Managing an Award

Funding agencies award grants to Lewis & Clark on behalf of a Principal Investigator (PI) or Project Director (PD). If award documents are sent directly to a PI, the PI should notify SPARC immediately. SPARC will coordinate formal review of the award terms and conditions, assist with negotiations, and obtain required signatures. Only an authorized institutional representative (not a PI) may sign an agreement on behalf of Lewis & Clark. 

PIs should review the award agreement to confirm that the budget, project period, scope of work and any deliverables are as expected. PIs may not spend any grant funds until an award agreement is fully executed and the project period has begun; any request for pre-award spending must be reviewed internally and approved by the funder in writing. 

SPARC will work with other offices on campus to facilitate publicity and account set-up, and schedule a project initiation meeting with the PI to answer questions, review requirements, and help get the project off to a good start. 

Please note that this process does not apply to awards that will not be administered by Lewis & Clark (e.g., awards paid directly to an individual).

The Principal Investigator (PI) is responsible for all aspects of the sponsored project, including administrative, programmatic and financial oversight. All work on any sponsored project must adhere to institutional policies, the terms and conditions of the award, and applicable regulations; the most stringent rules take precedence. Lewis & Clark has established processes to support the PI throughout the life of an award, and SPARC is here to help. 

• Compliance: In addition to complying with the terms of the award, it is the responsibility of the PI to meet any applicable requirements and follow all policies and guidelines. 
• Project Management: It is the responsibility of the PI to advance the project goals and objectives as outlined in the grant proposal. 
• Employee Management: If your project includes funds to hire a position, be aware that state and federal employment laws and staff policies and procedures apply. 
• Expenditure Management: The financial management of grant funds is the PI’s responsibility. The PI may authorize another individual to sign-off on expenses, but may not delegate their responsibility for financial management to another individual. 
• Subaward Management: The PI pays a critical role in monitoring the performance and expenses of any subrecipient. 
• Reporting: The PI is responsible for the timely submission of all narrative and programmatic reports required by the sponsor. Financial reports are prepared by SPARC  and Business Office, and may require certification by an authorized institutional official; a financial report prepared by a PI is not an official institutional report of expenditures. 

The PI should keep in contact with the Program Officer about the project itself, but communications relative to financial management should be coordinated by SPARC. This includes, but is not limited to, budget revisions and any modifications that may require formal approval. 

If pre-award spending is allowed by the sponsor it must be approved by both the institution and the sponsor in advance. Contact SPARC for assistance.

The PI must make sure that all charges to the project are allowable, reasonable, allocable, necessary, and consistent with institutional practices. A project’s expenses should correspond to the approved budget, and deviations may require prior approval from the sponsor.  Contact SPARC with any questions before you spend.

Mixing funds between project accounts is never allowed. If a charge is to be split between projects, it must be based on proportional benefit or another reasonable basis (§200.405) and documented as such. All vendor discounts, credit memos, rebates and other cost adjustments must be applied to the appropriate grant account.

The definitions provided below are best practice for all sponsored projects, and are required for federal grants (see Uniform Guidance 2 CFR 200 Subpart E Cost Principles for full details).

Allowability - Costs must be necessary and reasonable for the performance of the award and adequately documented.

Reasonable - A cost is reasonable if it does not exceed that which would be incurred by a prudent person under similar circumstances. 

Allocable - A cost can be allocated to a project only if the goods or services are clearly related to or benefit the project.

Consistent - Costs must always be treated in the same manner under like circumstances whether institutional or external funds, and whether direct or indirect costs.

Unallowable Costs: Some costs are never allowed and some require prior sponsor approval. Below is a partial list of costs that are generally unallowable on externally funded projects. Contact SPARC for confirmation.

•     Alcoholic Beverages
•     Alumni Activities
•     Commencement and Convocation Costs
•     Donations and Contributions
•     Entertainment Costs
•     Fines and Penalties (failure to comply with federal, state or local laws & regulations)
•     Fundraising and Investment Costs
•     Goods or services for personal use of employees
•     Housing and personal living expenses
•     Lobbying
•     Meals, other than budgeted travel costs
•     Student Activities, unless specifically provided for in the sponsored agreement
•     Travel: Upgrades for comfort or convenience. Some carriers are disallowed under the Fly America Act

It is the PI’s responsibility to review grant transactions in a timely manner and ensure that project spending does not exceed the approved budget. SPARC prepares budget status reports to aid in this process and provides support to help PIs understand the project’s finances. The PI should notify SPARC immediately if an error is suspected. If the grant is federal, mis-allocated charges must be corrected following the Cost Transfer Guidelines.

Cost sharing is when the institution provides “matching” funds or agrees to support part of the cost of an externally sponsored project; this includes waiving full indirect cost recovery. Cost share must be documented and tracked the same as all other project expenses. 

Income generated by sponsored projects must be accounted for in accordance with the applicable cost principles and the terms and conditions of the award. PIs must work closely with SPARC to ensure program income is managed appropriately. Additional information is provided in the Guidelines on Program Income for Federal Grants.

PIs must report any invention that results from external support. SPARC will help the PI coordinate disclosure to the sponsor as required. 

PIs should contact SPARC if any changes to the project’s scope of work or budget are planned to determine if institutional or sponsor approval is required prior to making any changes. If prior approval is required, SPARC will help facilitate this process. 

No-Cost Extension (NCE): Many sponsors allow an extension of the project if more time is required to complete the original scope of work and project funds are available to continue. The fact that funds remain at the end of the project period is not, in itself, sufficient justification for an extension. Extensions must be requested in advance of the project period expiration date and in accordance with sponsor guidelines.

Mandatory Prior Approvals: The specific events requiring prior approval are dependent upon the applicable guidelines and award agreement. Examples of common circumstances that require prior approval are below:

• Significant Change of Effort by, or Absence of, PI: Under the Uniform Guidance (200.308) prior sponsor approval must be obtained from the federal agency if a PI will be “disengaged” from the project for more than three months, or if there is a 25 percent reduction in the time the PI devotes to the project.
• Rebudgeting: Some sponsors do not allow changes to the approved proposal budget without permission, but other sponsors allow for rebudgeting up to some percentage of the total award.  
• Changes to restricted budget categories: Restricted categories include, but are not limited to equipment, participant support, and international travel. 

Closing an award is a critical piece in the life cycle of a grant. Grants are considered closed when all of the work has been performed to the sponsor’s satisfaction or upon the termination date specified in the award. The PI and SPARC should begin the closeout process three months prior to the award’s expiration date to ensure project expenses are final, all terms and conditions of the award have been met, and all reports have been submitted. If there are unused funds at the end of a project, the sponsor’s policy will determine whether those funds need to be returned or not.