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Office of Research and Projects
Office of Research and Projects
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Post-Award Compliance

As you develop grant application cover sheets and budgets, the following information is often requested. The Graduate School's Office of Research and Projects (ORP) staff

NO COST TIME EXTENSION

Many funding agencies allow a one time extension of the expiration date of the award up to one year. A request for the extension should be submitted in writing to the Director of Research & Projects noting supporting reasons for the extension and revised expiration date. This one time extension may not be used if the following conditions exist:
a. To use unobligated balances remaining at the end of the grant period;
b. The terms and conditions of the award prohibit the extension;
c. The extension requires additional funds;
d. Extension involves any changes in the approved objectives of scope of the project.

TRANSACTIONS AND CONTROLS

When accepting an award from a granting agency, the university certifies the following:

a. That we are requesting reimbursement for actual, allowable expenses for that particular project.
b. That we have accounting procedures and controls in place to prevent unallowable expenses from being charged to the project.
c. That we are not knowingly charging unallowable expenses to the project.

ORP Fiscal Management performs all requests for reimbursement from granting agencies. This is done either through invoicing agencies or performing letter of credit draw down procedures. ORP uses the expense data supplied through the university's FAS (Financial Accounting System) AMO reports. Fiscal Officers on grants and contracts receive a copy of this report on their 6-ledger grant account every month.

In order for ORP to determine the allowability of costs charged against grant accounts, all invoice vouchers, purchase requisitions and employment assignments are first forwarded to our office for proprietary approval.
This assist us in determining allowable and unallowable costs prior to transactions entering the 6-ledger grant account. This also reduces the need for cost transfers.

Because propriety approvals cannot be performed on p-card purchases, it is incumbent upon the Fiscal Officer of the grant account to insure that purchases made with p-card are allowable and meet the criteria established under the grant award.

Should any unallowable cost enter the system and reimbursement is requested for those costs, we must refund the amount of unallowable expenses to the granting agency. We would also be required to pay interest on those funds to the granting agency. As soon as it is determined that an unallowable cost has been posted to the grant account, a transfer of those costs to an appropriate account should be made as soon as possible.

EQUIPMENT

The Office of Management and Budget OMB Circular A-21 defines equipment as follows:

1. Equipment is tangible, nonexpendable personal property;
2. Equipment has a useful life of more than two (2) years;
3. Equipment has an acquisition costs of $5,000.00 or more;
4. Equipment acquisition costs can include modifications or accessories that make it useful for the purpose it was intended;
5. Equipment can include protective insurance, freight, and installation if the university' policy is to include it.


SIUE's definition of equipment as of July 1, 1999

1. Equipment is tangible, nonexpendable personal property;
2. Equipment has a useful life of more than two (2) years;
3. Equipment has an acquisition costs of $500.00 or more;
4. Equipment acquisition costs can include modifications or accessories that make it useful for the purpose it was intended;
5. Equipment can include freight, and installation.


Effects of the A-21 threshold on grants awarded based on the university's $500.00 equipment threshold:

1. Because of the university threshold, all equipment items purchased at $500.00 and above will be categorized as equipment on financial reports to the granting agency.
2. The F&A (indirect cost) will be less on grants with modified total direct costs (direct costs less equipment, each subcontracts over $25,000.00, stipends and fees)

Unless there is an equipment line and amount reflected in your awarded budget, equipment cannot be purchased under the grant without prior approval. Prior granting agency approval may be required for the purchase of equipment not in the approved budget. Allowances can be made for some items, with prior agency approval, because of the difference between the A-21 and university threshold for equipment. There are a few federal agencies that allow for the rebudgeting of other line items to the equipment line. Most state grants will not allow for the purchasing of equipment, unless it was initially proposed and appears in the approved budget. Please check with ORP if you require a modification and approval to your budget for the purchase of equipment.


If the purchase of equipment is allowable under your grant/contract, purchase the equipment at the beginning of your grant. Equipment purchases may be disallowed if purchased during the last few months of the grant period. Equipment purchased within the last 3-4 months of the grant period are considered questioned cost by auditors since equipment purchased with grant funds should be used or required for the performance of the activity conducted by the sponsored program.

SUBCONTRACTING VS. CONSULTING


The difference between a subcontractor and a consultant is outlined below. This outline should assist you in determining what vehicle to use to secure services under either of these categories.

SUBCONTRACT VS CONSULTING
WHEN TO USE
When an individual who is independent of the University is performing a significant part of the project or collaborating on the project. When an individual who is independent of the University is performing a small part of the project.
AGENCY APPROVAL
In many cases agency approval is required. Check the "Special Terms and Conditions" of the Grant or contact ORP for determination. In many cases agency approval is required. The "Special Terms and Conditions" for the Grant will indicate allowability or contact the ORP for determination.

WHEN AGREEMENTS ARE INITIATED (AGREEMENTS APPROVED IN THE BUDGET)

When the proposal was originally submitted to the funding agency, any subcontractor or individual who is to provide a substantial portion of the work on the project should have been identified.A subcontract will be prepared by ORP to the subcontractor and ORP will negotiate the terms and conditions of the subcontract. Call Jo Barnes for any subcontracting actions at ext. 5199. When the award has been received from granting agency, please contact ORP for assistance in preparing and initiating the appropriate documents to secure services of the individual. Call Jo Barnes at ext. 5199.
WHEN AGREEMENTS ARE INITIATED (AGREEMENTS NOT IN THE APPROVED BUDGET)
The principal investigator/project director should contact the ORP to initiate the subcontract. ORP will determine if agency approval is needed. The principal investigator/project can initiate a consulting agreement in cases where agency approval is not necessary. All agreements should be reviewed and approved by ORP and will be forwarded to the Office of the Provost for signature approval.


PAYMENT PROCESS

Based on the terms and conditions in the sub-contract, the subcontractor will submit invoices either monthly or quarterly to ORP. ORP will review the invoices and forward to the project director for review and approval. An initial purchase requisition will be generated for the full dollar amount. Upon receipt of each invoice from the subcontractor, the project director will prepare an invoice voucher, using the purchase order number assigned by the Purchasing Department. These documents should be forwarded to ORP for propriety signature. ORP will forward to the appropriate departments
for processing and payment. (subcontract)

Once the consultant agreement has been approved and signed a purchase requisition will be generated and the consultant agreement will be attached. If the consultant is to receive payment in a lump sum, an invoice voucher can be generated at the same time and attached to purchase requisition and consultant agreement. These documents should be forwarded to ORP, who will then forward to the appropriate departments for processing and payment. (consulting)

Important Considerations

1. Never have a consultant/independent contractor perform services prior to a consultant agreement being issued and approved.

2. If a significant or small portion of the work requires that specific expertise is to be provided by an outside consultant or agency, make sure to identify the individual/agency in your proposal by name. If not identified, the State of Illinois Procurement code will require that the work to be done will have to be subject to the bidding process and cannot be sole sourced.

3. All subcontract agreements must be prepared by the Office of Research and Projects


BUDGET REVISIONS/MODIFICATIONS

Budget revisions or modifications may be either performed internally, approved by the Office of Research and Projects or externally, approved by the Granting Agency.

Some agencies are flexible about re-budgeting and some have limitations on the percentage of the budget that can be revised. Whenever you anticipate a deviation from your approved budget, please give ORP a call. We will check the regulations and assist you in preparing your budget revision. Do not overspend in categories without first securing approval on your budget revision.

Please Contact ORP For The Type of Approval Required For Your Specific Rebudgeting Request

Internal Budget Revisions

The project director/principal investigator submitting a memorandum or a budget revision form (if supplied by granting agency) to ORP generally implements internal budget revisions. The memorandum or form should reflect the date of the request, what budget lines require modification and justification for the budget revision. The budget revision request should be addressed to the Director of Research and Projects and forwarded to ORP (campus box 1007). The revision is reviewed by ORP for the accuracy of the budget changes and the reasonableness of the justification. ORP will cite, on the submitted revision request, the appropriate agency expanded authority regulations on rebudgeting actions. The revision is approved by signature of the Director of Research and Projects. The approved original will be returned to the project director/principal investigator. Copies of the approved revision will be maintained in the ORP grant folder of the project and updated in the University FAS system.

External Budget Revisions

An external budget revision is mailed to the granting agency for prior approval. The project director/principal investigator submitting a memorandum or a budget revision form (if supplied by granting agency) to ORP/ORP implements the budget revision. The revision is reviewed by ORP for the accuracy of the budget changes and the reasonableness of the justification. A letter is prepared and sent via the Director of Research and Projects to the granting agency requesting the budget revision. Upon receipt of notification of the status of the request from the agency, ORP will forward such notification to the project director/principal investigator.

All budget revisions should include the following:

The budget categories that are affected should be listed with dollar amounts. The total amount of increases to budget categories must equal the total amount of decreases. Be aware that if the budget revision affects one of the following cost categories, then the indirect cost budget may need to be changed.

Salaries and wages*
Stipends (normally, this budget line cannot be revised on federal grants)
Tuition and Fees
Equipment
Rent of Buildings

*Budget revision under the salaries and wages category are carefully scrutinized with regard to any decrease in the level of effort by the principal investigator/project director or any key personnel identified in the project who are receiving compensation through the grant.


A justification is required explaining how and why the revision is needed. The justification should include:

a. Reasons for the additional expenditures in the cost categories that are being increased.
b. Reasons for the savings in the cost categories being decreased.

ALL BUDGET REVISIONS MUST BE APPROVED PRIOR TO SPENDING


HELPFUL TIPS FOR MANAGING YOUR GRANT OR CONTRACT

• Get prior approval on any budget revisions or modifications;
• Keep track of expenses - maintain all documents;
• Don't purchase equipment towards the end of the performance period of your grant;
• Don't send SIUE financial documents to your granting agency (i.e. FAS reports, payroll certifications, etc.)
• Don't sign contracts or agreements;
• Don't spend grant/contract funds after the termination date of your agreement;
• Encumber funds well in advance of the grant/contract termination date;
• Don't end your grant with a deficit balance;
• If cost sharing is anticipated to cover a portion of the project, spend your grant budget first. Charge all expenditures to the grant first, then begin using cost share;
• Submit cost share certifications to ORP at least on a quarterly basis; Keep supporting documentation on cost share file for potential audit review;
• Make sure you record time and effort correctly on quarterly Activity Reports;
• Make sure time and effort committed to the grant is met;
• Prepare personnel contracts (application for appointments, change of assignments, etc.) as soon as you receive your new FAS grant account number;
• Avoid transfers of costs as much as possible. Directly charged expenditures to your grant;
• Review your FAS reports every month;
• Call ORP for assistance with any post-award financial or non-financial matters;
• Use your department's P-card to purchase supplies and have charges billed directly to the grant account. Always consider cost principals and allowable cost issues when making purchases to the P-card. If you are unsure, call ORP.
• Do not prepare or submit financial reports to your funding agency. Please call ORP if there are any special considerations in this regard.

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