handbook


  • PI/DGM/RGM review proposal/NOA for new/existing subawards

  • If not in budget/proposal – prior approval (agency/sponsor specific)

  • Setup: Submit request to OSP SRM (2 week turnaround under normal circumstances)

  • Request must include:

    • Statement of work (SOW)*

    • Budget (even if in proposal)*

    • Carryover funds need separate budget

      *Agreement cannot be prepared and issued if either, or both are not attached

  • PI in communication with subrecipient

  • Before PI signs off on an invoice, Dept/OSP ensures that:

    • There is a fully executed agreement on file with the OSP SRM

    • Invoices are submitted in accordance with Terms & Conditions of the subaward

    • There are no duplications of invoices or costs

    • Invoices include only expenses that are allowable, allocable and reasonable

    • Expenses follow the budget and are for actual costs incurred during the invoice period

    • Invoice includes a signed certification statement verifying financial data. The subrecipient PI is usually not this person

Subawards cont
Subawards cont.

  • The PI is responsible for monitoring the periodic progress of the SOW and all invoices

  • PI’s Review of Invoices for Payment:

    • Determine if expenses reported on each invoice align with the technical progress

    • PI’s signature attesting to: “In signing below, I approve payment of this invoice and attest that the charges appear reasonable and progress to date on this project is satisfactory and in keeping with the statement of work”

    • Only the DC PI can approve payment

  • Non-compliance by subrecipient with technical reporting requirements or DC PI dissatisfaction with the level of progress should be reported immediately to OSP SRM

  • Closeout

    • PI must verify by email to OSP SRM that all required reports have been submitted and are acceptable

    • Sub-recipient has up to 60 days to send final invoice. If invoice is sent after this we are not obligated to pay

    • If award is not under FDP then subrecipient needs prior approval to carryover funds

  • Payroll

    • PI’s responsibility to:

      • Make certain that payment of salary or wages to an individual charged to a given project is commensurate with the individual’s contribution to THAT project and per agreement/ESNAP Report

      • Notify DGM/RGM of any personnel changes

      • Notify OSP SRM if there is a 25% or more decrease in salary/effort for any key personnel. OSP SRM, in turn, must notify sponsor

    • Largest expense for most projects

    • PI cannot have 100% effort on sponsored projects- Exclusions: teaching, writing of grant proposals and other non-sponsored project administrative duties

    • NIH Salary cap – key personnel salary cannot exceed NIH salary cap

    • Salary distribution – notify DGM/RGM of any changes

    Wage transfers
    Wage Transfers

    LADC/Retroactive Labor charges (Wage Transfer form) to move actual salary charges to or from a sponsored research account

    • Need only to supply affected PTAEO strings

    • Reason/justification to be included in the comment section

    • Signatures required :

      • DGM or FC when $500 (excluding fringe) or less and correction made within 90 days following the GL Transferred Date found on IRA using the “Transaction Detail” report

      • PI (Dept Chair or equivalent if PI is unavailable) if over $500 (excluding fringe) and not yet over 90 days following the GL Transferred Date

      • PI (Dept Chair or equivalent if PI is unavailable) if correction not made within 90 days following the GL Transferred Date. The PDF version will be reviewed but may not be approved depending on the circumstances

      • When multiple accounts are involved each PI must sign

    • Importance of review, reconciliation and communication

    Labor verification certification
    Labor Verification/Certification

    • Labor Verifications-By Employee

      • Report is generated at the end of the fiscal year

      • Employee has to sign, if they no longer work at Dartmouth then Department Chair should sign

  • Required by Federal Regulations

  • Documents and supports salary and fringe benefit allocations - after the fact (including cost shared effort)

  • Are we following through on commitments (proposed & awarded)?

  • Compensation funding agreements
    Compensation Funding Agreements

    • Compensation Funding Agreement is required whenever a Clinic or Hospital Employee will be paid off of a Sponsored Research Account

    • Separate agreement required for each grant/project year

    • New agreement if any changes in time commitment or rate of compensation

    • Not included in Labor Verification Reports and do not appear in the Dartmouth HRMS payroll system

    Pi handbook

    Reallocation of Charges Involving Sponsored Funds

    Simple Reclassification Journals and Cost Transfers are used to move expenditures from one account to another.

    • Simple Reclassification Journals and Cost Transfers should not be used to manage sponsored research funds

    • Frequent journals and cost transfers may indicate lack of proper oversight

    • Budget must be managed to minimize frequency and retroactivity of journals and transfers

    • Expenses must be allowable, allocable, documented, justified and in some instances approved by OSP

    • Federal cost principals prohibit transferring expenses from overspent sponsored research awards to other sponsored research awards

    • Cost transfers that are over 90 days create an audit risk and are rarely approved

    • Late cost transfers will not be tolerated without a solid justification and will be highly scrutinized by the OSP Sponsored Research Manager

    • All PIs on the debit and the credit side need to sign the form as well as OSP

      Timely corrections avoid deficits and risk of audit

    Simple reclassification journal
    Simple Reclassification Journal

    • Does not require documentation of the expense (invoice copy, transactions report) nor the PI’s signature. If the correction is made within the month following the original Transferred Date the transaction may be of any dollar amount.

    • If the correction is made with 90 days of the original Transferred Date then to be considered a Simple Reclassification Journal it must be less than $500/transaction, or within the same PTAEO string or be moving the expense from a PTAEO string to a GL account.

    Cost transfers
    Cost Transfers

    • If the transaction is over $500 but not yet over 90 days from the GL Transferred Date the cost transfer or wage transfer form is completed by the department grant manager, signed by the PI and is sent to OSP with accompanying documentation for approval. Processing will be done by OSP or the appropriate finance center.

    • If the transaction is over 90 days it is highly unlikely that it will be approved. Extenuating circumstances that would allow such a transfer include receipt of an award with a retro start date.

    Pi handbook

    Most Common Unallowable Costs

    Advertising, Public Relations Goods/Services for Personal Use

    *Alcoholic Beverages *First Class Air Travel

    Alumni Activities Lobbying Costs

    Bad Debts

    Cell phones including monthly charges

    Internet charges *Memberships in Community

    Charitable Contributions Organizations, Country Clubs, Social Clubs

    *Entertainment Housing of Officers

    Selling and Marketing Cost

    Fines and Penalties Certain Legal Costs

    Losses on Sponsored Agreements (Overruns)

    Fund Raising & Investment Mgmt Costs

    Interest Expense for Operating Purposes

    *Postage (usually part of indirects)

    *Telephone Line Charges and basic monthly charges(usually part of indirects)

    *Copying (usually part of indirects)

    *Unallowable unless clearly itemized and justified

    in the proposal and approved by sponsor

    Pi handbook

    Travel, Entertainment & Meals

    • The PI and department are responsible for adhering to the College travel policy- see Dartmouth Travel Policy Guidelines (Procurement Office)

    • All parties are responsible for reviewing Notice of Award for travel terms & conditions

      • Foreign travel – US Carrier

      • Is prior approval required

      • Department scrutinizes charges

    • OSP reviews travel charges reported on the Travel Reimbursement Form when greater than $500 (after the fact)

    • Purchasing Cards (procards) cannot be used for meals (only for supplies and equipment up to $2,500) but can be used for take-out and if order is delivered

      Dartmouth Travel Policy takes precedence over sponsor requirements

    Pi handbook

    Examples of Entertainment & Meal Situations

    • After the meeting, the dean of the Medical School holds a reception for the scientists where beer, wine and hors d’oeuvres are served. The costs are considered entertainment and are disallowed on a federally sponsored research award.

    • The Physics Department receives a sponsored research award to hold a symposium for leading scientists to discuss a new particle. In its sponsored research application, the Department listed the activities it planned to conduct, and the sponsored research award specifically provided for a working dinner the night before. This would be allowable on the sponsored research award since there was such a specific provision.

    Pi handbook

    Capital Equipment

    • Capital equipment is tangible personal property having a useful life of one year or more and an acquisition cost of $5,000 or more per unit.

    • Capitalized fabricated equipment that is assembled or manufactured by the College using purchased materials, in-house machinery or tools and College labor. Fabricated equipment valued at $5,000 or more and having a useful life of one year or more shall be capitalized and recorded on the College’s equipment inventory.

      • Statement of Intent to Fabricate an Item form

      • Department must contact Procurement Services (Fixed Assets Coordinator) when equipment is purchased

    • No capital equipment may be purchased during the last 6 months of a sponsored project.

    • All equipment purchased using sponsored research funds is the property of Dartmouth College

    Items requiring approval by pi
    Items Requiring Approval by PI

    When involving a sponsored research account

    • Advance Account request form

    • Request for issuance of a sub-award (or authorized designee)

    • Sub-award invoices

    • Any invoice greater than $25,000

    • Consultant/Independent Contractor form

    • Wage transfers

    • Cost transfers

    • Request for no-cost extension

    • Request to carry over funds (when prior approval required by sponsor)

    • Transferring residual funds

    • Requesting re-budgeting of funds

    • Any other items requiring prior approval from sponsor

    Items requiring approval by osp
    Items Requiring Approval by OSP

    When involving a sponsored research account

    • Advance Account request form

    • Request for issuance of a sub award (or authorized designee)

    • Sub-award invoices

    • Consultant/independent contractor form regardless of amount and on invoices covered under an IC agreement if over $5,000

    • Requests for payment (RFP) over $5,000

    • Miscellaneous Income Payment Vouchers (MIPV) over $5,000

    • Any invoice $5,000 or more

    • Wage transfers

    • Cost transfers

    • Journal entries

    • Compensation Funding Agreements

    Changes requiring prior approval from sponsor
    Changes Requiring Prior Approval from Sponsor

    Sponsor specific:

    • Project relatedness

    • Change of scope/salary allocation

    • Absence or change in key personnel

    • Change in grantee organization

    • Indirect cost rate adjustments

    • Re-budgeting

    • Compensation

    • Equipment

    • Foreign travel

    • Use of unspent balances

    • Stipends and tuition remission

    • Sub-agreements

    • Pre-award costs

    • No-cost extension

    • Capital expenditures involving buildings, land

      Procedure for initiating changes requiring prior approval

    • Request should be in writing and made “in advance” of change

    • Signed by PI

    • Countersigned by OSP

    Pi handbook

    Cost Sharing

    • Cost sharing - project costs not paid for by the sponsor

    • May be required by the sponsor (mandatory) or voluntarily offered by the grantee (voluntary)

    • Could include anything committed to in the narrative of the budget that will support the project but is not paid for by the sponsor

    • Do not propose cost sharing if not required by the sponsor. Adding cost share to a proposal DOES NOT increase the probability of being awarded

    • Once proposed and/or on the routing form but not in the Notice of Award it is still a commitment and must be tracked accordingly

    • Signed off by fiscal office via routing form; GL account to be provided

    • Is a direct cost and is included in the research base for calculating federally approved F&A rate

    • Most common types: Salary/fringe, equipment, F&A

      Cost sharing is closely reviewed by auditors

    Pi handbook

    Federal Demonstration Partnership (FDP)

    FDP allows:

    • One time no-cost extension up to 12 months

      • PI submits request to OSP Sponsored Research Manager at least 30 days prior to current end date

      • Additional no-cost extensions on the same sponsored research award require prior approval from the sponsor

    • 90 Day pre-award spending

    • Rebudgeting within agency guidelines

    • Automatic carryover

      • Refer to agency for thresholds or Notice of Award for restrictions

        Expanded Authorities (EA) same terms and conditions as the Federal Demonstration Partnership

    Pi handbook

    Continuing the Project

    The PI has 3 options for extending a sponsored research project beyond the original date stipulated in the Notice of Award:

    • Non-Competing Continuation

    • Competing Continuation

    • No=Cost Extension (NCE)

      No-Cost Extension under FDP:

    • First NCE (up to 12 months)-grantee approved

    • Subsequent NCE requests must be in writing and must include the following:

      • Estimated balance in directs and indirects

      • Explanation on why the additional time is needed

      • Explanation on how remaining money will be spent

    • The internal DC NCE form must be used/submitted for all requests

    • Requests need to be sent to OSP 60 days in advance of end date

    • Requests to be countersigned and submitted to sponsor by OSP

    • NCE is giving a PI more time to accomplish project goals

    • NCE cannot be requested simply to use unspent funds

      *If the sponsor allows for an email to be sent, then draft letter should be sent to OSP Sponsored Research Manager. OSP will review and then forward to the Sponsor

    Pi handbook

    Continuing the Project cont.

    No-Cost Extension under non-FDP/non-Expanded Authorities

    • Review agency-specific guidelines

    • PI must prepare detailed letter for all requests

      Estimated balance in directs and indirects

      Explanation on why the additional time is needed

      Explanation on how remaining money will be spent

    • The signed internal DC NCE form must accompany the detailed letter

    • Requests need to be sent to OSP 60 days in advance of end date

    • Requests countersigned and submitted to sponsor by OSP

    • NCE is giving a PI more time to accomplish project goals

    • NCE cannot be requested simply to use unspent funds

    Pi transfer change of institution
    PI Transfer/Change of Institution

    • Contact appropriate institutional personnel

    • Contact DC Sponsored Research Manager immediately

      • Are grants to be transferred?

        • If yes:

          • Obtain sponsor approval

          • New institution/Personnel contact

          • Effective termination date

          • If equipment to be transferred refer to policies

          • Relinquishing statement

          • Fulfill all reporting requirements

        • If no:

          • Sponsor approval for PI replacement

          • Effective termination date

          • Change in scope?

    Transferring capital equipment
    Transferring Capital Equipment

    • Required Procedure for Transferring Capital Equipment:

      • Notify Fixed Assets Coordinator in Procurement Services to remove Equipment Item from Inventory List

      • A Letter formally requesting the transfer of capital equipment to another institution and must include:

        • Current market value

        • Description of equipment (Name, Serial number, Dartmouth Asset Tag number)

        • Signatures of PI, Department Chair, Director of Office of Sponsored Projects

        • Carbon Copy to Fixed Assets Coordinator

        • Fully signed original must be sent OSP to be kept in the sponsored research account file

    Pi handbook


    • PI must prepare and submit timely reports where required:




      Federal-Mandatory submission of published works to PubMed Central

    • Work with Department Administrator/OSP to ensure timely closeout process

    • Late reporting may result in withheld funding for the PI and/or Dartmouth College

    Pi handbook

    Closeout cont.


    • Dartmouth retains all original data

    • PIs are allowed to keep ‘copies’ of research notebooks when leaving Dartmouth but the original must stay with the department.

    • How long should the records be saved?

      • OMB Circular A-110 states (for federal) “generally” 3 years from the due date of the final report on the sponsored research award

      • Sponsor specific