AWARD MANAGEMENT . . .

• Investigator-initiated project
• Investigator defines details and retains scientific freedom
• No substantial involvement between sponsor and recipient during project performance
• Most flexible award; allows the investigator control over the project

• Substantial involvement in the project by both sponsor and recipient

• Project conceived by sponsor
• Used to acquire product or services for the direct benefit of or use by sponsor
• Generally requires strict adherence to budget
• Sponsor exercises direction or control
      

Award Processing

When awards are received, the following steps are normally completed within two business days:   

• OSP reviews award terms and conditions to ensure they are appropriate for the College (this can take a while if the award document requires negotiation)
  
• OSP reviews the amount of effort proposed and awarded to ensure it is in compliance with current policy.
     
• OSP Information Systems (OSP-IS) assigns a 5-account number, enters the award in the Financial Accounting System (FAS), and sets up the indirect cost allocation program.
     
• OSP-IS then transmits Notice of Award to departmental Grant Managers, OSP Grant Managers, and the PI.
     
• Department Grant Manager/Administrator or the PI is required to prepare and submit an itemized budget to OSP-IS within two business days of receiving a Notice of Award.
      
• OSP prepares and transmits reports of new awards to various offices, including Public Affairs, the Provost’s office, and the dean’s office.

       

Pre-Award Spending
    

Prior to Notice of Award:

A pre-award account number may be requested by the PI so that work may begin.  All requests must be approved by the department head and then forwarded to an OSP Research Manager for review and final approval.  If authorized by a federal sponsor and conditions warrant, the PI may also request "pre-award spending" of up to 90 days prior to the start date.

It is important to understand that any expenses incurred prior to the receipt of an actual award will become the responsibility of the incurring academic department in the event the expected award does not materialize.

The forms (Pre-award Spending) for requesting advance accounts and/or pre-award costs are on the OSP web site: http://www.dartmouth.edu/~osp/resources/otherforms.html
     

Post-Award Requirements

The PI, as Project Manager, has three primary responsibilities (described in greater detail in The Principal Investigator's Quick Guide for Sponsored Activities):

• Managing the resources of the project.
• Planning and controlling the work of the project.
• Communicating with individuals and groups about the project.

Each award received by the Trustees of Dartmouth College on behalf of Dartmouth faculty can have a variety of reporting requirements with which the College must comply during the life (project period) of the award and beyond.  OSP transmits copies of all awards to both the PI and Department Grant Manager/OSP Research Managers to make them aware of the terms and conditions of awards, including which reports will be due and report deadlines.

Upon receipt of an award transmittal, investigators must become familiar with these award terms and conditions.  Any questions about what will be required should be addressed immediately by contacting OSP and/or the Department Grant Manager/OSP Research Managers.  Below are the typical characteristics that apply to the various types of reporting requirements:

Programmatic Reporting and/or Other Deliverables

Financial Reporting

Subaward Management:

The PI is responsible for monitoring periodic progress reports and invoices for compliance with the terms of the contract.  As a result, the PI is expected to:

• maintain good communication with the subrecipient PI;
• review subrecipient institution's reports and incorporate them into the project's progress reports;
• review all invoices to ensure that expenses are appropriate and aligned with technical progress.  Only the PI can approve payment of subrecipient invoices.

Non-compliance with technical reporting requirements or dissatisfaction with level of subrecipient progress should be reported immediately to OSP.  If there are issues with costs and/or work progress, the PI should not sign off on the invoice in question. A revised invoice will be requested from subrecipient or the invoice will be suspended until issues are resolved.

Other Reporting

Please submit an Invention Disclosure form to TTO at least 90 days prior to sharing information in presentations or publications related to any possible invention, in order to secure intellectual property rights.
        

PI Closeout Responsibilities

The following is a checklist of the PI's responsibilities at the time of closeout.  Items may vary by department; please check with the department administrator or the research grant manager assigned to your department.

90 days before budget/project end date:

• Review report schedule and reporting requirements.
• Ensure subaward recipients have met goals.
• If a no-cost extension will be required, notify the department and send the request to OSP via e-mail.
• Determine if cost-sharing requirements have been met.

At budget/project end date:

• Review all charges, including salary and benefits.

Within 60 days after budget/project end date:

• Ensure subaward recipients have met goals.
• Notify OSP Research Manager if subaward is subject to de-obligation.
• Sign final labor verification by grant account form.
• Prepare/submit timely final reports: technical, invention, property, contractor’s release, subcontract, Contractor’s Assignment of Refund, Rebates, Credits, and other amounts (reporting requirements are sponsor-specific).

All financial reports are prepared and submitted by the Cash Management Office of OSP.

Within 90 days after budget/project end date:

• Contact OSP Research Manager via e-mail when project is complete and ready for closeout.
• If Dartmouth College will keep the residual funds, send the relevant 2-account number to OSP via e-mail.

Provide OSP with copies of all final reports

ULTIMATELY, THE PI IS RESPONSIBLE FOR ENSURING THAT ALL REQUIREMENTS HAVE BEEN MET.
      

The Regulatory Environment for Federal Awards

Depending on the type of federal award and the agency providing it, there can be myriad differences in the requirements with which Dartmouth must comply.  This section will not try to cover all of the possible scenarios but will point out the key compliance elements that are consistently applied to most Dartmouth business transactions with the federal government.
     

Relevant Regulations Affecting Dartmouth
     

Office of Management & Budget (OMB)
Circular A-21 - Cost Principles
(Applicability:  Grants, Contracts, Cooperative Agreements)
http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html#f;
http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html#j

WHAT IT COVERS...

• Allowable:  An "allowable" cost is one that is eligible for reimbursement by the federal government.  Generally it is not the type of cost that determines allowability; it is the purpose and circumstance of the expenditure.
• Allocable:  The cost, or a group of costs, must be assignable to the project in a reasonable and realistic proportion that directly benefits a sponsored research award.
• Reasonable:  The cost must be able to withstand public scrutiny, i.e. objective individuals not affiliated with the institution would agree that a cost is appropriate on a sponsored research award.

It is important to refer to updates guidelines on allowable costs.
      
    

OMB Circular A-110 - Administrative Requirements
(Applicability: Grants, Cooperative Agreements)
http://www.whitehouse.gov/omb/circulars/a110/a110.html

WHAT IT COVERS...

• Definitions, standard forms, etc.
• Standards for financial systems, written policies, cash management, cost-sharing or matching, program income, more forms, etc.
• Required approvals, revision of budget/program plans, expanded authorities (e.g., to issue no-cost extensions, carry forward unobligated balances from year to year, etc.)
• Audit requirements, allowability of costs, period of performance, etc.
• Property standards, intangible property, intellectual property, etc.
• Incorporation of Freedom of Information Act (FOIA)
• Procurement standards, codes of conduct, competition, cost and price analysis, costing of proposals, etc.
• Contract provisions to be included in subawards
• Reporting requirements, record retention, etc.
• Termination, award close out, etc.
      

OMB Circular A-133 - Audits
(Applicability: Grants, Contracts, Cooperative Agreements)
http://www.whitehouse.gov/omb/circulars/a133/a133.html

WHAT IT COVERS...

• Specifies 14 separate compliance requirements, including allowable costs, activities, cash management, equipment, level of effort devoted, programmatic, financial and other reporting, sub-recipient monitoring, etc.
• Prescribes method for determining "Major Programs"
• Specifies sub-recipient monitoring and audit report requirements
      

Federal Acquisition Regulations (FAR)
(Applicability: Contracts Only)
http://www.arnet.gov/far/

WHAT IT COVERS...

• Used on contracts (procurements), rather than on grants, which provide financial assistance
• Part of the Code of Federal Regulations (CFR)
• Incorporates OMB Circular A-21 above for purposes of determining allowable costs
       

Agency Implementing & Supplementing Guidelines

• Examples include NSF Grant Policy Manual, NIH Grant Policy Statement, NASA Grant and Cooperative Agreement Handbook, etc.

      

As a Dartmouth Investigator, what do I need to know about all of these Federal regulations?
    

You should know that . . .

• If you submit a proposal to the federal government, any representations made are subject to a possible review and/or audit before or after receiving an award, even if you don't receive an award
     
• Awards are made to Dartmouth rather than to individual PIs because sponsors desire to legally bind the organization
     
• Evaluation of an allowable expense is followed by a determination of this expense as both allocable and reasonable (i.e., will an auditor feel the same way as you do about it in a year or two?).
     
• You must create a realistic budget with sufficient justification in relation to the scope of your project.
    
• Costs, such as secretarial/administrative support, membership dues, subscriptions, office supplies, postage, telephone line charges and the like are not allowable as direct charges to federal awards and should not be included in proposal budgets.
     
• Proposals involving the use of either human subjects or animals require the approval of your protocol by the Dartmouth IRB or IACUC prior to award receipt and commencement of a study
     
• Proposals to the National Institutes of Health (NIH) that include use of human subjects require a letter certifying that you, as well as all key personnel listed on the project, have successfully completed an educational program in the use of human subjects
      
• The level of effort you are devoting to a project must be consistent with what was proposed and approved in your award (this becomes more important if you expect to devote LESS effort than was indicated in your proposal)
     
• Should you decide to rebudget compensation associated with your effort, this becomes a cost-sharing issue and requires prior approval.
     
• Should you increase your effort and wish to be paid for the additional effort, this becomes a rebudget issue and requires prior approval.
    
• If you travel to a foreign country, you must use a U.S. flag carrier for the cost to be allowable on federal awards; otherwise, the cost of the air portion of the trip may become a personal liability.  When making travel arrangements through the College Travel Office, notify the agent that the travel is associated with a sponsored project.
      
• The title to equipment purchased on federal grants vests in the College, but equipment purchased on federal contracts remains the property of the government unless subsequently transferred to Dartmouth upon request
       
• Some grants are awarded with expanded authority, so that certain types of actions (e.g., pre-award costs, no-cost extensions, rebudgeting, etc.) can be approved internally by the College, while other actions (e.g., change of PI, change in scope of work, etc.) may need sponsor’s prior approval. 

PLEASE REFER TO THE TERMS AND CONDITIONS OF EACH AWARD FOR SPECIFIC INFORMATION.

• The information you need to disclose to an outsider regarding the results of your project is covered by the Freedom of Information Act – have anyone requesting such information refer to the Freedom of Information Act office at the sponsor that provided the award
     
• There will be reports and/or some other deliverable required under each award, you should know what they are and when they will become due.

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