Post-Award Grants Manual 2012-2013
This electronic Grants Manual has been prepared as a resource for faculty who have received external or federal funding in order to provide the necessary resources to ensure a successful project. Although the College is legally accountable to the grant sponsor as the official recipient of a grant, the Principal investigator is responsible for the proper fiscal management and conduct of the project.
Pre-Award: Grant Proposal Guidelines
Congratulations on the approval of your grant! Now what?
Principal Investigator's Responsibilities
Budget and Expenditure Reporting
Salary and wages for Faculty, Staff and Students
Effort Certification Reporting Requirements
Procurement, Suspension and Debarment Requirements for Federal Grants
Expense Transfer Requests
Budget changes in a grant
No-cost Extension of a grant
Business Office Contact Information:
Pre-Award: Grant Proposals Guidelines
The Business Office has developed an Excel spreadsheet to assist with budgeting for all research grant proposals. Our goal is to make the budgeting side of grant proposals easier and more uniform throughout the college for a wide variety of grants. Research Proposed Budget Template
The premise of this budget process is that no research project carried on at the college exists independent of the college as a whole. Grants come to the college and not an individual because agencies recognize that a research grant requires the support of many areas of the college outside of the direct research. Therefore, there are certain set charges to grants as follows:
Indirect cost rate
Indirect costs charged to government grants represent reimbursement to the College for overhead items such as building and administrative support (heat, lights, space utilization, maintenance, etc.).
The indirect cost rate is negotiated by the Business Office with the Department of Health and Human Services (HHS) following a prescribed formula. For government grants, our pre-determined indirect cost rate is 56.0% of the total of all faculty or technician salaries/stipends and undergraduate student stipends. This rate is in effect for grants approved between July 1, 2012 through June 30, 2015, and after until the rate is amended by HHS. Indirect costs are rarely allowed on non-government grants and some government grants mandate a set rate percentage.
For all grant proposals that include salaries or stipends, there should also be a budgeted line item for benefits. This will be 35% of salaries for part-time or full-time employees charged to the grant, and 10% for faculty summer stipends. The 35% rate may be subject to change as the cost of providing benefits increases. The rate or rates used in the budget will be the actual charge out rate regardless of changes. For student stipends, the benefit rate should be budgeted at 10%. We use the same benefit rate for all grants regardless of type or size so that all are treated equally under the budget guidelines.
There may be some grants on which benefits are not allowed, a lower indirect cost rate is applicable, or that have a cap of some level for total charges. We ask that the budget for all grants include all charges anticipated by the research or program, even those that may be covered by matching funds from a non-federal grant or college funds. By including all anticipated costs, the College is in a better position to make a decision regarding the grant proposal. Once the Dean of the College Office approves the grant, they will determine where the additional funds will come from to meet the total budget expenses and communicate that to the Business Office.
Student stipend/per hour rate
The hourly wage rate is established as part of the college budget process, which means you will need to use an estimated rate on the proposal. Please check with Corporate and Foundation Relations or the Business Office to assist in estimating the rate to use. If awarded, actual rates will be used during the grant period. The current break rate is $9.24/hour.
Congratulations! Upon Receipt of a new grant
Faculty who have received a new grant are encouraged to participate in a post-award orientation meeting with the Assistant Comptroller in the Business Office. This meeting is especially important if this is the Principal Investigator’s (PI) first time managing a grant at Carleton College.
Post-award orientation provides an opportunity to discuss the grant award, policies and procedures, and to familiarize the new PI with the resources available. Please contact Barbara Fowler, Assistant Comptroller, to schedule the post-award orientation meeting.
Once the College has received the official award notification, Corporate and Foundation Relations contacts the Business Office in order to assign an account number to the grant. All expenditures and other financial activity for the grant are tracked using this number. The PI, and anyone else they authorize, will have online access to their grant activity on the Hub. The following documents need to be received before the account number may be established:
- Official award document
- Awarded project proposal and budget
- Signature Authorization form (individuals authorized to approve charges)
The Business Office will assist with the overall financial administration of the grant including processing payment requests, purchase orders, invoicing and drawdowns, following standard accounting practices and adhering to College and federal regulations. We will also assist the PI with compliance and other grant related procedures or questions, and provide quarterly budget-to-actual spreadsheets for his/her grant. The Business Office will retain grant documents for ten years following the expiration of the grant.
- Comply with all terms and conditions imposed by the sponsor and the College
- Ensure that project funds are managed efficiently and effectively within approved budgets
- Initiate all required approvals for budgetary and programmatic changes
- Prepare timely submission of technical reports
- Complete and sign all employment authorization forms for all employees charged to the grant
- Sign all payment requests and purchase orders charged to the grant
- Include proper documentation with all payment requests including original receipts, detailed descriptions of the purchase, and any additional information (i.e brochure or flyer) to explain the nature of the expenditure if necessary
- Certify the accuracy of budget reports on a quarterly basis
Budget and Expenditure Reporting
Project Investigators (PI's) and the College share responsibility for proper fiscal management of the grant award. To facilitate effective budget management, each PI is given electronic access to their grant activity via The Hub at the time they receive an award. The PI is required to authorize all spending from the grant award and monitor activity on a monthly basis. The PI may also designate others as authorized to approve charges on the grant. Discrepancies should be communicated immediately to the Business Office for resolution. PI's must be familiar with allowable costs (see Allowable Expenditures for additional detail).
On a quarterly basis (effective December 31, 2011) the Business Office will prepare a budget-to-actual report for each grant and e-mail it to the PI. Budget overruns are prohibited by federal regulation and must be avoided. If a budget overrun is noted, it is the responsibility of the PI to initiate a transfer within 90 days of the date of the expense causing the deficit (see Cost Transfers for additional detail). The PI will be required to review the report and certify the accuracy of the charges by signing and dating a copy of the quarterly report and returning it to the Business Office. The certification statement reads, "I hereby certify that I have reviewed the grant expense and budget report attached and confirm that they accurately reflect expenses related to and allowable for the purposed of the grant." Reports will be sent at the end of the month following the close of each quarter ending March, June, September and December. The certification statement is due by the 15th of the following month (May 15, August 15, November 15 and February 15).
Please contact Human Resources before hiring an employee or independent contractor to ensure they are correctly classified. Employees hired to work on a grant administered by the College must complete new employee orientation with Human Resources. These are typically technician positions hired specifically for a grant and must be funded by the grant budget.
Faculty budgeted to receive summer stipends must submit the Stipend Request Form to the Business Office for payroll processing.
Summer salary stipends for faculty research are calculated as 1/9 (one month) or 2/9 (two months) of the previous academic year contract, and must be identified in the approved grand budget. After-the-fact Time and Effort Certification is obtained in the fall (see Time and Effort Reporting) to confirm summer activity. Stipends may be requested during the performance period.
Faculty acting as a project director or performing other significant work on a grant may receive a course release in lieu of direct compensation for effort expended on a grant.
A course release represents 1/5 of a normal teaching load and may be calculated up to 1/5 of actual academic contract for faculty PI. Carleton may elect to charge the grant less than the stated proportion of actual contract. Time and Effort Certification is required following course release work.
Please contact the Student Financial Services office for assistance when hiring student researchers.
Workshop and other compensation
Payments to faculty for work performed outside of their normal academic contract should be requested using the Stipend Request Form and submitted to the Business Office. Workshop stipends must be requested after the even has been completed.
Full-time exempt employees under contract with Carleton College are not eligible to receive additional compensation from government grants.
PIs who draw 2/9 summer salary from an NSF grant are prohibited from receiving additional compensation from other NSF Grants per NSF guidelines.
Effort Certification Reporting Requirements
As a recipient of federal funds, Carleton College must comply with the Office of Management and Budget (OMB) Circular A-21 (Cost Principals for Educational Institutions). Section J.10 requires certification of effort to document salary expenses charged directly or indirectly against federally sponsored projects. This process ensures that salary and wages are properly expended and that actual effort is consistent with the originally budgeted effort. Carleton’s effort reporting policies and procedures are intended to meet this requirement.
Carleton uses an “after-the-fact effort reporting” system to comply with the federal effort certification requirement. Under this system, the distribution of salaries for employees working on federally funded projects will be supported by Time and Effort Certification Reports. Hourly employees and student workers will not receive a form as their time is certified via electronic time sheets. Recipients of workshop stipends and other onetime payments will not be required to complete the form either.
Time and Effort Certification reporting will reasonably reflect the percentage distribution of effort by Carleton faculty and exempt employees charged to federally funded projects. Effort is not determined based on a 40 hour week, but rather on total hours worked. It is based on 100% of activities for which you are being compensated, including sponsored and non-sponsored activities, for a given time period. Effort is expressed as a percentage.
Each employee will complete and sign his/her effort certification. Federal requirements stipulate that anyone certifying another individual must have first-hand knowledge of that individual’s actual effort.
Time and Effort Certification reports will be required twice per year as it applies to your specific grant. The Business Office will distribute the form in June for the academic year and again in September for the summer.
Procurement, Suspension and Debarment Requirements for Federal Grants
Carleton College is prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred by the federal government. The College will assure compliance with this federal regulation with confirmation from the System for Award Management (SAM) (https://www.sam.gov). SAM will be checked before making a sub grant or contract award of any amount to an outside organization. Third party payments associated with federal grants will be reviewed against SAM prior to payment of $25,000.00 or more. The Business Office should be contacted before entering into a sub-award arrangement. A Vendor Selection Form is required to be submitted for equipment purchases of greater than $5,000.00 which will include the SAM check.
Grant expenditures are processed through Accounts Payable. All expenditures are reviewed to ensure they are allowable under the terms of the grant, within the allowed time period, properly authorized and adequately documented. If the invoice does not provide adequate information as to the nature of the charge and how it relates to the grant project, please supply other supporting documents or narrative.
The following policies have been provided in order to provide clear guidance as to what costs constitute appropriate charges to federally funded projects, as well as to achieve consistency with college policies.
The cost principles relating to expenditures on federal awards are contained in the OMB Circular A-21 grid provided below. While the list is long, some excluded items to note are:
- Alcoholic beverages
- Entertainment costs
- Personal expenses or purchases
- Participant support costs not specifically addressed in your award letter
- International travel costs not specifically addressed in your award letter
Additional Related College Policies:
Please see the Employee and Travel reimbursement policy if travel is allowed on the grant. Foreign travel using federal funds must have prior approval from the sponsoring agency, and airfare must be purchased on an American flag carrier (Fly America Act). College travel policies apply.
The Principal Investigator is responsible for purchasing equipment in accordance with College purchasing policy. For equipment purchases over $5,000, the Vendor Selection Form must be completed.
OMB Circular A-110, Section C.34 provides guidance for the handling of inventory of equipment of $5,000 and above, and a useful life of service of one year or more, purchased with federal funds.
Cost sharing or matching is that portion of a total sponsored project’s costs that are paid from sources other than the funds provided by the sponsor (non-federal share). Cost sharing or matching agreements should be approved during the proposal stage. After the grant is awarded, it is useful to meet with the Assistant Comptroller and those “contributing” to the match to clarify what form the match will take, and the time line over which it will be provided.
It is the Principal Investigator’s responsibility to verify and document that the match has been fulfilled. The documentation should be forwarded to the Assistant Comptroller in the Business Office for review.
The basic cost allowability test for the cost share or match (non-federal share of expenses) per OMB Circular A-110, Section .23 includes the following:
- Are verifiable from the recipient’s records
- Are not included as contributions for any other federally-assisted project or program
- Are necessary and reasonable project expenditures
- Are allowable under applicable cost principles
- Are not paid by the Federal Government under another award except where authorized by Federal statute to be used for cost sharing or matching
- Are provided for in the approved budget when required by the Federal awarding agency
- Conform to other provisions of Circular A-110, as applicable
The non-federal share of grant expenses must be identified and supported by documentation, which may be obtained from the following:
- Evidence of cash received (sources, deposit)
- Evidence of expenses (payroll, Effort Reports, Purchase orders, invoices, etc.)
- Volunteer services (Effort Reports to the extent feasible)
Expense Transfer Requests and Audit Red Flags
To comply with the cost allowability requirements of OMB Circular A-21, it is necessary to explain and justify transfers of charges into federal awards from other accounts. When cost transfer cannot be avoided, the following guidelines apply:
- Explanation of cost transfer must be clearly stated and sufficient for an independent federal reviewer to conclude that it is appropriate
- Transfer to grant accounts should be requested within 90 days of the expense (inappropriate expenses to a grant can be removed without a deadline)
- Cost transfers that effect payroll where effort certification applies require a revised certification form to be completed by the affected employee
- Cost transfers made solely for the purpose of spending down grant funds are not allowable
- Cost transfers must be authorized by the PI or an authorized member of the project team
Although cost transfers cannot always be avoided, the following have been identified as audit red flags:
- Excessive number of cost transfers
- Transfers made near the end or after the project period has expired resulting in increased expenses
- Transfers that give the appearance of moving deficits from one federal project to another
- Transfers made with inadequate supporting documentation
- Transfers made more than 90 days after the discovery of an error
Budget changes in a grant
Most funding agencies permit changes in budgets up to a certain level without prior approval. Principal Investigators are expected to understand the budget limitations of their grants prior to overspending any budget category.
Prior approval from the sponsoring agency may be required for:
- Changes in scope of the project including rebudgeting of more than 25% of the total award
- Changes in status of key personnel (withdrawal from project; absence for continuous period of three months or more; reduction of time devoted to project by 25% or more from approved level)
- Deviation from award terms and conditions
- Transfer of costs between direct and indirect costs
- Foreign component added to a grant
- Need for additional funding
- Use of budgeted participant funds for other categories
Requesting a No-cost extension of a grant
The sponsoring agency will provide the project period dates on the award document. As the project end dates approaches, the PI may wish to extend the project period to finish the project, providing grant funds remain. No-cost extensions may not be requested for the sole purpose of spending down remaining funds.
Federal grants are managed on a cash reimbursement basis. On a quarterly basis, the Grant Manager in the Business Office will prepare a request for reimbursement. That reimbursement request will be reviewed by the Assistant Comptroller and submitted for electronic reimbursement.